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Letters

Increased transparency of general insurance and life insurance data

Wednesday 18 August 2021

Published 18 August 2021

In 2020, APRA released a consultation proposing to determine general insurance (GI) class of business and life insurance (LI) product group data – that is submitted to APRA - to be non-confidential1. APRA also proposed to begin publishing explanations from individual insurers in relation to material revisions to, or large movements in, their data, including whether or not APRA requested the revision. 

This letter outlines APRA’s decisions on these proposals including its response to the submissions received during the consultation2.

Proposal 1: Determine class of business and product group data to be non-confidential

 

APRA will implement the proposal to determine class of business and product group data to be non-confidential. 

By publishing more of the data that APRA collects, APRA aims to promote greater transparency in the LI and GI industry in line with APRA’s prudential objectives3.  In turn, this will support competition, contestability and efficiency in the financial system and facilitate innovative uses of data. Additional benefits include:

  1. Informing the public: publishing more of the data APRA collects will generate greater consumer understanding and more informed public discussion of insurance-related issues; and informed decision-making for all users of the GI and LI statistical publications4.
  2. Influencing by comparison: promote better practices through comparability and peer review, facilitating analysis and understanding of observed trends and maintaining confidence in the Australian financial system.
  3. Driving accountability: encourage insurers to act with discipline and encourage better, more efficient market behaviour. 

Submissions were generally supportive of the intent of APRA’s initiative, albeit there were some concerns raised.

A number of respondents raised concerns about APRA publishing or otherwise disclosing class of business/ product group data for individual insurers. APRA will not be publishing insurer level data from reporting forms beyond that already published.  Should APRA plan in the future to expand the publication of insurer level data to include class of business / product group data for specific entities, APRA will formally need to consult on any such proposals at that time with industry.

APRA’s determination will only impact APRA’s existing publications of aggregate industry data.5 In practice it will result in APRA reporting a very limited number of data items which were previously masked in these publications. All reporting items impacted are outlined in Appendix A of this letter.

APRA has strict procedures and processes in place when considering requests to release data and will continue to respect any potential commercial concerns relating to the data collected from insurers.

Proposal 2: Publishing explanations from individual insurers

 

Respondents were generally concerned that this may result in the release of commercially sensitive information at an insurer level. In response to these concerns, APRA has decided not to proceed with this proposal.  

Additional feedback

 

APRA sought feedback on the question of how long data items should remain confidential to avoid market sensitive disclosures.  Given limited feedback, APRA will not be making a determination on this point at this time, but may decide to consult again on this issue in the future.

Next steps

 

APRA will release the first of the impacted publications, the Quarterly General Insurance Performance Statistics and Quarterly Life Insurance Performance Statistics for the September 2021 reference period, on 25 November 2021. 

Yours sincerely,

 

Alison Bliss
General Manager
Data Analytics and Insights

 

Appendix A – Impacted reporting forms

General Insurance – Level 1 Insurers

 

Reporting Form

Current data deemed non-confidential (1)

Determination of non-confidential data

GRF_115_0: Outstanding Claims Liabilities - Insurance Risk Charge

Were actuarial services used to complete this return (Yes/No)
Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Adjustments to OCL Insurance Risk Charge as approved by APRA – Total OCL insurance risk charge
Total - All data items

All data items, excluding 'Adjustments and exclusions to prudential requirements for the OCL Insurance Risk Charge'

GRF_115_1: Premiums Liabilities - Insurance Risk Charge

Were actuarial services used to complete this return (Yes/No)
Section 3A: GPS 320 Total
Total direct business - All data items
Total reinsurance business - All data items
Adjustments to PL Insurance Risk Charge as approved by APRA – Total PL insurance risk charge
Total - All data items
Section 3B: AASB 1023 Total
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Other items description
Section 3C: Total premiums liabilities surplus / deficit
Total direct business – premiums liabilities surplus/deficit
Total reinsurance business– premiums liabilities surplus/deficit
Total deferred reinsurance expenses for future business not yet written
Total premiums liabilities surplus/deficit

All data items, excluding 'Adjustments and exclusions to prudential requirements for the PL Insurance Risk Charge'

GRF_310_1_L: Premium Revenue and Reinsurance Expense (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Of which is from/with: Parent entity - All data items
Of which is from/with: Controlled entities/ Controlled entities of the parent - All data items
Of which is from/with: Associates/Joint ventures - All data items
Of which is from/with: Other related entities - All data items

