On 17th May 2021, the Australian Prudential Regulatory Authority (APRA) released some key dates for the industry around APRA Connect preparedness. APRA Connect test environment will be made available from 17th June 2021 and the first submission in production commences from 13th September 2021. With only a few months away from go live, entities must ramp up their resourcing in readiness for APRA Connect testing and go live.
APRA, in their recent communication, called out the need for entities to allocate resources to facilitate the transition to the new solution. Also, each entity will need to assign regulatory reporting administrator for APRA Connect via a separate D2A form RRA: APRA Connect test nomination.
Below is a snapshot of the immediate reporting requirements via APRA Connect for each industry.
*as of latest announcements.
The introduction of APRA Connect will impact all regulated industries this year while Superannuation industry being the most impacted with 9 new returns to be submitted via APRA Connect from September 2021 as part of Super Data Transformation (SDT) initiative.
APRA released the technical artefacts for the SDT Phase 1 data collections in APRA Connect back in April this year. In this article, our team shares their key observations about APRA Connect so far.
Taxonomy and Validations
D2A has been around since 2001 and has been supporting submission of returns that contain aggregated data in a specific reporting format. Over time, APRA has developed a standardised reporting taxonomy for all returns submitted via D2A. This taxonomy is also compliant with the Standard Business Reporting (SBR) standard. APRA incorporated SBR into its taxonomy in 2011.
D2A supports XBRL based submissions allowing entities that are SBR compliant to develop a common reusable process for preparing reporting submissions for all government agencies that are SBR compliant e.g., ATO, ASIC, APRA etc. For more information on SBR/XBRL and its benefits, read our previous article here.
APRA released APRA Connect taxonomy for SDT Phase 1 returns submission in March 2021. This included a set of excel files containing data dictionary, validations, and reporting taxonomy.
APRA has not made a Plain English Taxonomy (PET) version of the taxonomy available for APRA Connect.
The Validations published for APRA Connect is significantly different to APRA’s current approach for publishing data validations for D2A. APRA currently publishes D2A validations on a regular basis. These validations are constructed using the reporting taxonomy hence referring to the attribute codes in the taxonomy. The D2A validation rules use standard expressions (e.g. “=“) as well as certain APRA specific expressions. The APRA specific expressions are documented and available for entities to interpret the rule.
APRA is yet to publish the definitions for the expressions being utilised in APRA Connect validations.
Below is an example of APRA Connect rule compared with D2A.
In addition to the above, APRA has also released an XSD file that contains the technical validations that must also be considered while preparing the data set for submissions. Below is an example of the different types of technical validations being enforced by APRA in APRA Connect. Entities must consider these rules in their preparation of submission file regardless of their preferred method of submission format e.g. XML or XLSX.
There are 2 ways in which data can be submitted to APRA. Manual entry or automated submission via uploading a file in APRA acceptable format.
D2A currently accepts upload file in D2A XML format or XBRL format across all returns. The D2A XML format is tightly linked to the APRA reporting taxonomy that is available on the PET website.
APRA confirmed in the webinar held in April 2021 that the new platform APRA Connect will support only specific submission formats for each returns that is defined by APRA. For Super Data Transformation (SDT) Phase 1 returns, APRA Connect will accept XML (APRA connect specific format) or excel upload format only.
Manual entry method is still available however users cannot copy paste information into multiple cells (available in D2A currently).
Summary of key differences between D2A and APRA Connect
Below is a summary of the key differences between APRA Connect and D2A.
Granular data submission
An important consideration for entities is to also take into account the type of data being submitted in APRA Connect. APRA’s data strategy is centred around granular data collection. For the Super industry, as part of the SDT Phase 1 program, APRA has introduced 9 new returns to be submitted via APRA Connect. All of these returns consist of underlying tables with multiple columns. Below is a snapshot of number of data points required to be submitted via APRA Connect for Super industry as part of SDT Phase 1. This highlights the magnitude of data being collected in this new platform.
The introduction of APRA Connect technology on its own will have a significant impact on the regulated industry in particular on the existing regulatory reporting processes and systems in place for submissions. In parallel, the industry will be asked to submit much more granular data to the regulator on the new platform introducing its own set of challenges around ensuring appropriate data governance, data quality, meeting compliance requirements, increased scrutiny by the regulator etc.
Entities are faced with the challenge of dealing with both these major changes at the same time. The risk of not being prepared in time for APRA Connect go live can have major consequences such as delayed or incorrect submissions to APRA and future cost overruns in remediating processes and systems for APRA Connect submissions.
RegConnect was launched in readiness for APRA Connect so that our clients can focus on the wider regulatory challenges around granular data collection, while RegConnect automating their submission process on D2A as well as APRA Connect with minimal deployment effort.
RegConnect is currently available for deployment and is always up to date with the latest APRA Connect taxonomy, validations and submission model released by APRA. To know more about RegConnect, check out the video here or get in touch with one of our product experts who can walk you through how we can get you setup for APRA Connect submissions in a matter of weeks and not months.
We also host regular demo webinars. You can register here for an upcoming demo of RegConnect.