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Frequently asked questions - Pandemic Data Collection

A separate FAQs page on Superannuation trustees' response to COVID-19 can be found here. Reporting forms and instructions can be found on the Reporting requirements for superannuation page.


1. Are any superannuation entities not required to report this collection?

Some superannuation entities are exempted from the Pandemic Data Collection (PDC). These are Exempt Public Sector Superannuation Schemes (EPSSS’), Small APRA Funds (SAFs), Single Member Approved Deposit Funds (SMADFs) and Pooled Superannuation Trusts (PSTs).  EPSSS’, SAFs, SMADFs and PSTs will not be issued PDC reporting forms in D2A.  

Whilst noting the above, should any EPSSS entities wish to be involved in the PDC and be issued PDC forms in D2A, APRA is willing to receive submissions from these entities, please contact

2. Will data that is commercial sensitive (e.g. Fraud data) be published at the Registerable Superannuation Entity (RSE) level?

At this time APRA intends to only publish the data collected through the PDC at the industry level.

3. For the monthly collection, will all three months within the June 2020 quarter be reported at once?

A monthly form (SRF 921.0) has been developed to capture this data. For the June 2020 quarter, a completed form for each month (April, May and June) will need to be submitted. Following this quarter, data will be reported monthly (15 business days after the end of the month).

4. When is the reporting of the pandemic collection due?

The first submission is due 31 July 2020. This first submission captures the April, May and June 2020 reporting periods in SRF 921.0 (monthly form), the June 2020 reporting period in SRF 921.1 (quarterly form) and the April 2020 reporting period in SRF 921.2 (once off ad-hoc form). Following this initial collection, the SRF 921.0 will be due on the 15th business day following the end of each month and the SRF 921.1 will be due on the 15th business day following the end of the quarter.

5. How long will the PDC continue for? 

The PDC will continue until issues that are being faced by RSE licensees relating to the COVID-19 pandemic have abated. In this regard, a review of the continued need for the PDC will occur in late September 2020.

6. What is the purpose of the PDC?

The purpose of the PDC is to allow APRA to understand the impact of the COVID-19 pandemic on the superannuation industry, as well as provide reporting and insights to government and other agencies. 

Key elements of the PDC:

  • provide APRA with enhanced early release of superannuation data including demographic data;
  • provide APRA and ASIC with monthly data on complaints, insured member accounts that have been cancelled, insurance claim activity and intra-fund advice provided; and
  • provide APRA with quarterly data on investment options, foreign currency exposure and hedging and member switching.

7. Is there a character limit in the free text fields within D2A?

The character limit for free text fields in D2A is 4000 characters


Monthly reporting (SRF 921.0)

Reporting forms and instructions can be found on the Reporting requirements for superannuation page.

8. For income protection insurance claims, is the monthly benefit or the value of the claim at duration to be reported?

The monthly benefit is to be reported for income protection insurance claims.

9. Is ‘claim duration’ the time between receipt of claim and payment or the time between receipt of claim and claim determination?

Claim duration refers to the time period between receipt of claim and claim determination.

10. For Life and TPD insurance, does the value of the claims to be reported in item 3 ‘Insurance claims’ on SRF 921.0 include the account balance of the member?

No, only the insurance component should be reported in this section. The superannuation balance which is released under a condition of release should not be included in this value.

11. Are false claims on Early Release Initiative (ERI) payments where the member was found to be ineligible required to be reported in the fraud section on SRF 921.0? 

No, the ineligible claims are not to be reported in this collection and therefore should not be reported in this section.

12. Does ‘insurance claims finalised’ in SRF 921.0 refer to the finalisation of the claim by the insurer or by the RSE licensee?

A claim is finalised when the final decision has been made on the claim and this decision has been communicated to the claimant.


Quarterly reporting (SRF 921.1)

Reporting forms and instructions can be found on the Reporting requirements for superannuation page.

Foreign currency exposure and hedging

13. Our fund’s foreign assets are invested in a managed investment trust and are hedged by the manager. We do not currently use derivative financial instruments to hedge against foreign currency movements but our underlying investment manager does. How should I report this in the template?

There is no need to report on the foreign assets in a managed investment trust that are hedged by the underlying manager.  Item 1 should include those that are managed directly by the RSE and be reported at the RSE level.

14. Should I report notional principal of our foreign exchange (FX) hedging program under Items 1.1, 1.2 and 1.3 and the unrealised gains/(losses) under Item 1.4?

Yes, for Items 1.1, 1.2 and 1.3 report the notional principal of the FX hedging program and report in Item 1.4 the corresponding unrealised gains/(losses). Item 1.1 refers to internally managed FX hedging and Item 1.2 refers to externally managed FX hedging (e.g. managed by an external FX overlay manager). Report the corresponding amount of notional principal into the respective rollover dates in Items 1.3.1, 1.3.2, and 1.3.3. For Item 1.4, report positive (+) value for unrealised gains and negative value (-) for unrealised losses.


