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Regulator Performance Framework - Self-assessment 2018-19

Introduction

This report sets out APRA’s 2018/19 self-assessment against the Australian Government’s Regulator Performance Framework.

The Framework: Measures of good regulatory performance

The Government’s Deregulation Agenda established the Regulator Performance Framework (the Framework) to assess regulators’ performance when interacting with business, the community and individuals while carrying out their functions. The Framework came into effect on 1 July 2015 and aims to encourage regulators to undertake their functions with minimum impact necessary to achieve regulatory objectives and to effect positive ongoing and lasting cultural change within regulators.

The Framework comprises six Key Performance Indicators (KPIs) that articulate the Government’s overarching expectations of regulator performance, namely:

  • KPI 1: Regulators do not unnecessarily impede the efficient operation of regulated entities
  • KPI 2: Communication with regulated entities is clear, targeted and effective
  • KPI 3: Actions undertaken by regulators are proportionate to the regulatory risk being managed
  • KPI 4: Compliance and monitoring approaches are streamlined and coordinated
  • KPI 5: Regulators are open and transparent in their dealings with regulated entities
  • KPI 6: Regulators actively contribute to the continuous improvement of regulatory frameworks.

In accordance with the Framework, all regulators are to undertake an annual self-assessment of performance against each KPI. The self-assessment report is externally validated through an approved stakeholder mechanism1 prior to its release to the regulator’s Minister, and publication. The validation process provides an avenue for stakeholders to give feedback on whether the self-assessment accords with their views of performance against the KPIs over the assessment period. Stakeholders consider whether conclusions are reasonable and objective and if the areas identified for further improvement are appropriate or justified2.

The Framework is one component of a broader suite of accountability structures in place including those set out in APRA’s Statement of Expectations set by the Government and the Public Governance, Performance and Accountability Act 2013 (PGPA Act). To this end, APRA’s self-assessment against the Framework complements a range of performance reporting mechanisms in place. More information about the Framework can be found at: www.cuttingredtape.gov.au/resources/rpf.

Evaluating APRA’s performance against the Framework

APRA established a set of metrics to support its assessment against the above KPIs. After consultation with approved stakeholders, APRA’s Regulator Performance Framework Metrics were published in July 2015. These metrics, together with measures of good regulatory performance that support each KPI articulated within the Framework, are included in Attachment A of this report. While the metrics provide a useful frame of reference, a range of data sources and qualitative information are used to demonstrate APRA’s performance against each KPI relevant to the reporting period. APRA is planning to review its metrics in 2020 to ensure they remain relevant and appropriate in preparation for its self-assessment against the Framework covering the 2019/20 financial year.

In 2019, APRA conducted its biennial stakeholder survey from which insights from regulated entities and other knowledgeable observers are obtained. The survey results are a key source of evidence for APRA’s self-assessment.

APRA was also subject to a range of reviews conducted during the 2018/19 financial year. Aspects of APRA’s operations (as well as those of other domestic regulatory agencies) were examined by the International Monetary Fund’s (IMF) Financial Sector Assessment Program (FSAP), the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry, and the Productivity Commission’s reviews on ‘Competition in the Australian Financial System’ and ‘Superannuation: Assessing Efficiency and Competition’. APRA was also subject to a Capability Review by an external panel of independent experts; the report from this review was released in July 20193.

In 2018/19, APRA also undertook a comprehensive review of its enforcement approach, assisted by an independent advisory panel of experts in the administration of law and regulatory enforcement. The review was a forward-looking examination of APRA’s current enforcement strategy and how it interacts with APRA’s supervisory approach. As a result of this review, APRA published a new enforcement approach in 2019 and is implementing recommendations designed to better leverage its enforcement powers to achieve sound prudential outcomes.

In summary, the outcome of these reviews is the recognition that APRA has been successful in delivering on its core mandate being the financial safety of the institutions it regulates and a sound and resilient financial system. However, the reviews acknowledge that APRA’s operating environment is rapidly evolving and becoming increasingly complex, and APRA needs to expand its focus and capabilities to enable it to continue to be fit for purpose and meet its mandate into the future.

The reviews collectively provided 157 recommendations and suggestions for APRA to consider to strengthen regulation and supervision practices. APRA supports all recommendations from the Royal Commission and Capability Review directed at APRA together with APRA’s own review of its enforcement approach. These recommendations, in addition to those directed at APRA by the IMF as part of the FSAP (and supported) and the Productivity Commission findings, have been factored into APRA’s 2019-2023 Corporate Plan.     

Whilst the focus of these reviews differ to the measures to assess good regulatory performance articulated in the Framework (as per Attachment A), the relevant findings and evidence from these reviews have been incorporated into this self-assessment report. Importantly, APRA has embraced these reviews as opportunities for continuous improvement, with actions to address a number of recommendations directed at strengthening the regulatory frameworks and practices already underway.

Footnotes:

1 APRA’s approved stakeholder consultation mechanism includes the following industry associations: Australian Banking Association (ABA), Association of Superannuation Funds Australia (ASFA), Community Owned Banking Association (COBA), Insurance Council of Australia (ICA), Financial Services Council (FSC), Members Health Fund Alliance and Private Healthcare Australia (PHA).

2 The validation process is not intended to be an audit of APRA’s self-assessment or an opportunity for stakeholders to deal with specific individual experiences or interactions with a regulator.

3 The Royal Commission recommended an independent panel of external experts complete a review to assess APRA’s capability to deliver upon its statutory mandate, its ability to respond to an environment growing in complexity and the emerging risks for APRA’s regulated sectors.  


Overall self-assessment

Overall, APRA considers it has met all six KPIs set out in the Framework. However opportunities for improvement have been identified in relation to three KPIs. These, together with actions APRA is planning to take to address the areas for improvement identified, are included in the summary table below. Detailed assessments against each KPI comprise the body of this report and support the overall self-assessment below.

KPI 1 - Regulators do not unnecessarily impede the efficient operation of regulated entities

Self-assessment KPI met, although opportunities for improvement identified
Performance summary In promoting financial stability in Australia, APRA continues to balance financial safety with efficiency, competition, contestability and competitive neutrality in line with its statutory objectives. APRA achieved its target of 100% compliance with Office of Best Practice Regulation (OBPR) requirements for all changes to the prudential framework made across all regulated industries in 2018/19, which included the preparation of formal Regulatory Impact Statements (to assess the costs and benefits of proposed policy changes) where required. Despite being assessed as compliant by the OBPR, the 2019 biennial stakeholder survey indicated that only 31% (23% in 2017) of stakeholders consider changes to APRA’s prudential framework sufficiently consider the costs of regulation imposed on industry. Although an improvement, this suggests there is significant opportunity for APRA to improve transparency on the assessment of costs (and benefits) for proposed policy changes, and better communicate this process with APRA’s stakeholders. 
Planned action(s) A key objective (and related actions) included in APRA’s 2019-2023 Corporate Plan is to improve external engagement by expanding communications to promote better prudential outcomes and drive accountability, including demonstrating how APRA balances its objectives. This was reinforced by APRA’s Capability Review. Improving transparency on the assessment of costs and benefits for proposed policy changes (such as meeting OBPR requirements) will also be addressed.  

