Reasonable assurance and limited assurance are central to the standard. These terms are defined by reference to the Framework for Assurance Engagements issued by the Auditing and Assurance Standards Board (AUASB). Reasonable assurance is a high but not absolute level of assurance, expressed positively that the subject matter conforms in all material respects with the criteria. Limited assurance is a moderate level of assurance, expressed in a negative form (e.g. nothing has come to the auditor's attention that indicates the subject matter is not in accordance with criteria). The standard applies reasonable assurance to the auditable annual returns listed in Attachment A, except for six items where no assurance is required (friendly society items, statement of policy liabilities, assets backing policy liabilities, claims and disputes). Limited assurance is applied to the annual review of systems, procedures and internal controls.

Auditor independence and fitness are prerequisites. The life company must ensure its auditor satisfies the eligibility criteria in Prudential Standard CPS 520 Fit and Proper, is a fit and proper person under the life company's own fit and proper policy, and meets the independence requirements of Prudential Standard CPS 510 Governance. This means the auditor cannot have conflicts of interest or relationships that impair objectivity, and the life company's board must have a process for assessing the auditor's ongoing suitability.

Tripartite arrangements describe the default mode of APRA liaison with the auditor, involving APRA, the life company and the auditor. However, paragraph 15 expressly permits bilateral meetings between APRA and the auditor at any time, on request of either party. This creates an important pathway for confidential communication outside the presence of the life company, consistent with the auditor's duty to report under section 88(2).

Statutory fund accounting is addressed in paragraph 33. For the purposes of section 47(1) of the Act, the income and outgoings of a statutory fund are determined according to the reporting standards under the Collection of Data Act. This provision eliminates any ambiguity about whether alternate accounting bases (such as Australian Accounting Standards) might apply for that statutory purpose; the prudential reporting standards govern.

Special purpose engagements are distinct from the annual audit and internal control review. They are triggered by a written request from APRA and may cover matters beyond the normal scope of the auditor's statutory functions. APRA can specify the scope, and may depart from AUASB standards if it considers, having regard to the nature of the life company's operations, that an alternative standard is more appropriate. The life company bears the cost, which is uncapped and could be substantial for a targeted forensic review.

Working paper retention is a seven year obligation for the auditor (paragraph 17). On written request, the auditor must provide those working papers to APRA. No claim of legal professional privilege or confidentiality is recognised in the text. This is a significant compliance burden for auditors, who must store and be able to retrieve potentially large volumes of documentation for a protracted period.

Ascertainment of income and outgoings (paragraph 33) ties statutory fund accounting directly to the Collection of Data Act reporting standards. This means that the content of those standards directly determines what counts as income or outgoings for a statutory fund, which in turn affects the calculation of policy liabilities, distributable profits and capital adequacy.

The standard directly affects three groups: life companies (including friendly societies) registered under the Life Insurance Act 1995, auditors appointed under section 83 of that Act, and APRA as the prudential regulator. Indirectly, the standard affects policy owners, the boards and audit committees of life companies, and third party contractors who provide services to life companies.

Life companies must appoint an auditor (section 83(1) of the Act) and are responsible for ensuring that auditor meets the independence and fit and proper requirements. They must provide the auditor with access to all relevant data, information, reports and staff, and take all reasonable steps to ensure access to contractors. They must inform the auditor of all prudential requirements and any other information APRA has provided to the company that may assist the auditor. They must submit the auditor's reports to APRA by the due date for the annual returns under the Collection of Data Act. When APRA requests a special purpose engagement, the life company must arrange for its auditor (or another approved auditor) to perform the work and must pay the cost.

Auditors are the central actors. Their responsibilities include preparing the reasonable assurance report on the specified annual returns and the limited assurance report on internal controls, providing those reports to the life company addressed to the Board, retaining working papers for seven years, and reporting to APRA under section 88(2) when certain thresholds are met. The auditor must have regard to AUASB standards but must comply with this standard where inconsistency arises. The auditor may meet with APRA bilaterally and must not place sole reliance on work performed by APRA.

Boards and audit committees receive the auditor's reports, associated assessments and any APRA commentary. The life company must ensure these materials are provided to the Board or audit committee. Special purpose engagement reports go to the Board or audit committee simultaneously with APRA. The Board also receives the auditor's report on annual returns and internal controls. This imposes a governance obligation: the board cannot simply delegate oversight of auditor matters to management.

