Response to submissions - proposed changes to ADI quarterly reporting due dates

The Australian Prudential Regulatory Authority (APRA) has today released a response to submissions on proposed changes to the due dates for ADI quarterly reporting.

Background

In November 2019, APRA consulted on a proposal to standardise quarterly reporting due dates for ADIs to 35 calendar days after the last day of the reference quarter. 

Different quarterly reporting forms are due 15, 20, and 30 business days and 28 calendar days after the end of the quarter. A shift to 35 calendar days extends the time ADIs have to submit data for forms previously due on 15 or 20 business days or 28 calendar days. However, for forms with a due date of 30 business days after the end of the quarter, this reduces the submission timeframe.

On the 1st of April 2020, APRA granted an extension of the due dates for all quarterly forms that were due before 35 calendar days to calendar day 35 as part of a package of COVID relief considerations.¹

Submissions received

APRA received four submissions – two from industry bodies, and two from reporting entities. Submissions were very supportive of the standardisation of reporting due dates, however they raised concerns regarding lower quality of data submitted due to compressed time frames; and potential market sensitivity of the data. One submission recommended the retained use of business days. 

Impacts of bringing forward the due date for ADIs

Two submissions raised concerns that the proposed initiative would reduce the timeframe to submit a small number of forms.  Concerns were focused on the data submitted potentially being of a poorer quality or may have not been approved by boards. Further, there were concerns raised that by bringing forward dates, the data may become market sensitive.

APRA understands that standardising due dates may impose initial complications on ADIs. However, APRA’s view is that, as the complete standardisation will be staggered for forms where there will be a reduction in the submission timeframe, ADIs will have ample time to ensure their reporting systems and operational practices can adhere to the standardisation.

APRA consults directly on the public disclosure of information and will conduct further consultation in the future to consider the market sensitivity of any information before any public disclosures, e.g. in statistical publications.

Use of business day as an alternative to calendar days

One submission suggested that APRA should continue to specify due dates using business days, as ADIs may experience disruption due to public holidays. Given that public holidays are determined nationally and also by each state, APRA prefers to avoid the ongoing variation in due dates that using business days create. Furthermore, APRA considers that, since the standardised due date to 35 calendar days extends the due date for most forms, this is sufficient to alleviate any delays caused by public holidays. 

Response to consultation

APRA has considered submissions from the consultation and will implement the due date of 35 calendar days after the reporting period for all quarterly reporting forms, except for the modernised Economic and Financial Statistics (EFS) reporting forms.

For non-EFS reporting forms that were due before 35 calendar days, APRA will keep the existing extension. These forms will continue to be due on the 35th calendar day. APRA will formally update the due dates in the relevant reporting standards when they are next revised.

For forms that were due after calendar day 35, APRA will update the reporting due date to 35 calendar days when it revises the respective reporting standards and will notify affected ADIs during public consultation on these revisions. Until then, the due dates for these returns remain as specified in the reporting standard.

EFS data collection quarterly reporting

As communicated in the November 2020 letter to industry², the Australian Bureau of Statistics has investigated the impacts of changing the quarterly EFS reporting due dates on the GDP publications. As a result, APRA and the ABS and have agreed to keep the due date of quarterly EFS forms at 28 calendar days after the end of the quarter to maintain the timely production of these publications.

Reporting Form ARF 210.4 3-year Funding Plan (ARF 210.4)

ARF 210.4 is also due on the 28th calendar day after the reporting period, but is due on an annual basis. To avoid confusion, APRA has also extended the due date for this return to the 35th calendar day, effective 1 April 2021.

A full list of affected reporting forms and their previous due dates is presented in the Appendix to this letter.

Yours sincerely,

Alison Bliss
General Manager
Data Analytics and Insights 

Footnotes

¹Changes to reporting obligations in response to COVID-19
²Proposed changes to modernised Economic and Financial Statistics reporting standards and guidance 

Attachment – Schedule of revised quarterly ADI and RFC reporting due dates

The reporting forms specified in the below schedule will be due by 35 calendar days after the end of the quarter. 

For reporting forms that were due before 35 calendar days, this is effective immediately and formalises the extension granted 1 April 2020. 

For reporting forms that are currently due after 35 calendar days, the change will come into effect when APRA next revises the respective reporting standards. APRA will announce when this change will occur when it consults on revisions to these reporting standards.