KPI 2 - Communication with regulated entities is clear, targeted and effective

Self-assessment KPI met, although opportunities for improvement identified
Performance summary APRA’s communication with regulated entities is considered clear and effective. This was validated in the biennial stakeholder survey where 95% of regulated entities (94% in 2017) confirmed that APRA’s communication is clear and effective and 92% (88% in 2017) thought that APRA’s publications are clear and effective. While these results are very strong, APRA considers it could do more to ensure that communications are targeted and cater to all stakeholder needs. 
Planned action(s) A key objective (and related actions) included in APRA’s 2019-2023 Corporate Plan is to develop and implement a communications strategy and roadmap that caters to all stakeholder needs. APRA is also intending to measure and report on the timeliness of regulatory decisions and advice as per its public response to the Capability Review.

KPI 3 - Actions undertaken by regulators are proportionate to the regulatory risk being managed

Self-assessment KPI met
Performance summary Throughout 2018/19, APRA continued to take a risk-based approach to identifying and assessing areas of greatest risk to regulated entities in meeting their obligations to beneficiaries; and to financial stability in Australia, and directing its resources to address those risks. This was validated in the biennial stakeholder survey where 90% of stakeholders (86% in 2017) considered that APRA is primarily risk-based in it supervision. 
Planned action(s) APRA’s review of its supervision model (included in APRA’s 2019-2023 Corporate Plan) aims ensure that it is fit for purpose and responsive to a rapidly changing environment, as well as one that drives consistent, risk-based, informed and comprehensive prudential supervision across the Australian financial system.

KPI 4 - Compliance and monitoring approaches are streamlined and coordinated

Self-assessment KPI met, although areas for improvement identified.
Performance summary APRA maintained strong working relationships with Australia’s key regulatory agencies throughout the year particularly those within the Council of Financial Regulators (CFR) including the Australian Securities and Investments Commission (ASIC), The Reserve Bank of Australia (RBA) and Treasury. However APRA has recognised it can promote more coordinated and streamlined approaches across CFR agencies as well as other domestic and international peer agencies to achieve regulatory objectives.
Planned action(s)

Within the Policy and Advice Division, APRA recently established a dedicated Regulatory Affairs unit and explicitly acknowledged uplifting its capabilities in relation to collaborating with domestic and international peer regulatory agencies in its 2019-2023 Corporate Plan. The independent reviews conducted during the year reinforced this strategic objective.

Other key objectives (and related actions) included in APRA’s 2019-2023 Corporate Plan are to:

  • Develop and implement a data strategy to facilitate greater and more effective use and sharing of data in the oversight of the Australian financial system and defining and implementing the cross agency data sources required.
  • Create a modern, efficient and flexible solution which will serve APRA and industry for years to come in relation to data collection, storage, analysis and publication.

KPI 5 - Regulators are open and transparent in their dealing with regulated entities

Self-assessment KPI met.
Performance summary During 2018/19, APRA continued to be open and transparent about its performance in line with expectations set by the Government in APRA’s Statement of Expectations, APRA’s own Statement of Intent and the PGPA Act. This is validated by the biennial stakeholder survey, where 83% of stakeholders considered APRA to be consultative in its supervision and 75% reported that APRA handled requests for approval, variation or exemptions well (when required).
Planned action(s) APRA will continue to work on being open and transparent in our dealings with regulated entities as part of its broader strategic objective to improve external engagement highlighted.

KPI 6 - Regulators actively contribute to the continuous improvement of regulatory frameworks

Self-assessment KPI met.
Performance summary APRA continued to engage with and receive feedback from stakeholders throughout the year and work proactively with domestic and international agencies to continuously improve regulatory frameworks and practices.
Planned action(s) As noted in the 2019-2023 Corporate Plan, APRA will adopt a ‘whole of system’ approach to the collective success of Australia’s financial regulatory regime through a more deliberate approach to collaborating with peer domestic and international agencies on a broader range of risks and mitigation activities and will continue to contribute to the improvement of regulatory frameworks.

General stakeholder feedback

APRA’s self-assessment report was externally validated. APRA received responses from six of the seven industry associations as part of the validation process. The responding stakeholders were appreciative of the opportunity to provide feedback to APRA.

Overall, industry associations broadly agree with APRA’s 2018-2019 self-assessment and that APRA’s conclusions are reasonable. Industry associations recognise that APRA is undergoing organisational change, partly in response to recommendations arising from the range of reviews conducted during the 2018/19 financial year but consider that APRA continues to undertake its role as a prudential regulator well and conduct its regulatory activities in an open and transparent manner.

Industry associations endorse the opportunities for improvement identified by APRA in its self-assessment report and support improvement plans.

Some industry bodies noted specific areas for improvement based on their (or their members) dealings with APRA. Two of the more common responses related to more consideration of the increasing cost of regulation for their members (particularly smaller financial institutions) and opportunities for APRA to work more closely with the Australian Securities and Investments Commission (ASIC).

Stakeholder feedback relating to each KPI is included in the body of this report. 

 

KPI 1 - Regulators do not unnecessarily impede the efficient operation of regulated entities

Measures of good regulatory performance

1(i)  Regulators demonstrate an understanding of the operating environment of the industry or organisation, or the circumstances of individuals and the current and emerging issues that affect the sector.
1(ii) Regulators take actions to minimise the potential for unintended negative impacts of regulatory activities on regulated entities or affected supplier industries and supply chains.
1(iii) Regulators implement continuous improvement strategies to reduce the costs of compliance for those they regulate.

 

 

APRA’s self-assessment against KPI 1

In promoting financial stability in Australia, APRA continues to balance financial safety with efficiency, competition, contestability and competitive neutrality in line with its statutory objectives. APRA achieved its target of 100% compliance with Office of Best Practice Regulation (OBPR) requirements for all changes to the prudential framework made across all regulated industries in 2018/19, which included the preparation of formal Regulatory Impact Statements (to assess the costs and benefits of proposed policy changes) where required. Despite being assessed as compliant by the OBPR, the 2019 biennial stakeholder survey indicated that only 31% (23% in 2017) of stakeholders consider changes to APRA’s prudential framework sufficiently consider the costs of regulation imposed on industry. Although an improvement, this suggests there is significant opportunity for APRA to improve transparency on the assessment of costs (and benefits) for proposed policy changes, and better communicate this process with APRA’s stakeholders.