Contractors are indirectly affected because the life company must take reasonable steps to ensure the auditor has access to them. This includes outsourced service providers, actuarial consultants, IT vendors, and any other third party whose work is relevant to the life company's operations, risk management or financial reporting. The standard does not impose direct obligations on contractors, but they may be required to cooperate with the auditor under their contracts with the life company.

APRA gains explicit powers to request special purpose engagements, adjust or exclude specific requirements for a life company (paragraph 34), request terms of engagement and correspondence from the life company (paragraph 11), and request auditor's working papers. APRA also receives the auditor's reports on annual returns and internal controls and may engage in tripartite or bilateral discussions with the auditor.

Policy owners are the ultimate beneficiaries of the assurance framework, but the standard does not confer any direct rights on them. The auditor's duty to report under section 88(2) is designed to protect their interests, but the decision whether to report and whether to inform the life company rests with the auditor, subject to the guidelines in paragraph 32.

Duties of the life company. The life company must appoint an auditor (section 83(1) of the Act, reflected in paragraph 6). It must ensure the auditor satisfies the eligibility criteria, is a fit and proper person, and meets independence requirements (paragraph 7). It must grant the auditor access to data, information, reports, staff, and take reasonable steps to ensure access to contractors (paragraph 8). The company must ensure the auditor is fully informed of all prudential requirements and of any other information APRA has provided that may assist the auditor (paragraph 9). The company must ensure that the auditor's reports, APRA's responses and any company commentary on the auditor's reports are provided to the Board or audit committee (paragraph 10). On APRA request, the company must provide terms of engagement, instructions and correspondence that may bear on the auditor's work (paragraph 11). The company must submit the auditor's reports to APRA by the due date for the annual returns (paragraph 12). When APRA requests a special purpose engagement, the company must arrange for the auditor to undertake it and bear the cost (paragraphs 26 and 29). The company must ensure the auditor can access the Board, audit committee and internal auditors (paragraph 8 footnote reference).

Duties of the auditor. The auditor must prepare a reasonable assurance report on the annual returns listed in Attachment A, specifying whether they are reliable and in accordance with prudential requirements, and whether prudential requirements in relation to accounting for statutory funds have been met (paragraphs 19 to 21). The auditor must prepare a limited assurance report on the life company's systems, procedures and internal controls, including specifically controls relating to actuarial data integrity and financial reporting risks (paragraphs 23 to 24). The auditor must provide both reports to the life company, addressed to the Board (paragraphs 22 and 25). The auditor must retain all working papers for seven years and provide them to APRA on written request (paragraph 17). The auditor must have regard to relevant AUASB standards (paragraph 13) and must not place sole reliance on APRA's work (paragraph 16). The auditor must comply with the obligation to report to APRA under section 88(2) of the Act when circumstances warrant (paragraphs 31 to 32). If undertaking a special purpose engagement, the auditor must submit the final report to APRA and the Board simultaneously within three months (paragraph 30).

Rights of the auditor. The auditor has the right to access all relevant data, information, reports, staff and contractors of the life company (paragraph 8). The auditor has the right to access the Board, Board Audit Committee and internal auditors (paragraph 8). The auditor may meet with APRA bilaterally at any time (paragraph 15). The auditor is entitled to receive from the life company information about all prudential requirements and any other information APRA has provided to the life company (paragraph 9). The auditor is entitled to engage with the life company on a tripartite basis with APRA (paragraph 15). In relation to special purpose engagements, the auditor may be a different person from the appointed auditor if APRA agrees (paragraph 27).

Rights of the life company. The life company may request from APRA an adjustment or exclusion of a specific requirement in the standard (paragraph 34). The life company may seek APRA's agreement to use an alternative auditor for a special purpose engagement (paragraph 27). The life company is entitled to receive the auditor's reports addressed to the Board and may provide commentary or responses to APRA (paragraphs 10 and 22). The company's previous exercises of discretion under the earlier version of the standard continue to have effect (paragraph 35).

No rights for policy owners directly. The standard does not create a private right of action for policy owners against the life company or auditor. The auditor's duty to report to APRA under section 88(2) is owed to the regulator, not to individual policy owners.

