APRA EFS Reporting: How the Collection Works After the RPG 701.0 Update

RegReportingDesk card: APRA, Australian Prudential Regulation Authority, Australia

On 28 September 2026 the Australian Prudential Regulation Authority (APRA) released a revised RPG 701.0 ABS/RBA Reporting Concepts for the Economic and Financial Statistics (EFS) Collection, the practice guide that authorised deposit-taking institutions (ADIs) and registered financial corporations (RFCs) use to interpret the EFS forms. For teams that own APRA EFS reporting, three edits carry filing consequences: a new Section 1.20 on set-off accounts, a rewritten Section 1.5.5 that closes the list of central borrowing authorities (CBAs), and the move of the last stand-alone EFS FAQs into an annex at the back of the guide. APRA says the separate EFS FAQ page on its website will be retired.

The data travels well beyond APRA. RPG 702.0 records that the Australian Bureau of Statistics (ABS) uses EFS data to compile Australia’s National Accounts and leading indicators of lending activity, and that the Reserve Bank of Australia (RBA) uses it to construct and publish the monetary and credit aggregates. A loan that a core banking system nets against a linked deposit, and that reaches the return in that netted form, feeds straight into those published series.

The September 2026 material is described as an update to RPG 701.0 rather than an amendment to an EFS reporting standard. Neither the release nor the guide states a separate application date. The gross reporting treatment for linked loan and deposit balances is not new: earlier APRA RPG 701.0 guidance already stated that linked deposit and loan balances were, absent contrary instructions, to be reported on a gross basis. Entities should therefore treat the September update as guidance to be applied to current reporting rather than as establishing a new implementation date.

Related reading: APRA’s 2026 minor updates to the prudential framework

What the September 2026 RPG 701.0 changes, edit by edit

The release lists four changes, and each maps to a specific part of the guide.

  • FAQ consolidation. APRA says most EFS FAQs were already absorbed into the guide in 2024. The September 2026 edition takes the remainder: the content of FAQ 144 now sits in Section 1.5.5, and the other surviving FAQs appear in a new Frequently Asked Questions part at the end of the document, renumbered by form with the original FAQ number kept for reference.
  • Central borrowing authorities. Section 1.5.5 now explains what a CBA is, restricts the classification to seven named entities and directs ACT Treasury to the state, territory and local government sector.
  • Set-off accounts. A new Section 1.20 covers accounts that let a customer’s loan and deposit be recognised internally as one net position, and sets the EFS reporting basis for the linked balances.
  • Format. The document has been reformatted to align with APRA’s style guidance.

The release is silent on legal status, so the guide’s own preamble fills the gap. The “About this guide” section states that reporting practice guides discuss legal requirements from legislation and APRA’s standards “but do not themselves create enforceable requirements”. The binding text remains ARS 701.0 ABS/RBA Definitions for the EFS Collection and the individual EFS reporting standards. My reading is that Section 1.20 describes how the existing loan and deposit items were meant to be reported all along, so an entity that currently nets set-off balances has a data quality question to answer on its next return, with no future start date attached.

The EFS collection, formerly called the Domestic Books collection, is administered by APRA on behalf of the ABS and the RBA. The EFS reporting standards are made under section 13 of the Financial Sector (Collection of Data) Act 2001 (FSCODA), as the Authority paragraphs of ARS 701.0, ARS 720.1 and ARS 730.0 each state; the 2021 determination that remade ARS 730.0 cites paragraph 13(1)(a). From statute to form, the chain has three layers.

