3. Implementation approach and timing
Last updated: 30 July 2019
APRA is managing a complex solution design, project schedule and a wide range of internal and external risks and interdependencies
APRA is taking a measured approach to implementing the new Data Collection Solution. Part of this approach involves considering entity readiness for adoption of the new solution, data feeds to other government agencies and the replacement of the whole-of-government authentication tool – AUSkey.
Originally scheduled for March 2020, the go-live date for the new solution will now be later in 2020
APRA assessed the feasibility of the previously advised go-live date of March 2020 considering project complexities identified in the design phase, additional scope, external dependencies as well as industry feedback. The go-live date for the new solution will now be later in 2020.
D2A will remain available after March 2020 to ensure entities can continue to meet their reporting obligations while the new solution is being finalised. APRA remains committed to consulting with industry and providing regular updates on further key decisions.
APRA will provide time for entities to prepare for the transition
APRA is committed to providing entities with time to prepare for the transition including the provision of a testing environment to enable their readiness. All reporting entities will need to be ready to use the new solution by the go-live date to ensure they meet their reporting obligations. APRA will not grant extensions to entities that are not prepared for transition to the new solution, and the option to submit via email, mail or fax will no longer be available.
APRA will continue to engage with established external advisory groups and industry bodies throughout the transition
APRA will continue to engage with the Strategic Industry Reference Group (SIRG) and Technical Working Group (TWG) as advisory groups representing industry preferences and perspectives on the implementation and transition to the new solution. Additionally, APRA will continue to engage with the Software Vendor Working Group (SVWG) to ensure the RegTech community is actively involved in the transition to the new solution.
APRA will also continue to work closely with industry bodies and provide regular updates to communicate key information to entities. This will ensure that industry preferences and risks are carefully considered throughout the transition to the new solution.
Managing implementation risks
As with all large-scale technology-related projects, APRA is committed to managing and mitigating risks. APRA has a risk management framework in place with assurance processes to ensure risks are considered and appropriate mitigation plans and contingencies are in place.
Since commencing design in April 2019, APRA has identified additional complexities relating to the constraints built into D2A as well as the dependencies of critical applications. As a result, APRA has decided to revise the target date for both go-live and the availability of a fully secure test environment. APRA will provide additional information by October 2019 about the revised go-live date, and the date when the test environment will be available. APRA will continue to work closely with the SIRG and TWG advisory groups to discuss key risks and mitigation strategies.
APRA will ensure D2A remains available after March 2020 so that entities can meet their reporting requirements until the new solution is finalised. APRA is working closely with the Australian Taxation Office for the rollout of the new whole-of-government authentication method, myGovID to align timelines and reduce risk for the commencement of the testing and go-live. Further information will be provided at a later date.