The standard itself does not prescribe monetary penalties or imprisonment terms. Enforcement operates through several mechanisms:

Criminal offence for false or misleading information. Paragraph 18 explicitly warns that providing false or misleading documents or information to a Commonwealth entity such as APRA may attract serious offences under sections 137.1 and 137.2 of the Criminal Code 1995. These are strict liability offences in part, with maximum penalties of 12 months imprisonment (for documents) and five years imprisonment (for information) depending on the circumstances. This applies to any person involved in providing information to APRA, including life company officers, staff and the auditor.

Breach of prudential standards as a statutory contravention. The Life Insurance Act 1995 makes compliance with prudential standards determined under section 230A a requirement for authorised life companies. Non-compliance can lead to APRA exercising its enforcement powers under the Act, including directions to comply, imposition of additional capital requirements, restrictions on business operations, and ultimately revocation of authorisation. The standard does not elaborate on these consequences but they flow from the Act itself.

Auditor's statutory duty to report. The obligation under section 88(2) to report to APRA if a contravention may significantly prejudice policy owners is backed by the potential for criminal penalty under the Act if the auditor knowingly fails to report. The Act does not specify a penalty for breach of that section, but it is a serious duty that courts have recognised as intended to protect the public interest.

APRA's power to require information. Under paragraph 11, APRA can request the life company to provide terms of engagement, instructions, correspondence and management letters that have a bearing on the auditor's work. Refusing that request or providing incomplete information could lead to APRA issuing a notice under section 62 of the Act requiring production of documents, with penalties for non-compliance.

Working paper retention. Failure to retain working papers for seven years (paragraph 17) might be treated as a breach of the prudential standard, triggering APRA's enforcement powers. APRA can also request those papers in writing; failure to produce them could be a separate breach of the standard and potentially an offence if the auditor deliberately destroys or conceals documents.

Special purpose engagement enforcement. A life company that fails to arrange a special purpose engagement when APRA requests one, or fails to ensure timely submission of the report within three months, is in breach of the standard. APRA could issue a direction requiring compliance or treat the failure as evidence that the life company is not being conducted in a sound and prudent manner.

No civil penalty provisions in the standard itself. Unlike some financial sector legislation, this prudential standard does not specify civil penalties. The enforcement is indirect, through the general powers of APRA under the Life Insurance Act. The practical cost for a life company of non-compliance includes adverse regulatory findings, higher capital requirements, reputational damage and potential loss of authorisation.

APRA's discretion to adjust or exclude requirements. Paragraph 34 gives APRA the power to adjust or exclude a specific requirement for a particular life company by written notice. This is a enforcement flexibility, not a penalty, but it allows APRA to tailor requirements or impose additional conditions when it detects weaknesses.

Life Insurance Act 1995. This is the primary legislation under which the standard is made. Section 230A confers the power to determine prudential standards. The standard cross-references several other sections of the Act: section 21 (registration of life companies), section 47 (statutory fund accounting), section 83 (appointment of auditor and duty to make arrangements), and section 88 (auditor's obligation to report contraventions). The standard's requirements are functions of the auditor for the purposes of subsection 83(2), meaning they are part of the auditor's statutory duties.

Financial Sector (Collection of Data) Act 2001. The standard relies heavily on this Act for the reporting forms that are subject to audit. The annual returns listed in Attachment A are reporting standards made under the Collection of Data Act. The due date for submitting the auditor's reports is linked to the due date for the life company's annual returns under that Act. Paragraph 33 also provides that the ascertainment of income and outgoings of statutory funds for the purposes of section 47(1) of the Life Insurance Act is governed by those reporting standards. This creates a direct interdependence: any amendment to a reporting standard under the Collection of Data Act automatically affects the scope of the auditor's reasonable assurance opinion under LPS 310.

Prudential standards CPS 510 Governance and CPS 520 Fit and Proper. Paragraph 7 of LPS 310 requires the auditor to satisfy the eligibility criteria in CPS 520 and the independence requirements in CPS 510. This means the auditor must be assessed under those standards by the life company. The life company's fit and proper policy must specifically address the auditor. If CPS 510 or CPS 520 are amended, the eligibility criteria for auditors under LPS 310 are automatically updated, subject to any transitional provisions in those standards.

Criminal Code 1995. As noted, paragraph 18 alerts the auditor and other persons involved in providing information to APRA of the offences under sections 137.1 and 137.2. This creates a criminal law overlay on the audit process. Any document or information provided to APRA, whether by the life company or the auditor, must be accurate and not misleading.