APRA continued to have a deep understanding of its operating environment and current and emerging issues affecting regulated entities, industries and the financial system more broadly.

APRA continued to enhance the prudential framework across all regulated industries throughout the year in response to, amongst other things, specific risks within regulated entities and broader vulnerabilities in the external environment both domestically and internationally.

APRA targeted full compliance with OBPR principles to ensure costs to industry are thoroughly considered as part of new policy proposals. APRA’s policy development work is directed towards establishing an appropriate balance between financial safety and other considerations, including regulatory costs and is consultative in nature to ensure that APRA does not unnecessarily impede the efficient operation of regulated entities in achieving regulatory objectives. APRA achieved 100% compliance with OBPR requirements for all changes to the prudential framework made in 2018/19.

While targets have been achieved, APRA acknowledges it can do more to improve transparency in terms of how it balances its regulatory objectives and the costs (and benefits) for proposed changes to the prudential framework across all regulated industries.

Supporting evidence for KPI 1

OBPR compliance

APRA achieved its target of 100% compliance with OBPR requirements for all changes to the prudential framework made in 2018/19, supported by the preparation of Regulatory Impact Statements (RIS) to assess the costs, benefit and impacts of policy changes on industry where required. A RIS was required for three policies released by APRA as final during the year, which were assessed as compliant with the Australian Guide to Regulations.

Demonstrated understanding of operating environment

APRA's understanding of its operating environment including the industries it regulates is articulated in, and underpins, APRA’s four-year Corporate Plan. APRA’s Corporate Plan covering the 2018-2022 and 2019-2023 periods were published in August 2018 and August 2019 respectively.

APRA's ‘Insight’ publication (available on its website) contains editorial articles on key industry and topical issues. APRA overhauled the structure of Insight during the year targeting a broader audience than the institutions and industries APRA regulates. The new-look APRA Insight publication was released in August 2019. During 2018/19, two issues of ‘APRA Insight’ were published and included articles on the 2017 banking industry stress test; cloud computing; the Private Health Insurance policy roadmap; commercial real estate lending; class actions and the important of directors and officers’ insurance; and international issues.

In addition to APRA’s Corporate Plan and Insight publication, APRA published a number of media releases, speeches and information papers throughout the year covering the following key themes:

  • The strength and resilience of the Australian banking system;
  • Governance and culture within banking institutions;
  • The erosion of community trust in the fairness of the financial sector;
  • The need for regulated institutions to invest in technology for adequate cyber security and risk mitigation and ensuring existing systems remain fit for purpose; and
  • Strengthening the focus of superannuation entity licensees on outcomes for members. 

Compliance with international principles

Over the course of the 2018/19 financial year, Australia was subject to an extensive independent review conducted by the IMF which included, amongst other things, a comprehensive assessment against all international principles for banking. The IMF assessed Australia as achieving a high degree of compliance with the Basel Core Principles for Effective Banking Supervision (compliant for 19 core principles, largely compliant for 8 core principles and materially non-compliant for two core principles). Addressing recommendations made by the IMF (and supported by CFR agencies) have been factored into APRA’s 2019-23 Corporate Plan as part of strategies focused on continuous improvement.

Publication of policy submissions

APRA's Statement of Intent notes that: 

APRA’s policy development process will continue to include comprehensive industry consultation to provide for an open and transparent consideration of stakeholder views and include the publication of non-confidential stakeholder submissions and APRA’s response papers.

For each policy consultation in 2018/19, non-confidential submissions in response to the consultation were published on APRA’s website.

Stakeholder feedback

 

APRA's 2019 biennial stakeholder survey asked stakeholders to rate their level of agreement with the following statements:

In its supervision of your industry, APRA effectively pursues financial safety, balanced with considerations of efficiency, competition, contestability and competitive neutrality, and promotes financial stability:

  • Strongly Agree/Agree: 73% (73% in 2017)
  • Neutral: 16% (21% in 2017)
  • Disagree/Strongly disagree: 10% (7% in 2017)
  • Don’t know: 1%

APRA sufficiently considers issues relevant to industry and other stakeholders when developing its prudential standards and guidance material:

  • Strongly Agree/Agree: 65% (67% in 2017)
  • Neutral: 23% (23% in 2017)
  • Disagree/Strongly disagree: 9% (9% in 2017)
  • Don’t know: 3% (1% in 2017).

Changes to APRA’s prudential framework sufficiently consider the costs of regulation imposed on industry:

  • Strongly Agree/Agree: 31% (23% in 2017)
  • Neutral: 34% (39% in 2017)
  • Disagree/Strongly disagree: 33% (37% in 2017)
  • Don’t know: 3% (1% in 2017)

APRA provides sufficient opportunity for consultation with industry about proposed changes to prudential standards and guidance material:

  • Strongly Agree/Agree: 80% (84% in 2017)
  • Neutral: 16% (12% in 2017)
  • Disagree/Strongly disagree: 2% (4% in 2017)
  • Don’t know: 1%

APRA has a good understanding of your organisation:

  • Strongly Agree/Agree: 82%
  • Neutral: 11%
  • Disagree/Strongly disagree: 6%
  • Don’t know: 1%

The effort required of your entity during APRA’s prudential reviews is appropriate:

  • Strongly Agree/Agree: 75% (77% in 2017)
  • Neutral: 17% (15% in 2017)
  • Disagree/Strongly disagree: 6% (6% in 2017)
  • Don’t know: 2% (1% in 2017)

External stakeholder validation

Industry associations generally agreed with APRA’s self- assessment against KPI 1 and that APRA has a sound understanding of current and emerging prudential risks. A notable exception to this was for private health insurance where industry believes APRA’s technical expertise/ capability has declined over the last few years.

A number of industry associations acknowledged and welcomed APRA’s ongoing commitment to industry consultation particularly as part of the policy development process.

Some industry associations expressed concerned about the increasing cost of regulation (particularly for smaller industry participants) with the majority supporting the need for more transparency in relation to the costs (and benefits) of proposed policy changes and welcomed better communication of this process with APRA’s stakeholders. 