  • ARS 701.0 defines the terms used across the collection, including residency, domestic books, sector classifications and the ADI reporting categories, and states that all EFS reporting standards applicable to ADIs and RFCs must be read in conjunction with it.
  • The form standards each carry their own application table, frequency, due date and quality control paragraph. The ARS 720 series covers the balance sheet, loans and finance leases, deposits, intra-group positions, securities held and on issue, and bill acceptances; ARS 721.0 covers repos and securities lending; ARS 722.0 derivatives; ARS 723.0 margin lending; ARS 730.0 and ARS 730.1 financial performance and fees; and ARS 741.0 to ARS 748.0 business, housing and personal finance together with the credit, deposit and wholesale funding stocks, flows and interest rates.
  • RPG 701.0 (reporting concepts) and RPG 702.0 (data quality) sit underneath as guidance, alongside the EFS Priority Listing for Data Items.

Two boundary points are easy to miss for anyone arriving from prudential reporting. First, APRA’s banking standards page lists the ARS 731 International Banking Statistics returns in the same block as the EFS standards, yet the list of EFS reporting standards in the registered ARS 701.0 (F2024L00434) does not include them, and RPG 701.0’s form-specific guidance runs from ARF 720.0A/B to ARF 748.0A/B and stops there. ARS 701.0 definitions reach those returns only if their own instructions import them. Second, the same banking page labels ARS 701.0 with the RPG’s title, “Reporting Concepts”. The instrument itself, and APRA’s RFC standards page, use “ABS/RBA Definitions for the EFS Collection”, which is the title to cite in a policy or data dictionary.

Other jurisdictions route the same kind of data differently. In the UK, banks send statistical balance sheet data directly to the Bank of England, as our Form BT monthly reporting note covers. In Australia the prudential regulator collects on behalf of the statistical agencies, under a statute built for data collection.

ADI Category A, Category B and the thresholds that pick the form

ARS 701.0 splits ADIs into two reporting categories, and the split is a list. The registered ARS 701.0 (F2024L00434, registered on 9 April 2024 and applying to reporting periods ending on or after 30 June 2024) defines ADI Category A by naming individual institutions, mostly credit unions and building societies plus a number of other ADIs, and defines ADI Category B as every ADI not in Category A. Only a change to that named list moves an ADI between categories, whatever its growth.

The form standards then add asset thresholds. Under the current ARS 720.1 ABS/RBA Loans and Finance Leases, made by Financial Sector (Collection of Data) (reporting standard) determination No. 9 of 2022 (F2022L00212), the application table reads:

Class of institution ARF 720.1A (Standard) ARF 720.1B (Reduced)
ADI Reporting Category A No Yes, if total assets are $200 million or more
ADI Reporting Category B Yes No
RFCs No Yes, if total assets are $50 million or more

ARS 730.0 ABS/RBA Statement of Financial Performance applies only to ADIs with total assets of $5 billion or more and RFCs with $500 million or more. All amounts are Australian dollars.

The measurement point is fixed in each standard, and the two standards do not measure RFCs the same way. Under ARS 720.1, an ADI’s total assets means the value at item 13 (column 1) of ARF 720.0A/B, or item 11 of ARF 323.0 Statement of Financial Position (Licensed ADI), as at 31 December of the prior calendar year, while an RFC’s means item 13 of ARF 720.0A as at the last day of its prior financial year. ARS 730.0 measures both ADIs and RFCs at item 13 (column 1) of ARF 720.0A/B as at 31 December of the prior calendar year. Read literally, whether ARS 730.0 applies to an entity’s 2027 reporting periods turns on its 31 December 2026 figure, whatever the balance sheet does during 2027.

“Reduced” is easy to read as a lighter cycle. The Reduced form has fewer items, but ARS 720.1 puts a Category A ADI with $200 million or more on the same monthly frequency and the same 10-business-day due date as a Category B ADI filing the Standard form. The frequency concession belongs to RFCs: those below $400 million report once per financial year.

APRA keeps discretion inside the application paragraphs. ARS 720.1 paragraph 5 lets it determine that a threshold, or a higher threshold, applies to a particular ADI or RFC and notify that entity in writing, and a footnote gives the example of exempting an ADI from ARF 720.1A under paragraph 16(1)(b) of FSCODA on condition that it provides ARF 720.1B. Anyone mapping obligations from the published tables should check the entity’s correspondence file for such a notice before settling which form applies.