All data items

GRF_310_2_L: Claims Expense and Reinsurance Recoveries (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Of which is from/with: Parent entity - All data items
Of which is from/with:  Controlled entities/ Controlled entities of the parent - All data items
Of which is from/with:  Associates/Joint ventures - All data items
Of which is from/with:  Other related entities - All data items

All data items

GRF_310_3_L: Details of Income and Expenses

1. Investment income – All data items
2. Operating income – All data items
3. Operating expenses – All data items
4. Underwriting expenses and Acquisition costs
Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total – All data items

All data items

GRF_410_0_L: Movement in Outstanding Claims Liabilities

Section 3:
Total direct business - All data items
Total reinsurance business - All data items

Total – All data items

All data items

GRF_420_0_L: Premium Revenue by State and Territory of Australia (L)

None

All data items

GRF_430_0_L: Claims Expense by State and Territory of Australia (L)

None

All data items

GRF_440_0_L: Claims Development Table (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items

Total – All data items

All data items

(1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015.

 

General Insurance – Level 2 Groups

 

Reporting Form

Current data deemed non-confidential (1)

Determination of non-confidential data

GRF_115_0A_G: Outstanding Claims Liabilities - Insurance Risk Charge - Australia by Class of Business (G)

Were actuarial services used to complete this return (Yes/No)
Section 2: Direct business (International) - All data items
Section 4: Reinsurance business (International) - All data items
Section 5: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Group adjustments – All data
Adjustments to OCL Insurance Risk Charge as approved by APRA
Total - All data items
OCL surplus / (deficit)

All data items, excluding 'Adjustments to OCL Insurance Risk Charge'

GRF_115_1A_G: Premiums Liabilities - Insurance Risk Charge - Australia by Class of Business (G)

Were actuarial services used to complete this return (Yes/No)
Basis of preparation

 

PART A: PREMIUMS LIABILITIES - GPS 320 BASIS
Section 2: Direct business (International) - All data items
Section 4: Reinsurance business (International) - All data items
Section 5: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Total premiums liabilities - GPS 320 basis – All data items

 

PART B: PREMIUMS LIABILITIES - AASB BASIS
Section 7: Direct business (International) - All data items
Section 9: Reinsurance business (International) - All data items
Section 10: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Total premiums liabilities - AASB basis – All data items

 

 

PART C: ADDITIONAL POLICIES RISK CHARGE
Section 12: Direct business (International) - Net written premium for material business that incepts in the next reporting period – All data items
Section 14: Reinsurance business (International) - Net written premium for material business that incepts in the next reporting period – All data items

 

PART D: TOTAL PREMIUMS LIABILITIES
Section 15: Total
Total Australian direct business - All data items
Total Australian reinsurance business - All data items
Total International direct business - All data items
Total International reinsurance business - All data items
Group adjustments
Adjustments to PL Insurance Risk Charge as approved by APRA
Total - All data items
PL surplus / (deficit) – All data items

All data items, excluding 'Adjustments to PL Insurance Risk Charge'

 (1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015.

 

Life Insurance
 

Reporting Form

Current data deemed non-confidential (2)

Determination of non-confidential data

LRF_200_0: Capital Adequacy Supplementary Information

Section 2: Insurance risk charge
(i) 3. Total impact of stress margins – all data items
Section 3: Variable annuities – all data items

All data items

LRF_330_0: Summary of Revenue and Expenses

(i) Totals by class of business – all data items

All data items

LRF_400_0: Statement of Policy Liabilities

(i) 2. Totals by class of business and basis – all data items

All data items

LRF_420_0: Assets Backing Policy Liabilities

(i) 3.Totals by class of business – all data items

All data items

LRF_430_0: Sources of Profit

(i) 2. Totals by class of business and profit allocation – all data items

All data items

(2) Australian Prudential Regulation Authority (confidentiality) determination No. 12 of 2015.

 


Footnotes:

1. APRA commences consultation on increased transparency of general insurance and life insurance data.
2. APRA received 9 submissions from interested parties in response to the proposals in the discussion paper. Of these submissions, 3 are available at: Confidentiality of general insurance and life insurance data. The other 6 submissions were marked as confidential.  
3. APRA's objectives.
4. This initiative also aligns with the Australian Government Public Data Policy Statement.  See: https://pmc.gov.au/public-data/public-data-policy
5. Specifically, Quarterly General Insurance Performance Statistics, Quarterly Life Insurance Performance Statistics, and General Insurance Claims Development Statistics.  The proposals relate to current and historical data in these publications.

2021