Email: DCS Subscriber Update 13 – 13 December 2019

Dear subscriber,

As the year comes to a close, the APRA Data Collection Solution project team would like to share some insights from recent industry feedback.

Entity engagement about the new Data Collection Solution implementation approach

As advised in October 2019, APRA has been exploring alternative implementation approaches for the new solution. In late October and early November, APRA engaged a cross-section of industry representatives to explore the benefits and impacts of contrasting approaches.  Entities were also asked about the impact of continuing to report through D2A after March 2020.  Some interesting themes which emerged were:

• Many entities are keen to involve RegTechs to support the uplift of their capability and move from manual to automated submission processes, and set them up for future, more granular data collections
• Entities want APRA to engage with them early in relation to our future data collection roadmap.  This will help entities plan their future technology uplift for regulatory reporting. When looking at future data collections, entities called out the complexity of changing the actual data within a collection, especially where they rely on service providers to help them submit data.
• There was tolerance for continuing to use D2A after March for a limited period, however some concerns were raised about an implementation approach which would require continuing two systems (D2A and new solution) in the longer term
• Entities confirmed that resubmission of past returns (which may be required if all existing collections were migrated in their current form), would create a significant burden.

The feedback from participants has been valuable in shaping the revised implementation approach for the project, which will be communicated in early 2020.  Entities appreciated the opportunity to engage openly with APRA, and APRA looks forward to sharing more information and continuing to work closely with the industry on the implementation of the new solution.

Insights into current and future data submission practices – results of D2A survey 

In August and September 2019, APRA conducted a survey of D2A reporting entities’ current and intended future state submission practices and channels. The responses represented good coverage of entities across regulated industries and have provided valuable insights to inform the implementation of the new solution.

Some interesting statistics and observations include:

• A large majority of entities submit the majority of forms manually and therefore do not use file upload (XML or XBRL)
• While the majority of entities intend to continue submitting manually in the new solution, nearly 30% of respondents anticipated an increase in the number of forms that will be submitted via automated submission channels (file upload and APIs) in the new Data Collection Solution. 
• A number of respondents expressed interest in using APIs in the future to submit returns and anticipate around 12% of forms will be submitted using APIs, across all industries.

APRA is pleased to see support for more fit-for-purpose submission methods and an anticipated uplift in use of automation in the new solution.

It is important that entities are aware that manual entry will operate differently in the new solution compared to D2A. For manual submissions, copy and paste functionality will only work for single cell values, which means that entire tables can no longer be copied across.

APRA encourages entities to consider the implementation of the new solution as an opportunity to enhance and evolve submission practices, and will encourage further discussion of this with the industry in 2020, as we continue to consult on new and revised data collections.

And finally…

We’d like to thank our subscribers for your continued interest and engagement in this project throughout 2019, and we look forward to switching on APRA’s new Data Collection Solution later next year. On behalf of APRA, the project team wishes all our subscribers and entities a very happy and safe festive season.

Best wishes

Daniel Hunt,
Business Lead, Data Collection Solution project