Investment by investments option

15. How should I report our RSE’s MySuper product given that its underlying investments are managed by our external fund managers under mandates? For example the underlying investments are held in both pooled investments and in direct investments - should I report the whole value of MySuper under internally managed (column 7)?

Yes, you should report the full value of your RSE’s MySuper under the internally managed column (column 7). Columns 8-10 applies to investment options available on your investment menu (e.g. platforms) that are managed by external managers under mandate (column 8), pooled investments (column 9), or direct assets/securities, e.g. ASX listed securities (column 10).

16. Should I include Defined Benefit (DB) assets in the ‘Investments by investments Option’ section

DB assets are not required to be reported in this section.

17. I have > 30 days notice accounts in my cash assets. Where do I report them in terms of liquidity?

These should be reported under ‘Illiquid assets - > 30 days’ (column 15) if no notice has been provided. If notice has been provided, it will be reported in either ‘Liquid assets <= 3 days’ (column 13) or ‘Liquid assets > 3 days to 30 days’ (column 14) depending on the number of days the deposits is expected to be received. 

18. Our liquidity stress testing is performed periodically but does not coincide with the period requested for in the collection. What data could I submit to APRA? Also, we perform a number of scenarios for our liquidity stress testing. Does APRA have a specific scenario it expects to be reported on?

APRA requests that RSEs submit the results of the liquidity stress testing performed closest to the reporting date requested, including any ad-hoc stress testing. APRA does not have a specific scenario for reporting purposes, but suggests that RSE reporting is based upon the scenario that that results in the worst liquidity position for a particular investment option. This means the scenario chosen can be different for different investment options. 

19. Can I aggregate reporting into a single line item for certain products? 

Yes, this would be allowed for direct assets or securities. For example, where ASX 200 listed securities are offered in member direct product, this can be reported as a single line item, e.g. ‘ASX 200’ with aggregate value reported in ‘Direct assets / securities’ column rather than separately listing each name and value of ASX listed security in multiple rows.

20.  When is an investment considered illiquid?

An investment is considered illiquid when it cannot be redeemed within 30 days. 

21. If a RSE has not been able to compile investment information by the due date is prior period data acceptable until the reference period is available?

If a RSE is not able to access and compile any of the data points contained in the pandemic collection by the due date then the RSE should contact APRA at to discuss any alternate actions that can be taken. 

Any data that is ready at the due date should be submitted. RSEs should not wait to source missing data before submitting data that is available.

22. Is reporting in Item 3 ‘Investments by investment option’ on SRF 921.1 required to be done on a look through basis?

Look through reporting is not required as the data is collected at the investment option level. For example, the liquidity profile of the option under columns 8-12 is to be reported based on the level of liquid assets of the option, not based on the liquidity of downstream trusts or vehicles.

23.  How is cash defined e.g. are term deposits cash?

Cash is defined as cash on hand and demand deposits, as well as cash equivalents. Cash equivalents represent short-term, highly liquid investments that are readily convertible to known amounts of cash and which are subject to an insignificant risk of changes in value. This is consistent with definitions provided in relevant accounting standards. Term deposits can be considered cash as they represent money placed in an ADI for a fixed period for a stated interest rate. Cash also includes certificates of deposits.

24. How are platforms supposed to report Item 3 ‘Investments by investment option’ and item 4 ‘Member switching’ on SRF 921.1? 

Item 3 is to be reported at investment option level. Reporting into a single line is allowed for certain investments such as direct assets (see separate FAQ and reporting instructions for further detail). Item 4 is to be reported at investment option level, and the form allows for platform specific process through application and redemptions columns for those platforms without switch functionality or those who use a cash account intermediary for switching. See further details in the reporting instructions.


Member switching

25. I have a lifecycle product, can I report switching at the lifestage level instead of the product (i.e. whole of lifecycle) level?

The intention is to capture members moving from MySuper products (including lifecycle products) to choice products, as such product level switching data is appropriate. However, it is acceptable to report lifestage level switching if this is easier to do so.


ERI payment demographics 

26. Should demographics be provided for all members?

No, demographic information is only required for those members who have received an ERI payment.

27. Is the ‘Members’ benefit bracket (after ERI payment has been made) in item 5 ‘ERI payment demographics’ on SRF 921.1 the bracket the member account is in after the ERI payment or the bracket the member account is in at the end of the quarter? 

The bracket the member account is in at the end of the reporting period is to be reported.


Insurance cancellation (SRF 921.2)

Reporting forms and instructions can be found on the Reporting requirements for superannuation page.

28. What does an insurance cancellation refer to?

An insurance cancellation notice refers a communication or notice which warns the member that the trustee will stop providing insurance cover unless the member takes a specific course of action to avoid it. It does not refer communications or notices informing the member that their insurance cover has been cancelled.

For more information

Email or mail to

Senior Manager, Superannuation Strategic Insights - Data Analytics and Insights
Australian Prudential Regulation Authority
GPO Box 9836, Sydney NSW 2001