 

KPI 2 - Communication with regulated entities is clear, targeted and effective

Measures of good regulatory performance

2(i)   Regulators provide guidance and information that is up to date, clear, accessible and concise through media appropriate to the target audience.
2(ii)  Regulators consider the impact on regulated entities and engage with industry groups and representatives of the affected stakeholders before changing policies, practices or service standards.
2(iii) Regulators’ decisions and advice are provided in a timely manner, clearly articulating expectations and the underlying reasons for decisions.
2(iv) Regulators’ advice is consistent and supports predictable outcomes.

 

APRA’s self-assessment against KPI 2

APRA’s communication with regulated entities is considered clear and effective. This was validated in the biennial stakeholder survey where 95% of regulated entities (94% in 2017) confirmed that APRA’s communication is clear and effective and 92% (88% in 2017) thought that APRA’s publications are clear and effective. While these results are very strong, APRA considers it could do more to ensure that communications are targeted and cater to all stakeholder needs.  

The 2019 biennial stakeholder survey results identified a number of positives in which APRA can further build on in relation to its communication approach with regulated entities and external stakeholders more broadly.

Overall, APRA is consistently considered very effective in communicating the findings of supervisory visits to regulated entities with 92%-93% of stakeholders agreeing or strongly agreeing in 2017 and 2019 respectively.

Specifically, the biennial stakeholder survey identified an improvement of four per cent (from 40% in 2017 to 44% in 2019) in the percentage of stakeholder responding to the usefulness of speeches by senior APRA representatives which has been a conscious effort by APRA to uplift its internal capabilities in this area. Similarly, there was a marginal uptick in the percentage of stakeholders reporting that other information on APRA’s website such as policy papers and FAQs were useful, albeit from a relatively low base (42% in 2017 to 45% in 2019).

Supporting evidence for KPI2

Provision of guidance and information

APRA's website includes a comprehensive suite of prudential standards and guidance covering all regulated industries. During 2018/19, the standards and guidance sections of the APRA website (by industry) were accessed as follows:

  • Authorised deposit-taking institutions: 167,150 times.
  • General Insurance: 60,496 times.
  • Life insurance and friendly societies: 31,109 times.
  • Private health insurance: 14,187 times.
  • Superannuation: 69,902 times.

APRA published media releases and information papers on key prudential activities and decisions impacting regulated entities throughout the year including:

  • 20 speeches (23 in 2017/18) including addressing the findings of the Royal Commission and FSAP reviews.    
  • 84 media releases (70 in 2017/18), of which just under half were directly related to providing regulated entities with updates on guidance materials; notifying regulated entities of proposed updates/changes to standards, approaches or expectations; responses to independent reviews; and policy priorities. The remaining media releases were notifications of consultations, statistical publications, general announcements and notification of newly licensed authorised deposit-taking institutions.
  • 9 information papers (5 in 2017/18) covering APRA’s policy priorities and key issues including superannuation, governance, accountability, culture, IT (specifically, outsourcing involving shared computing services) and residential mortgage lending.

Stakeholder feedback – usefulness of guidance and information

APRA's 2019 biennial stakeholder survey asked stakeholders to rate the usefulness of guidance materials, including those published on the website:

APRA's prudential standards clearly communicate requirements:

  • Strongly Agree/Agree: 78% (81% in 2017)
  • Neutral: 18% (14% in 2017)
  • Disagree/Strongly disagree: 4% (5% in 2017)

Usefulness of APRA’s Prudential Practice Guides:

  • Extremely/Very useful: 77% (83% in 2017)
  • Moderately useful: 21% (16% in 2017)
  • Slightly useful/not at all: 2% (2% in 2017)

Usefulness of speeches by senior APRA representatives:

  • Extremely/Very useful: 44% (40% in 2017)
  • Moderately useful: 42% (44% in 2017)
  • Slightly useful/not at all: 14% (16% in 2017)

Usefulness of other information on APRA’s website, such as Policy Papers and FAQs:

  • Extremely/Very useful: 45% (42% in 2017)
  • Moderately useful: 48% (48% in 2017)
  • Slightly useful/not at all: 7% (10% in 2017)

APRA's public communications are clear and effective (e.g. speeches/ media releases and website content):

  • Strongly Agree/Agree: 92% (88% in 2017)
  • Neutral: 8% (10% in 2017)
  • Disagree/Strongly disagree: <1% (1% in 2017)

APRA's communication to my entity are clear and effective:

  • Strongly Agree/Agree: 95% (94% in 2017)
  • Neutral: 4% (5% in 2017)
  • Disagree/Strongly disagree: <1% (1% in 2017)

APRA's resolution of your entity’s technical and supervisory requests is satisfactory:

  • Strongly Agree/Agree: 84% (83% in 2017)
  • Neutral: 11% (12% in 2017)
  • Disagree/Strongly disagree: 3% (5% in 2017)
  • Don’t know: 1% (<1% in 2017)

Stakeholder feedback – clarity of communication

APRA communicates clearly during consultation with industry about proposed changes to prudential standards and guidance materials:

  • Strongly Agree/Agree: 79% (81% in 2017)
  • Neutral: 18% (16% in 2017)
  • Disagree/Strongly disagree: 2% (3% in 2017)
  • Don’t know: 1% (<1% in 2017)

APRA is effective in communicating the findings of supervisory visits to your entity:

  • Strongly Agree/Agree: 93% (92% in 2017)
  • Neutral: 4% (7% in 2017)
  • Disagree/Strongly disagree: <1% (1% in 2017)
  • Don’t know: 3% (<1% in 2017)

Report timeliness

As per APRA’s Supervision Approach, supervisors act in a timely manner and promptly escalate issues of concern with regulated entities. An internal measure used by APRA is the percentage of visit reports issued within four weeks of conducting an on-site review of a regulated entity. In 2018/19, APRA provided 84% of reports to regulated entities within four weeks of the visit (83% in 2017/18).

Consistency in Supervision

APRA's 2019 biennial stakeholder survey asked stakeholders to rate their level of agreement with the following statements:

APRA is consistent in its supervision:

  • Strongly Agree/Agree: 71% (72% in 2017)
  • Neutral: 18% (16% in 2017)
  • Disagree/Strongly disagree: 7% (10% in 2017)
  • Don’t know: 4% (3% in 2017)

External stakeholder validation

Industry associations generally agreed with APRA’s assessment of KPI 2 that it is clear, targeted and effective in its communications and agreed that there are opportunities for improvement. Specific examples provided by some industry associations where APRA’s communication could be improved included:

  • Clearly articulating the purpose for data collections so that entities understand the benefit being gained and how the collection fits within APRA’s prudential oversight requirements.
  • Sufficient lead time between the release of new prudential standards and commencement.
  • Greater investment in maintaining APRA’s website as a key channel of communication.