AUASB Standards and Guidance Statements. The auditor must have regard to these standards when preparing reports, to the extent they are not inconsistent with the prudential requirements. This means AUASB standards are a default but can be displaced by APRA's requirements. For special purpose engagements, APRA can override AUASB standards entirely if it considers an alternative standard more appropriate. This gives APRA a powerful tool to demand audits that do not follow standard auditing methodologies.

Common law and equitable duties of auditors. The standard does not displace the auditor's common law duties of care and skill owed to the life company and potentially to third parties. Rather, it adds a public law dimension. An auditor who complies with LPS 310 may still be liable in negligence if the audit is conducted carelessly. Conversely, compliance with LPS 310 is evidence of meeting professional standards but not a complete defence.

Corporations Act 2001. Life companies that are companies limited by shares also have obligations under the Corporations Act, including financial reporting and auditing requirements. The LPS 310 audit is separate from the annual statutory audit under the Corporations Act. The standard's requirement for reasonable assurance on the prudential returns does not replace the Corporations Act audit of financial statements; it is an additional layer of assurance. This duplication increases compliance costs but is intended to address the particular prudential risks of life insurers.

Section 137.1 and 137.2 Criminal Code interaction with whistleblower protections. If an auditor reports a contravention to APRA under section 88(2), that report is covered by the standard's confidentiality provisions (paragraph 32) and may also be protected under whistleblower laws in the Corporations Act or the Public Interest Disclosure Act 2013 (Cth). The standard does not address whistleblower protections but they would apply separately.

This instrument, Life Insurance (prudential standard) determination No. 14 of 2023, is the current version. It revokes the previous determination No. 11 of 2023, which made the immediately prior version of Prudential Standard LPS 310. The revocation and re-determination took effect on 18 December 2023, with the instrument signed on 21 November 2023.

No earlier versions are provided in the source text, but the structure of paragraph 35 ("Previous exercise of discretion") indicates that there have been earlier versions of LPS 310. The existence of determination No. 11 of 2023 implies that there were at least two versions before the current one: the original LPS 310 made at some point after the commencement of section 230A of the Life Insurance Act, and the version under No. 11 of 2023. The current version is essentially a consolidation or refinement of the previous version.

The standard's objectives and key requirements box at the start of the schedule appears unchanged from the previous version in substance, but the specific provisions may have been adjusted. The following notable changes can be inferred:

• The elimination of the old version and replacement with this one means any earlier specific requirements that are not reproduced are no longer in force.
• The transitional provision at paragraph 35 ensures that any APRA exercise of discretion (approvals, waivers, directions) granted under the previous version continues to have effect under the corresponding power in the new version, provided such a power exists. If a previous discretion related to a requirement that has been removed, it effectively lapses.
• The Attachment A list of auditable annual returns may have been updated to reflect changes in reporting standards under the Collection of Data Act. The standard does not indicate any additions or removals.
• The determination itself is a Commonwealth instrument registered on the Federal Register of Legislation. It is legislative in character, not merely administrative.

The amendment process reflects APRA's practice of periodically updating prudential standards to reflect changes in the industry, lessons from regulatory experience, or alignment with international standards. Life companies and auditors must ensure they are using the current version and not relying on the earlier No. 11 of 2023.

The next amendment is likely to occur when APRA next reviews its prudential framework for life insurance, or when there are changes to the underlying legislation or reporting standards. The standard is subject to periodic review in APRA's cycle of policy development.

No litigation specific to LPS 310 is recorded in the source text. The standard was made in late 2023 and is relatively new. To the extent that previous versions of LPS 310 have been the subject of litigation, that is not disclosed in this instrument.

However, the legal context is relevant. The auditor's duty to report to APRA under section 88(2) of the Life Insurance Act has been judicially considered in other proceedings, though no cases are cited in the standard. The confidentiality provision at paragraph 32 (not disclosing the report to the life company if it may jeopardise policy owner interests or if the auditor has lost confidence in management) reflects a cautious approach that may have been informed by past controversies.

Possible areas of future litigation include:

• Scope of the auditor's duty. A life company might dispute whether a particular matter triggered the reporting obligation under section 88(2), especially if the auditor reported to APRA without first informing the board. The standard gives the auditor discretion not to inform the company, which could lead to disputes about the reasonableness of that decision.

