Financial Sector (Collection of Data) (reporting standard) determination No. 3 of 2025

EXPLANATORY STATEMENT

Prepared by the Australian Prudential Regulation Authority (APRA)

Financial Sector (Collection of Data) Act 2001, sections 13 and 15

Acts Interpretation Act 1901, section 33

Under subsection 13(1) of the Financial Sector (Collection of Data) Act 2001 (the Act), APRA has the power to determine reporting standards, in writing, with which financial sector entities must comply. Such standards relate to reporting financial or accounting data and other information regarding the business or activities of the entities. Subsection 33(3) of the Acts Interpretation Act 1901 provides that where an Act confers a power to issue an instrument the power shall, unless the contrary intention appears, be construed as including a power exercisable in the like manner and subject to the like conditions (if any) to revoke any such instrument.

Subsection 15(1) of the Act provides that APRA may declare a day on and after which the reporting standards are to apply.

On 30 April 2025, APRA made:

(1)         Financial Sector (Collection of Data) (reporting standard) determination No. 3 of 2025 which:

(i)           revokes Reporting Standard SRS 101.0 Definitions for Superannuation Data Collections (SRS 101.0) made under Financial Sector (Collection of Data) (reporting standard) determination No. 10 of 2024; and

(ii)        determines a new version of SRS 101.0 (New SRS 101.0).

The instrument commences at the start of the day after the day the instrument is registered on the Federal Register of Legislation.

1. Background

APRA is empowered to make reporting standards under the Act, which require regulated institutions, including RSE licensees, to submit specified data through various reporting forms. Data from these forms are used internally to assist APRA’s supervisory functions and by other agencies such as the Australian Bureau of Statistics and the Australian Securities and Investments Commission. APRA also collates and publishes statistical information and analysis using data from these reporting forms.

SRS 101.0 sets out definitions relating to reporting required under APRA’s superannuation reporting standards.

In January 2025, APRA determined one new superannuation reporting standard to capture data on registerable superannuation entity (RSE) licensee financial statements and redetermined one superannuation reporting standard to capture data on investment and transaction fees and costs.

In March 2025, APRA determined five new reporting standards to capture data on RSE licensee profile, RSE profile and investment reporting and redetermined four reporting standards to capture data on RSE Structure, RSE Profile, Insurance and Asset Allocation.  

APRA also updated SRS 101.0 to include the definitions as required in light of these new and revised reporting standards.

2. Purpose and operation of the Legislative Instrument

The purpose of the instrument is to revoke SRS 101.0 and to replace it with the New SRS 101.0. The updated reporting standard sets out definitions relating to reporting required under APRA’s superannuation reporting standards.

Explanation of each provision in the instrument

Authority – paragraph 1

This paragraph outlines APRA’s authority to determine reporting standards that are required to be complied with by relevant financial sector entities under section 13 of the Act.

Application and commencement – paragraphs 2 – 4

These paragraphs state which financial sector entities, reporting standards and reporting periods the reporting standard applies to, and when the reporting standard begins to apply.

General – paragraph 5

This paragraph provides a general instruction that terms defined in the reporting standard appear in bold italics.

Interpretation – paragraph 6

Paragraph 6 states that unless the contrary intention appears, a reference to an Act, Regulation, Prudential Standard, Australian Accounting or Auditing Standard is a reference to the instrument as in force or existing from time to time.

Overview – paragraph 7

This provision states that definitions in the reporting standard are listed alphabetically.

Definitions

This section lists key terms used in APRA’s superannuation reporting standards and provides their definitions.

Documents incorporated by reference

Under paragraph 14(1)(a) of the Legislation Act 2003 (Legislation Act), the standard incorporates the following documents by reference as in force from time to time:

• Acts of Parliament and associated delegated legislation;
• Prudential Standards determined by APRA, except Prudential Standards relating to superannuation; and
• Australian Accounting Standards determined by the Australian Accounting Standards Board under section 334 of the Corporations Act 2001 (Cth).

These documents may be freely obtained at www.legislation.gov.au (all documents listed above except for the Australian Accounting Standards), and https://www.aasb.gov.au/pronouncements/accounting-standards/ (the Australian Accounting Standards).

Under paragraph 14(1)(b) of the Legislation Act, the standard incorporates the following documents from the time that the instrument commences:

• Prudential Standards determined by APRA under subsection 34C(1) of the Superannuation Industry (Supervision Act) 1993 relating to superannuation. These Prudential Standards may be freely obtained at www.legislation.gov.au.
• Reporting Standards determined by APRA under subsection 13(1) of the Act that relate to superannuation. These Reporting Standards may be freely obtained at www.legislation.gov.au.
• the Australian Securities and Investments Commission’s (ASIC) Regulatory Guide 97 (‘Disclosing fees and costs in PDSs and periodic statements’) (RG 97) dated March 2017. This document provides guidance on how fees and costs should be disclosed in Product Disclosure Statements and periodic statements and can be freely accessed and used by members of the public at: https://asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-97-disclosing-fees-and-costs-in-pdss-and-periodic-statements.
• ASIC RG 97 dated September 2020. This document provides guidance on how fees and costs should be disclosed in Product Disclosure Statements and periodic statements and can be freely accessed and used by members of the public at: https://asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-97-disclosing-fees-and-costs-in-pdss-and-periodic-statements.