 

KPI 3 - Actions undertaken by regulators are proportionate to the regulatory risk being managed

Measures of good regulatory performance

3(i)   Regulators apply a risk-based, proportionate approach to compliance obligations, engagement and regulatory enforcement actions.

3(ii)  Regulators’ preferred approach to regulatory risk is regularly reassessed. Strategies, activities and enforcement actions are amended to reflect changing priorities that result from new and evolving regulatory threats, without diminishing regulatory certainty or impact.

3(iii) Regulators recognise the compliance record of regulated entities, including using earned autonomy where this is appropriate. All available and relevant data on compliance, including evidence of relevant external verification is considered.

APRA’s self-assessment against KPI 3

Throughout 2018/19, APRA continued to take a risk-based approach to identifying and assessing areas of greatest risk to regulated entities in meeting their obligations to beneficiaries; and to financial stability in Australia, and directing its resources to address those risks. This was validated in the biennial stakeholder survey where 90% of stakeholders (86% in 2017) considered that APRA is primarily risk-based in it supervision.

APRA’s Statement of Intent includes amongst other things a description of APRA’s supervisory approach

“APRA adopts a risk-based approach to prudential supervision that is designed to identify and assess those areas of greatest risk to an APRA-regulated institution (or to the financial system as a whole) and then direct resources and attention to these risks. APRA seeks to ensure that its judgments are accurate, timely and robust and that its responses are targeted and proportionate.”  

APRA’s long established risk assessment and response systems — the Probability and Impact Rating System (PAIRS) and the Supervisory Oversight and Response System (SOARS) — are critical tools for identifying institutions that have a higher risk/ impact of failure and tailoring APRA’s approach accordingly.

As mentioned in last year’s self-assessment, APRA is reviewing its supervision model (including PAIRS and SOARS) to ensure that it remains fit for purpose and responsive to a rapidly changing environment, as well as one that drives consistent, informed and comprehensive prudential supervision across the financial system.

Supporting evidence for KPI3

Supervisory and enforcement approaches

APRA's supervisory approach is forward-looking and involves identifying key risks to which regulated entities are exposed. APRA’s supervisory approach provides for a ‘baseline’, or minimum, level of supervisory activity designed to identify and assess the key risks affecting regulated entities and to determine ‘risk-based’ supervision priorities.

APRA uses its enforcements powers where appropriate to prevent and address serious prudential risks and hold entities and individuals to account. APRA has regard to the following principles in applying its enforcement approach.

  • Risk-based: APRA assesses the seriousness, nature and circumstances of the matter and prioritises the issues and entities that pose the most serious prudential risks;
  • Forward-looking: APRA’s enforcement supports its supervisory focus on preventing harm, mitigating risks and achieving ex ante remedial action;
  • Outcomes-based: APRA’s appetite for enforcement action is  driven by the prudential outcomes it is trying to achieve;
  • Deterrence: In determining when and how to take enforcement action, APRA actively considers the need to deter a recurrence of serious prudential risk, both at the entity concerned and also more widely across the industry.

Stakeholder feedback

2019 biennial stakeholder survey asked stakeholders to rate their level of agreement with the following statements:

APRA's prudential framework is effective in achieving APRA’s mission:

  • Strongly Agree/Agree: 84% (87% in 2017)
  • Neutral: 13% (12% in 2017)
  • Disagree/Strongly disagree: 2% (1% in 2017)
  • Don’t know: 1% (<1% in 2017)

APRA's supervision of your entity is consistent with APRA’s mission:

  • Strongly Agree/Agree: 86% (87% in 2017)
  • Neutral:  9% (8% in 2017)
  • Disagree/Strongly disagree: 2% (1% in 2017)
  • Don’t know: 4% (3% in 2017)

During prudential reviews of your entity, APRA appropriately assesses the importance of issues that are subject to APRA requirements, recommendations or suggestions:

  • Strongly Agree/Agree: 84% (82% in 2017)
  • Neutral: 11% (16% in 2017)
  • Disagree/Strongly disagree 2% (1% in 2017)
  • Don’t know: 3% (2% in 2017)

APRA is primarily risk-based in it supervision:

  • Strongly Agree/Agree: 90% (86% in 2017)
  • Neutral: 8% (12% in 2017)
  • Disagree/Strongly disagree: 1% (2% in 2017)
  • Don’t know: 1%

During supervisory visits to your entity, APRA supervisors focus on major risks or controls:

  • Strongly Agree/Agree: 89% (88% in 2017)
  • Neutral: 8% (9% in 2017)
  • Disagree/Strongly disagree: 2% (3% in 2017)
  • Don’t know: 2% (<1% in 2017)

APRA assists your institution to identify and mitigate emerging risks:

  • Strongly Agree/Agree: 51%
  • Neutral: 38%
  • Disagree/Strongly disagree: 9%
  • Don’t know: 2%

External stakeholder validation

Industry associations generally agreed with APRA’s assessment of KPI 3 and are supportive of the approach taken by APRA in recent years to demonstrate proportionality, including graduated approaches, simplification measures and lower supervisory intensity. Specific feedback is highlighted below.

‘… we believe the consultative supervisory approach taken by APRA to seek to work in cooperation with [industry] to reach and maintain primarily risk-based compliance has been successful to this point and should be maintained to the greatest extent possible. A regulator who poses a constant litigation risk may be less likely to be capable of building the degree of trust and openness necessary to achieve the objective of identifying prudential problems before they affect the ability of an [entity] to meet its financial obligations.’

 

KPI 4 - Compliance and monitoring approaches are streamlined and coordinated

Measures of good regulatory performance

4(i)   Regulators’ information requests are tailored and only made when necessary to secure regulatory objectives, and only then in a way that minimises impact.

4(ii)  Regulators’ frequency of information collection is minimised and coordinated with similar processes including those of other regulators so that, as far as possible, information is only requested once.

4(iii) Regulators utilise existing information to limit the reliance on requests from regulated entities and share the information among other regulators, where possible.

4(iv) Regulators base monitoring and inspection approaches on risk and, where possible, take into account the circumstance and operational needs of the regulated entity.

 

APRA’s self-assessment against KPI 4

APRA maintained strong working relationships with Australia’s key regulatory agencies throughout the year particularly those within the Council of Financial Regulators (CFR) including the Australian Securities and Investments Commission (ASIC), The Reserve Bank of Australia (RBA) and Treasury. However APRA has recognised it can promote more coordinated and streamlined approaches across CFR agencies as well as other domestic and international peer agencies to achieve regulatory objectives.