Domestic books: a perimeter narrower than the statutory group

Every EFS form is reported on a domestic books consolidation. For an ADI, ARS 701.0 defines that as an unconsolidated report of positions, transactions and other information recorded on the Australian books of the body corporate authorised by APRA to carry on banking business, covering dealings with both residents and non-residents booked there. Extended licensed entities, entities not consolidated at Level 1, related parties such as subsidiaries, SPVs and parent entities, and overseas-based branches and offshore banking units stay out.

Section 1.4.2 of RPG 701.0 states the rule in both directions: an entity not consolidated for statutory reporting is not consolidated for domestic books either, and several entities that are consolidated statutorily are still excluded. Table 2 of the guide then settles the common cases:

  • Australian-based branches and Australian-based offshore banking units are consolidated; their overseas-based equivalents are not.
  • Subsidiaries, parent entities and extended licensed entities are not consolidated.
  • Bare trusts are consolidated only where the reporting institution is the beneficiary.
  • SPVs are not consolidated by ADIs, or by RFCs that are related parties of an ADI. Other RFCs consolidate their resident SPVs under Section 1.4.4.

The effect lands on counterparty classification. Positions with the related entities left outside domestic books are reported as positions with related parties. Section 2.2.2 gives the concrete case: loans to SPVs that are related parties are excluded from ARF 720.1A/B and reported on ARF 720.3 ABS/RBA Intra-group Assets and Liabilities. A loan book sourced from the statutory consolidation gets the perimeter wrong twice: it pulls in the books of entities EFS excludes, and it eliminates the loans to those entities that EFS wants reported on ARF 720.3.

Section 1.20: set-off accounts are reported gross

The new section is short. It describes set-off accounts as arrangements that allow a customer’s loan and deposit accounts to be recognised internally as a net asset or liability depending on the flows in the period, and states that for EFS reporting purposes the linked loan and deposit balances are to be reported on a gross basis unless otherwise specified. It adds that this is similar to the treatment of offset accounts and may differ from accounting treatments.

The offset account comparison points back to Section 1.12.2, which lists offset accounts first among the items that deposits generally include. Section 1.20 extends the same logic to products where the netting sits deeper in the system. Seven form-specific sections now list Section 1.20 among the general guidance that applies: 2.1.1 for ARF 720.0A/B Statement of Financial Position, 2.2.1 for ARF 720.1A/B Loans and Finance Leases, 2.3.1 for ARF 720.2A/B Deposits, 2.4.1 for ARF 720.3 Intra-group Assets and Liabilities, 2.14.1 for ARF 741.0 Business Finance, 2.15.1 for ARF 742.0A/B Business Credit Stocks, Flows and Interest Rates and 2.20.1 for ARF 747.0A/B Deposit Stocks, Flows and Interest Rates.

An illustration with hypothetical figures: a customer has a $500,000 loan and a linked $120,000 deposit under a set-off arrangement, and the core system carries a single $380,000 net asset. On the EFS forms the guidance points to $500,000 in loans on ARF 720.1A/B and $120,000 in deposits on ARF 720.2A/B, each classified by the customer’s sector and residency.

The reconciliation meant to catch a netting error can miss it. A netted extract understates loans and deposits by the same amount, so ARF 720.0A/B still balances, and a total-assets tie-out to a general ledger that nets the same way still passes. The gap shows only against a gross, product-level extract.

The “unless otherwise specified” carve-out needs the same form-by-form care. Section 1.20 lists no exceptions itself, but the guide already contains one: Section 2.15.3 has ARF 742.0A/B reporters report credit outstanding net of offset account balances and, for a loan with an attached set-off account, the loan less the deposits in that account, never below zero. Any other net treatment has to trace to an equally specific instruction.

