New financial reporting and auditing requirements for APRA superannuation funds

On 12 August 2021, the Federal Government released for consultation a draft Bill setting out proposed financial reporting and auditing obligations for registrable superannuation entities (i.e. APRA regulated entities). The consultation period ended on 13 September 2021.

The underlying purpose of these changes is to increase transparency within the superannuation industry and to continue to broaden individual member engagement with their superannuation account.

Financial reporting requirements

The current financial reporting regime for APRA regulated superannuation funds requires them to prepare, and have audited, financial statements and lodge related annual APRA returns within three months of the year-end i.e. by 30 September for the vast majority of the population. They are also required to submit quarterly APRA returns over the course of a year. These financial statements are prepared based on the accounting standard AASB 1056 Superannuation Entities.

The draft Bill transfers financial reporting obligations from within the APRA regime to ASIC, and essentially proposes to treat registrable superannuation entities as listed companies for financial reporting purposes by amending various sections of Part 2M of the Corporations Act 2001 (the Act). If the draft Bill is passed, registerable superannuation entities will have the following obligations as outlined below.


Registerable superannuation entities will need to prepare a half-year financial report and directors’ report, and the half-year financial report must be reviewed or audited. These documents will then be lodged with ASIC within 75 days of the end of the half-year.

Annual periods

Registrable superannuation entities will also need to prepare an annual financial report and directors’ report, and the financial report must be audited. The directors’ report must include:

  • Additional information regarding the extent of non-audit services provided, although further clarity is required as to the definition of what constitutes non-audit services, and
  • A remuneration report (audited) for key management personnel, the details of which are included in regulations that have yet to be published. It is therefore uncertain whether any final requirements will be more or less extensive than what is required in a remuneration report for a listed company. All superannuation funds currently include disclosures around key management personnel remuneration, some of which do so in some detail, hence this is not expected to be a significant step forward.

Within three months of the end of the financial year, a registrable superannuation entity must report to members by making a copy of the above documents available on its web site, and also lodge them with ASIC. Currently, only the Trustee Company is required to publish their financial statements on its website, although in reality a number of superannuation funds also do this to ensure transparency and to act from a governance better practice perspective.

Financial statements for sub funds

An important point to note is that the draft Bill proposes to require both the half-year and annual financial statements to be prepared for each sub fund. This is likely to be a very onerous task for registrable superannuation entities and results in more onerous financial reporting obligations than what is currently required for listed entities.


The current financial reporting regime for superannuation funds is already extensive and, as such, the proposed changes are not significant in nature. Whilst we are in favour of any financial reporting developments that promote increased transparency and good governance, this should not be at the broader costs to members, and should not be set at a level that is more onerous than what is currently expected from ASX listed entities.

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