APRA recently established a dedicated Regulatory Affairs unit and explicitly acknowledged uplifting its capabilities in relation to collaborating with domestic and international peer regulatory agencies in its 2019-2023 Corporate Plan. The independent reviews conducted during the year reinforced this strategic objective.

APRA continued to play an important role as the central repository of statistical information on the Australian financial system. APRA collects, distributes and publishes data on behalf of a number of other Government agencies including the Reserve Bank of Australia (RBA) and the Australian Bureau of Statistics (ABS). Undertaking this role has enabled a coordinated approach to reporting of statistical information for regulated entities, however the amount of data and information needed to achieve regulatory objectives has been called out within the biennial stakeholder survey as requiring attention with 31% of stakeholders (34% in 2017) indicating that the data collected was ‘too much’ or ‘far too much’. In saying this, 68% of stakeholders did note that the information collected was ‘about right’.

APRA is cognisant of the cost of collecting data from regulated entities. As such, and as outlined in APRA’s 2019-2023 Corporate Plan, APRA is  continuing with its multi-year transformation program to create a modern, efficient and flexible data collection solution which will serve APRA and industry for years to come.

APRA’s data strategy intends to transform the data it collects into a collective strategic asset, in consultation with key stakeholders (including industry participants and other regulatory agencies), to facilitate more effective and transparent sharing of data and better insights – both at an entity and industry-level, but also cross-agency and for the general public. A forward looking review of cross-agency data needs was also recommended by the IMF as part of the FSAP in 2018/19. 

Supporting evidence for KPI 4

Statistical publications

In 2018/19 APRA released 70 statistical publications of which 100% were published according to a pre-disclosed timetable.

Information sharing

In addition to providing access to statistical publications on its website, APRA completed specific statistical requests from, or shared data/ information with, the following agencies/ organisations during the year:

  • Australian Competition and Consumer Commission (ACCC)
  • Australian Securities and Investment Commission (ASIC)
  • Australian Bureau of Statistics (ABS)
  • Australian Taxation Office (ATO)
  • Bank of International Settlements (BIS)
  • Department of Agriculture
  • Department of Health
  • The Organisation for Economic Co-operation and Development
  • Reserve Bank of Australia (RBA)
  • Department of the Treasury

Stakeholder feedback

 

APRA's 2019 biennial stakeholder survey asked stakeholders to rate their level of agreement with the following statements:

The amount of statistical data collect by APRA is:

  • Far too much/Too much: 31% (34% in 2017)
  • About right: 68% (66% in 2017)
  • Too little/Far too little: 1% (0% in 2017)

The information that APRA collects in the course of supervision is adequate to assess risks in your entity:

  • Strongly Agree/Agree: 82% (90% in 2017)
  • Neutral: 13% (8% in 2017)
  • Disagree/Strongly disagree: 3% (1% in 2017)
  • Don’t know: 2% (<1% in 2017)

During supervisory visits to your entity, APRA supervisors focus on principles rather than detailed prescription:

  • Strongly Agree/Agree: 74% (73% in 2017)
  • Neutral: 17% (19% in 2017)
  • Disagree/Strongly disagree: 7% (7% in 2017)
  • Don’t know: 3% (<1% in 2017)

External stakeholder validation

Industry associations generally agreed with APRA’s assessment of KPI 4 that compliance and monitoring approaches are streamlined and coordinated and validated APRA’s strong relationship with key regulatory agencies, particularly those within the Council of Financial Regulators. In saying that, industry associations welcomed greater coordination between APRA and ASIC particularly in relation to data collections and extending the Executive Accountability Regime to all APRA regulated entities. Specific feedback is highlighted below.

‘APRA should be cognisant of the extensive investment required of [industry] when implementing changes to reporting requirements. While there is a need to keep reporting up to date with emerging technologies and data management processes, any regulatory reporting changes have resourcing implications which can vary across [members].’

‘One area that has caused some concern in the past is the apparent failure for ASIC and APRA to appropriately liaise. We accept that this position is changing and our members do acknowledge this change. We are pleased that APRA going forward will adopt a ‘whole of system’ approach to its decisions and activities.’

 

KPI 5 - Regulators are open and transparent in their dealings with regulated entities

Measures of good regulatory performance

5(i)   Regulators’ risk-based frameworks are publicly available in a format which is clear, understandable and accessible.

5(ii)  Regulators are open and responsive to requests from regulated entities regarding the operation of the regulatory framework, and approaches implemented by regulators.

5(iii) Regulators’ performance measurement results are published in a timely manner to ensure accountability to the public.

APRA’s self-assessment against KPI 5

During 2018/19, APRA continued to be open and transparent about its performance in line with expectations set by the Government in APRA’s Statement of Expectations, APRA’s own Statement of Intent and the PGPA Act. This is validated by the biennial stakeholder survey, where 83% of stakeholders considered APRA to be consultative in its supervision and 75% reported that APRA handled requests for approval, variation or exemptions well (when required).

The Australian Government sets out its expectations of APRA including managing relationships with key stakeholders and issues of transparency and accountability in APRA’s Statement of Expectations (SOE). APRA responds to the Government’s Statement of Expectations with its Statement of Intent. APRA’s Statement of Intent specifically acknowledges that:

“APRA seeks to maintain open and constructive relationships with the institutions it regulates”.

As with other Commonwealth entities, APRA’s performance framework and governance and accountability requirements are set out in the Public Governance, Performance and Accountability Act 2013 (PGPA Act). The PGPA Act requires APRA to prepare an Annual Performance Statement (APS) to be included in its Annual Report. The APS provides an informative summary to Parliament and the public on APRA’s performance against its four-year Corporate Plan and how it continues to deliver on its mandate.

APRA’s 2019 biennial stakeholder survey indicated that 83% of stakeholders believe that APRA is consultative in it supervision. While APRA acknowledges that this is a strong result, it is a decline of four per cent from the 2017 survey results. In saying that, 75% of stakeholders either agreed or strongly agreed that the resolution of technical and supervisory requests is timely and that requests for approval, variation or exemption from a prudential or reporting standard were handled well, which was an improvement on the 2017 survey results.

To supplement prudential engagements with regulated entities, APRA uses a range of channels to communicate various policy, statistical and other announcements with relevant stakeholder groups. Regular engagement on a bilateral and multilateral basis with professional and industry associations continues to take place. APRA also engages with the Government and other regulatory agencies, the media and the general public and provides ready access to information on its website.

Supporting evidence for KPI 5

Enforcement and supervision approach

APRA's supervisory and enforcement approaches are available on its website. APRA’s enforcement approach was significantly revised during the 2018/19 financial year and was viewed 5,721 times. APRA’s supervision approach was viewed 1,864 times.