• Access to contractors. Paragraph 8 requires the life company to take "all reasonable steps" to ensure the auditor can access contractors. If a contractor refuses to cooperate, the life company could be in breach. A life company might argue it took all reasonable steps, while APRA might disagree. This could lead to contested enforcement.

• Cost of special purpose engagements. The life company bears the cost (paragraph 29), which could be substantial. A life company might challenge the necessity or scope of a special purpose engagement as unreasonable, but the standard does not provide for an appeal mechanism. APRA's decision to request the engagement is discretionary and may be judicially reviewed only on narrow grounds.

• Working paper retention and privilege. The standard requires the auditor to retain working papers for seven years and provide them to APRA on written request (paragraph 17). Auditors may resist on grounds of legal professional privilege if some working papers contain legal advice. The standard does not address privilege, and courts may need to resolve conflicts between the prudential standard and common law privilege.

• Enforcement actions. Any enforcement action by APRA against a life company or auditor for alleged breach of LPS 310 could be challenged in the Federal Court or the Administrative Appeals Tribunal. No decisions have been reported to date.

The lack of litigation history means the standard has not been tested in court. Life companies and auditors should proceed cautiously, as the scope of requirements like "reasonable belief" (paragraph 8) and "significant prejudice" (paragraph 31) are open to interpretation.

Several provisions in LPS 310 deserve careful reading because they create obligations that may not be obvious at first glance.

No assurance on six annual return forms. Attachment A lists 21 annual returns, but six have the level of assurance marked as "None". These are: Friendly Society Related Items, Statement of Policy Liabilities, Assets Backing Policy Liabilities, and Claims and Disputes. The auditor is not required to express any opinion on those returns. But the life company must still submit them accurately. The absence of auditor assurance does not reduce the company's liability; it simply means there is no independent check. A life company that relies on the auditor's work to catch errors in those forms will be disappointed.

Limited assurance on internal controls is a separate opinion. Many readers equate "audit" with the annual financial report. LPS 310 requires two separate auditor outputs: one reasonable assurance opinion on the annual returns, and a limited assurance opinion on the design and operating effectiveness of internal controls (including actuarial data integrity). The limited assurance opinion is not a guarantee; it is expressed in the negative (nothing came to the auditor's attention). The board should not take this as strong comfort. The auditor also provides limited assurance on quarterly data reliability, even though quarterly returns are not themselves audited.

Auditor must address reports to the Board, not management. Paragraphs 22 and 25 require the auditor's reports to be addressed to the Board of the life company. This procedural requirement has legal significance: the board receives the reports directly, and management cannot intercept or modify them before they reach the board. The life company must also ensure the board receives APRA's commentary and the company's responses. This creates a clear governance channel.

Seven year retention period is mandatory. Paragraph 17 requires the auditor to retain all working papers for seven years from the date of the report. This period cannot be shortened even if the auditor ceases to act for the life company. The auditor must also provide those papers to APRA on written request. No exemption for commercial sensitivity or privilege is expressed. Auditors should budget for storage costs and ensure their document retention policies comply.

APRA can override AUASB standards for special purpose engagements. Paragraph 28 allows APRA to write to the life company stating that an alternative standard must be used for a special purpose engagement, instead of the usual AUASB standards. This means the auditor may be required to follow a methodology that is unfamiliar or less established. The life company cannot object; it must arrange for the auditor to accept those terms.

Cost of special purpose engagement is unlimited and immediate. Paragraph 29 says the cost will be borne by the life company. There is no cap, and APRA is not required to consider the proportion of the cost to the company's revenue or capital. A small friendly society could face a disproportionate expense for a targeted review. There is no right to challenge the cost as unreasonable.

Confidentiality of reports to APRA under section 88(2). Paragraph 32 instructs the auditor not to disclose the fact of a report to APRA to the life company if the auditor considers that policy owner interests may be jeopardised or if the auditor has lost confidence in the board or senior management. This puts the auditor in a difficult position: the auditor is contracted by the life company but may be required to conceal from it that a report to the regulator has been made. This creates a risk of professional liability if the company later discovers the report and argues it should have been informed.

Previous exercise of discretion may not be saved. Paragraph 35 continues the effect of previous APRA discretions only "as though exercised pursuant to a corresponding power (if any)" under the new standard. If the new standard does not contain a corresponding power, the previous discretion lapses. Life companies that had specific approvals or waivers under the old LPS 310 should check whether those approvals remain valid; if not, they must reapply to APRA.