The standard also requires entities to report against the following standards and codes as a matter of fact:

• ISO 3166, ISO 4217, ISO 6166 and ISO 17442 – The standard requires financial sector entities to report certain items with a two-letter ISO 3166 country code, a three-letter ISO 4217 currency code, a twelve-character alpha-numeric ISO 6166 financial instrument code and a 20-digit ISO 17442 Legal Entity Identifier code. ISO 3166, ISO 4217, ISO 6166 and ISO 17442 are internationally recognised codes for the representation of countries, currencies, and legal entities developed by the International Organization for Standardization (ISO). Financial sector entities are aware information relevant to the two-letter ISO 3166 country code, the three-letter ISO 4217 currency code, the twelve-character alpha-numeric ISO 6166 financial instrument code, and the 20-digit ISO 17442 Legal Entity Identifier code is widely available online with the relevant links being available in the standard.
• APIR codes – The standard requires financial sector entities to report certain items using standard identifiers for Responsible Entities, Trustees and other participants in the Australian wealth management industry. Financial Sector entities are aware that information relevant to the APIR codes is freely available online with relevant links being available in the standard.
• Development Status Groups classification – The standard requires financial sector entities to report against an economy’s classification against the Development Status Group Classification developed by the United Nations Conference on Trade and Development (UNCTAD). Financial Sector Entities are aware that information relevant to the Development Status Group classification is freely available online with the relevant links available in the standard. The link is: https://unctadstat.unctad.org/en/classifications.html.
• Committee On Uniform Security Identification Procedures (CUSIP) identifiers – The standard  requires financial sector entities to report certain items using identifiers issued under the CUSIP system. Financial sector entities are to report these items using the CUSIP identifiers where available.
• Committee On Uniform Security Identification Procedures International Numbering System (CINS) – The standard requires financial sector entities to report certain items using identifiers issued under the CINS system. Financial sector entities are to report these items using the CINS identifiers where available.
• Options Clearing Corporation (OCC) Option Symbol - The standard requires financial sector entities to report certain items using identifiers issued under the Options Clearing Corporation's (OCC) Option Symbology Initiative (OSI). Financial sector entities are to report these items using the OCC identifiers where available.
• Stock Exchange Daily Official List (SEDOL) identifiers – The standard requires financial sector entities to report certain items using identifiers issued under the London Stock Exchange's Stock Exchange Daily Official List. Financial sector entities are to report these items using the SEDOL identifiers where available.

The contents of these standards and codes is not relevant to understanding the New SRS 101.0 and accordingly the New SRS 101.0 does not incorporate by reference the contents of these standards and codes.             

3. Consultation

APRA conducted consultation for this instrument.

In November 2023, APRA released publicly, the consultation package on proposed changes to superannuation reporting to include proposed enhancements for the collection of data on investments (including indirect investment costs), RSE, and RSE licensee profiles and RSE licensee financials.

Nine submissions were received from RSE licensees and industry bodies in response to the consultation package.

In September and December 2024, APRA released responses to consultation, incorporating the feedback received from industry into the final version of the reporting standards.

APRA is satisfied the consultation was appropriate and reasonably practicable.

4. Regulation Impact Statement

The Office of Impact Analysis advised that a Regulatory Impact Statement was not required for the consultation relating to investments (including indirect investment costs), RSE, and RSE licensee profiles and RSE licensee financials.

5. Statement of compatibility prepared in accordance with Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011

A Statement of compatibility prepared in accordance with Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011 is provided at Attachment A to this Explanatory Statement.

6.    Legislative instrument – disallowance and sunsetting

The instrument is a legislative instrument for the purposes of the Legislation Act. In accordance with section 44 of the Legislation Act and item 3 in paragraphs 9 and item 6 in paragraph 11 of the Legislation (Exemptions and Other Matters) Regulation 2015 (Legislation Regulation), the instrument is not subject to disallowance or sunsetting under the Legislation Act on the grounds that the instrument relates to superannuation. The Explanatory Statement to the Legislation Regulation states:

“Item 3 is an instrument (other than regulations) relating to superannuation. This item preserves the exemption in item 39 of the table in subsection 44(2) of the Legislative Instruments Act. This exemption exists because exposure of superannuation instruments to disallowance would cause commercial uncertainty, as well as uncertainty for superannuation fund members and providers. These instruments are intended to have enduring operation and are not suitable for the disallowance process.”

“Item 6 is an instrument (other than a regulation) relating to superannuation. This item preserves the exemption in item 42 of the table in subsection 54(2) of the Legislative Instruments Act. Sunsetting of instruments relating to superannuation could cause commercial uncertainty, as well as uncertainty for superannuation fund members and providers. These instruments are intended to have enduring operation and it would not be appropriate to subject them to sunsetting.”

As detailed above, appropriate consultation with industry stakeholders occurred prior to the finalisation of the instrument. APRA conducts regular reviews on its reporting standards, which range from post-implementation reviews to targeted reviews of specific standards or aspects of standards. 

ATTACHMENT A

Statement of Compatibility with Human Rights

Prepared in accordance with Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011

Financial Sector (Collection of Data) (reporting standard) determination No. 3 of 2025

This Legislative Instrument is compatible with the human rights and freedoms recognised or declared in the international instruments listed in section 3 of the Human Rights (Parliamentary Scrutiny) Act 2011 (HRPS Act).

Overview of the Legislative Instrument

The purpose of the Legislative Instrument is to revoke Reporting Standard SRS 101.0 Definitions for Superannuation Data Collections (SRS 101.0) made under Financial Sector (Collection of Data) (reporting standard) determination No. 10 of 2024 and to replace it with a new version of SRS 101.0. The Legislative Instrument will facilitate APRA’s collection of certain information provided to APRA by financial sector entities under certain reporting standards. The Legislative Instrument sets out definitions relating to the reporting required under those reporting standards.

Human rights implications

APRA has assessed the Legislative Instrument and is of the view that it does not engage any of the applicable rights or freedoms recognised or declared in the international instruments listed in section 3 of the HRPS Act. Accordingly, in APRA's assessment, the Legislative Instrument is compatible with human rights.

Conclusion

This Legislative Instrument is compatible with human rights as it does not raise any human rights issues.