Stakeholder engagement

During 2018/19, APRA met with 38 domestic public (Commonwealth and State departments) and private organisations (associations and peak bodies). In addition, APRA:

  • Presented at 80 formal speaking engagements
  • Issued 83 media releases
  • Received 8,389 enquiries from regulated entities (regarding data/statistics)
  • Received 6,026 enquiries through the APRAinfo call centre
  • Attended three Parliamentary hearings
  • Provided two submissions to formal Parliamentary Inquiries

Stakeholder feedback

APRA's 2019 biennial stakeholder survey asked stakeholders to rate their experience or level of agreement with the following statements:

APRA is consultative in its supervision:

  • Strongly Agree/Agree: 83% (87% in 2017)
  • Neutral: 13% (8% in 2017)
  • Disagree/Strongly disagree: 3% (5% in 2017)

In instances where entities request an approval, exemption or variation to a prudential standard or reporting standard (39% of respondents, 45% in 2017) – how did APRA handle your request for approval, variation or exemption considering the process rather than the APRA decision:

  • Very Well/Well: 75% (73% in 2017)
  • Neutral: 22% (15% in 2017)
  • Poorly/Very Poorly: 2% (12% in 2017]
  • Don’t know: <1%

APRA's resolution of your entity’s technical and supervisory request is timely:

  • Strongly Agree/Agree: 75% (72% in 2017)
  • Neutral: 14% (18% in 2017)
  • Disagree/Strongly disagree: 9% (10% in 2017)
  • Don’t know: 2% (<1% in 2017)

PGPA Act compliance

During 2018/19, APRA complied with PGPA Act requirements including the publication of its APS and Corporate Plan within required timeframes.

External stakeholder validation

Industry associations generally agreed with APRA’s assessment of KPI 5 that APRA has maintained open and transparent dealing with regulated entities and strong engagement and communication with APRA personnel. In saying that, one industry association did highlight that some of its members have experienced turnover in their key contacts at APRA and instances where timely notification of changes in supervision teams could be improved.

 

KPI 6 - Regulators actively contribute to the continuous improvement of regulatory frameworks

Measures of good regulatory performance

6(i)   Regulators establish cooperative and collaborative relationships with stakeholders to promote trust and improve the efficiency and effectiveness of the regulatory framework.

6(ii)  Regulators engage stakeholders in the development of options to reduce compliance costs. This could include industry self-regulation, changes to the overarching regulatory framework, or other strategies to streamline monitoring and compliance approaches.
6(iii) Regulators regularly share feedback from stakeholders and performance information (including from inspections) with policy departments to improve the operation of the regulatory framework and administrative processes.

 

APRA’s self-assessment against KPI 6

APRA continued to engage with and receive feedback from stakeholders throughout the year and work proactively with domestic and international agencies to continuously improve regulatory frameworks and practices.

In line with its published Service Charter, APRA maintained its commitment to receiving regular feedback from key stakeholders to inform improvements to regulatory frameworks and practices including formally surveying regulated institutions, industry bodies and other knowledgeable observers via its biennial stakeholder survey. Commencing in 2009, the biennial survey is undertaken by an independent party with survey results publicly available on APRA’s website.

As previously highlighted, APRA was subject to a number of independent reviews throughout the year, which culminated in a series of recommendations aimed at improving APRA’s operations and capabilities, regulatory frameworks and practices and the ongoing stability of Australia’s financial system. APRA embraced these reviews as opportunities for continuous improvement. APRA is working closely with other agencies particularly those that form part of the Council of Financial Regulators (CFR) on the implementation of agreed recommendations.

APRA continued to deliver a number of reforms to the prudential framework across all regulated industries during the 2018/19 financial year. APRA’s cooperative and collaborative approach to policy development was confirmed by the 2019 biennial stakeholder survey results, where 82% of stakeholders (84% in 2017) agreed that APRA’s consultation packages provide a good base for consultation with industry.

APRA continued to play an active role in relevant domestic and international groups and forums for banking, insurance and superannuation to remain informed on, and contribute to, best practice regulatory developments and to determine how they should apply in the Australian context.

Supporting evidence for KPI 6

Feedback mechanisms

APRA accepts feedback from stakeholders via the 'contact APRA' service available at: https://www.apra.gov.au/contact-us. For regulated institutions, feedback can be provided directly to APRA’s Responsible Supervisors. For members of the public, feedback can be provided via the APRAinfo team on 1300 558 849, via the ‘contact APRA' service on APRA’s website or by contacting any of APRA’s offices listed on its website.

Stakeholder surveys

The results of APRA’s 2019 biennial stakeholder survey were published on 31 July 2019. Publication of the survey results underline APRA’s commitment to transparency and accountability and are used to inform ongoing improvements to APRA’s operations and regulatory frameworks and practices.

Independent reviews

As mentioned above, a number of independent reviews (FSAP, Royal Commission, two productivity reviews and the APRA Capability review) examined various aspects of APRA’s activities and operations throughout the year. Following the completion of the FSAP, Royal Commission and APRA Capability reviews, APRA provided details of the recommendations/ findings and outlined its acceptance and commitment to addressing recommendations via public documents available on its website.

Policy consultations

As noted in APRA’s Statement of Intent

“APRA’s policy development process will continue to include comprehensive industry consultation to provide for open and transparent consideration of stakeholder views and include the publication of non-confidential stakeholder submissions and APRA’s response papers.”

During 2018/19, APRA progressed 404 consultation packages covering enhancements to the prudential framework. Non-confidential stakeholder submissions and responses to submissions, were publicly released on APRA’s website.

Stakeholder feedback on policy consultations

APRA's 2019 biennial stakeholder survey asked stakeholders to rate their level of agreement with the following statement:

APRA's consultation packages provide a good base for consultation with industry:

  • Strongly Agree/Agree: 82% (84% in 2017)
  • Neutral: 15% (14% in 2017)
  • Disagree/Strongly disagree: 1% (2% in 2017)
  • Don’t know: 2%

International engagement

There are significant benefits to the Australian financial sector in APRA maintaining practices founded on international standards, and in APRA engaging with international bodies and offshore regulators to seek consistent and coordinated supervisory approaches, learn from peer experiences and share better practices.

APRA's international activities take two main forms: liaison with overseas supervisory agencies on the activities of internationally active institutions that form part of a Group including through participation in supervisory colleges; and participation in global standard-setting bodies to ensure relevant characteristics of the Australian financial system are taken into account in how international standards evolve.