Access to contractors is subject to "reasonable steps". Paragraph 8 requires the life company to take "all reasonable steps" to ensure the auditor can access contractors. This is not an absolute guarantee. If a contractor refuses access despite the company's best efforts, the company may still be in breach if a court or APRA considers that more steps should have been taken. The standard does not define what "reasonable steps" means.

Compliance with LPS 310 requires a coordinated effort by the life company's board, management, internal audit, and the appointed auditor. The following steps are grounded in the standard's provisions.

Step 1: Appoint a compliant auditor. Ensure the auditor meets the eligibility criteria in CPS 520 Fit and Proper, is a fit and proper person under the company's fit and proper policy, and satisfies the independence requirements of CPS 510 Governance. This means conducting a fit and proper assessment before appointment and periodically thereafter. The board or audit committee should document the assessment.

Step 2: Provide access. The life company must grant the auditor access to all relevant data, information, reports and staff. This includes giving the auditor direct access to the Board, Board Audit Committee and internal auditors. The company should also take reasonable steps to ensure contractors (e.g. outsourced service providers, actuarial consultants) provide access. This may involve adding clauses to contractor agreements requiring cooperation with the auditor.

Step 3: Inform the auditor. The company must fully inform the auditor of all prudential requirements applicable to the company. This includes not only LPS 310 and other prudential standards but also any APRA guidance, letters or directions. The company should maintain a register of prudential requirements and share it with the auditor. Additionally, the company must provide the auditor with any other information APRA has provided to the company that may assist the auditor (paragraph 9). This is a broad obligation.

Step 4: Prepare and submit auditor reports. The auditor will prepare two principal reports: the reasonable assurance report on the annual returns listed in Attachment A, and the limited assurance report on systems, procedures and internal controls. The life company must submit those reports to APRA on or before the due date for the annual returns under the Collection of Data Act (paragraph 12). The due dates are set by APRA's reporting standards; compliance requires aligning the audit timetable with those dates.

Step 5: Provide reports to the board. Paragraph 10 requires the life company to ensure that the auditor's reports, any APRA commentary on them, and any company responses are provided to the Board or Board Audit Committee. This means the board must receive the reports, not just management. The company should establish a process for distributing these documents promptly.

Step 6: Respond to APRA requests. If APRA requests the terms of engagement, instructions or correspondence (paragraph 11), the company must provide them within a reasonable time. The company should keep a file of all engagement letters, instructions and management letters exchanged with the auditor. If APRA requests a special purpose engagement (paragraph 26), the company must arrange for the auditor to undertake it, bearing the cost, and ensure the final report is submitted to APRA and the board within three months (unless APRA grants an extension).

Step 7: Ensure auditor retains working papers. The auditor has an obligation to retain all working papers for seven years. The life company should confirm that the auditor has appropriate document retention policies. If the company changes auditor, the outgoing auditor must still retain the papers for the remainder of the seven year period. The company should include a provision in the engagement letter requiring the auditor to comply with paragraph 17.

Step 8: Monitor auditor's ongoing compliance. The life company should periodically check that the auditor remains eligible, fit and proper, and independent. If the auditor becomes compromised (e.g. through a conflict of interest), the company must take steps to address it, potentially appointing a new auditor.

Step 9: Handle special reports under section 88(2). The company should be aware that the auditor may report to APRA without informing the company if certain conditions exist (paragraph 32). While the company cannot prevent this, it should maintain open communication with the auditor to reduce the likelihood of the auditor losing confidence in management.

Step 10: Maintain records of APRA exercises of discretion. If APRA has granted any approvals, waivers or directions under previous versions of LPS 310, the company should verify whether those discretions are preserved under paragraph 35. If not, the company should seek new approvals.

Step 11: Budget for compliance costs. The standard imposes direct costs: auditor fees for the reasonable and limited assurance engagements, potential special purpose engagement costs, internal time for providing access and information, and storage costs for working papers. The board should consider these costs when approving the annual audit plan. The limited assurance report on internal controls is a separate engagement from the financial audit and may require additional scoping.

Step 12: Engage with APRA on adjustments. If a specific requirement is impracticable or disproportionate for the life company, it may request APRA to adjust or exclude that requirement under paragraph 34. The request should be in writing and set out the reasons. APRA is not obliged to grant the request, but the existence of this power suggests APRA is open to tailored treatment where justified.