In 2018/19, APRA:

  • Received visits from 38 international delegations across 18 countries to share information on supervisory practices and other core business activities.
  • Maintained membership with 12 international organisations.
  • Liaised or assisted another 9 international organisations.
  • Had bilateral information sharing arrangements with 32 overseas regulatory agencies through Memorandums of Understanding (MoUs) and letters of exchanges.

External stakeholder validation

Industry associations agreed with APRA’s assessment of KPI 6. Specific feedback is highlighted below.

‘We consider that APRA has … and has been generally effective in actively contributing to the continuous improvement of prudential regulation frameworks.’’

Footnotes:

4 ADI - 14; General Insurance - 1; Life Insurance – 4; Private Health Insurance – 3; Superannuation – 7; Cross Industry – 11. 

 

Attachment A – Performance measures relevant to each KPI

KPI 1 – Regulators do not unnecessarily impeded the efficient operation of regulated entities

Measures of good regulatory performance5 APRA measures

1(i) Regulators demonstrate an understanding of the operating environment of the industry or organisation, or the circumstances of individuals and the current and emerging issues that affect the sector.

1(ii) Regulators take actions to minimise the potential for unintended negative impacts of regulatory activities on regulated entities or affected supplier industries and supply chains.

1(iii) Regulators implement continuous improvement strategies to reduce the costs of compliance for those they regulate.

1.1 APRA publications address current and emerging issues or developments in the financial sector.

1.2 Development of standards includes a consultation process consistent with the Office of Best Practice principles (OBPR) including preparing Regulation Impact Statements (RIS), public release of stakeholder submissions and a response to submissions.

1.3 Publicly reported peer assessments against relevant international practices and standards and demonstrated engagement with relevant international bodies and offshore regulators.

1.4 Feedback collected and publicly reported from biennial stakeholder survey.

KPI 2 – Communication with regulated entities is clear, targeted and effective

Measures of good regulatory performance5 APRA measures

2(i) Regulators provide guidance and information that is up to date, clear, accessible and concise through media appropriate to the target audience

2(ii) Regulators consider the impact on regulated entities and engage with industry groups and representatives of the affected stakeholders before changing policies, practices or service standards.

2(iii) Regulators’ decisions and advice are provided in a timely manner, clearly articulating expectations and the underlying reasons for decisions

2(iv) Regulators’ advice is consistent and supports predictable outcomes

2.1 APRA publishes up-to-date guidance on its framework, processes and activities on its external website.

2.2 Timely communication on key developments or consultations are delivered electronically to all relevant APRA contacts and those stakeholders that register for notifications on APRA’s website.

2.3 Development of standards includes a consultation process consistent with the Office of Best Practice principles including preparing Regulation Impact.

2.4 Statements, public release of stakeholder submissions and a response to submissions.

2.5 Feedback is collected and publicly reported from biennial stakeholder surveys.

KPI 3 – Actions undertaken by regulators are proportionate to the regulatory risk being managed

Measures of good regulatory performance5 APRA measures

3(i) Regulators apply a risk-based, proportionate approach to compliance obligations, engagement and regulatory enforcement actions.

3(ii)Regulators’ preferred approach to regulatory risk is regularly reassessed. Strategies, activities and enforcement actions are amended to reflect changing priorities that result from new and evolving regulatory threats, without diminishing regulatory certainty or impact.

3(iii) Regulators recognise the compliance record of regulated entities, including using earned autonomy where this is appropriate. All available and relevant data on compliance, including evidence of relevant external verification is considered.

3.1 APRA publications address current and emerging issues or developments in the financial sector.

3.2 APRA publishes its supervisory and enforcement approaches on its website.

3.3 Statements of Expectations and Intent are published.

3.4 Feedback is collected and publicly reported from biennial stakeholder surveys.

KPI 4 – Compliance and monitoring approaches are streamlined and coordinated

Measures of good regulatory performance5 APRA measures

4(i) Regulators’ information requests are tailored and only made when necessary to secure regulatory objectives, and only then in a way that minimises impact.

4(ii) Regulators’ frequency of information collection is minimised and coordinated with similar processes including those of other regulators so that, as far as possible, information is only requested once.

4(iii) Regulators utilise existing information to limit the reliance on requests from regulated entities and share the information among other regulators, where possible.

4(iv) Regulators base monitoring and inspection approaches on risk and, where possible, take into account the circumstance and operational needs of the regulated entity.    

4.1 APRA collects and shares statistical information with other government agencies including RBA, ABS and ASIC.

4.2 Development of the reporting framework includes a consultation process consistent with the Office of Best Practice principles including preparing Regulation Impact Statements, public release of stakeholder submissions and a response to submissions.

4.3 APRA publishes non-confidential industry and entity level statistical information.

4.4 Feedback is collected and publicly reported from biennial stakeholder surveys.

KPI 5 – Regulators are open and transparent in their dealing with regulated entities

Measures of good regulatory performance5

APRA measures

5(i) Regulators’ risk-based frameworks are publicly available in a format which is clear, understandable and accessible

5(ii) Regulators are open and responsive to requests from regulated entities regarding the operation of the regulatory framework, and approaches implemented by regulators.

5(iii) Regulators’ performance measurement results are published in a timely manner to ensure accountability to the public.

5.1 APRA publishes its supervisory and enforcement approaches on its external website.

5.2 Demonstrated regular engagement with stakeholders.

5.3 APRA publicly reports on its performance and provides detail on key aspects of APRA’s activities.

5.4 APRA’s service charter is publicly available.

5.5 Feedback collected and publicly reported from biennial stakeholder survey.

KPI 6 – Regulators actively contribute to the continuous improvements of regulatory frameworks

Measures of good regulatory performance5 APRA measures

6(I) Regulators establish cooperative and collaborative relationships with stakeholders to promote trust and improve the efficiency and effectiveness of the regulatory framework.

6(ii) Regulators engage stakeholders in the development of options to reduce compliance costs. This could include industry self-regulation, changes to the overarching regulatory framework, or other strategies to streamline monitoring and compliance approaches.

6(iii) Regulators regularly share feedback from stakeholders and performance information (including from inspections) with policy departments to improve the operation of the regulatory framework and administrative processes. 

6.1 Development of standards includes a consultation process consistent with the Office of Best Practice principles including preparing Regulation Impact Statements, public release of stakeholder submissions and a response to submissions.

6.2 Feedback mechanisms are available and made known to all stakeholders.
6.3 Feedback is collected and publicly reported from biennial stakeholder surveys.
 

Footnotes:

The Government framework explicitly defines measures of good regulatory performance for each high-level KPI