Central borrowing authorities: seven names, with ACT Treasury outside the list

Sector classification in the EFS collection follows the Standard Economic Sector Classifications of Australia (SESCA) 2008, and Section 1.5.1 assigns each entity to one and only one SESCA category. CBAs form one of the financial institution sub-sectors in that schema. In the revised draft of RPG 701.0 that APRA released with its response to consultation on 29 January 2024, Section 1.5.5 was a bare list of eight entities, the last of them ACT Treasury.

The September 2026 text adds a description, that CBAs primarily provide finance for public corporations and for notional institutional units and other units owned or controlled by government, and then closes the list. Only the following entities are classified as CBAs for EFS reporting:

  • NSW Treasury Corporation
  • Treasury Corporation of Victoria
  • Queensland Treasury Corporation
  • Western Australian Treasury Corporation
  • South Australian Government Financing Authority
  • Tasmanian Public Finance Corporation
  • Northern Territory Treasury Corporation

ACT Treasury is to be reported as “state, territory and local government” and not as a CBA. APRA’s release says Section 1.5.5 now carries information previously covered in FAQ 144 and states no application date, so the September 2026 text does not itself date a sector change for ACT Treasury.

The check sits in counterparty static data: a mapping table that still carries ACT Treasury as a CBA has it in a financial institution sub-sector where the guide places it in general government, and because the list is now closed, any other public financing body that the table has placed in the CBA sector needs a second look. ANZSIC-based mapping will not settle it on its own: Section 1.5.8 acknowledges that the ANZSIC 2006 to SESCA 2008 concordance is one-to-one for most classes but not all. Germany faces the same public-sector boundary in its bank statistics, and our note on Bundesbank customer classification and RS-57 shows how an official entity list resolves those cases there.

The new FAQ annex: old numbers, new identifiers

Seven FAQs survive as stand-alone entries. Each now carries a form-based identifier, with the old number retained in the heading:

New identifier Previously Subject
ARF 722.0-1 FAQ 150 Settled-to-market derivatives and quarterly flows on ARF 722.0
ARF 730.0-1 FAQ 145 Market data provider expenses (Bloomberg, Reuters, IRESS) at item 7.1.7 Other information technology expense
ARF 730.0-2 FAQ 146 Credit card loyalty programs and marketing costs at item 8.1.5 Advertising expense
ARF 730.0-3 FAQ 147 Staff bonuses at item 5.1.1 Total wages and salaries
ARF 730.1-1 FAQ 148 Interchange payments excluded; merchant service fees reported gross of interchange expenses at Item 3
ARF 730.1-2 FAQ 149 Fees reported net of housing loan cashback offers
ARF 748.0A/B-1 FAQ 143 When changes to existing liabilities, such as repos, count as new issuance at item 5.1

FAQ 144, on central borrowing authorities, has no annex entry because its content moved into Section 1.5.5. The form-specific sections point to the annex where relevant; Section 2.21.13, for example, is an “Additional FAQ” heading that refers the reader to ARF 748.0A/B-1 (previously FAQ 143).

Two entries carry conditions that are easy to lose when the source document changes. ARF 722.0-1 lets an entity using settled-to-market (STM) derivatives, whose opening and closing positions are zero, report reasonable estimates of what those positions would have been if the derivatives were collateralised-to-market, in Item 5, so the agencies can compile quarterly derivative flows. The entity is asked to notify the agencies through the Data Analytics inbox before adopting the approach, and the agencies accept that ARF 722.0 will then differ from ARF 720.0 for those positions. ARF 748.0A/B-1 treats three changes to an existing liability as new issuance: an extension of maturity beyond the originally contracted unwind date (liabilities with no defined unwind date, such as open repos, are excluded), an increase in the contracted cash amount, and a renegotiated interest rate (trades at a floating rate such as the cash rate plus a margin are excluded). Changes to collateral, haircuts or margin calls on an existing repurchase agreement count only where they increase the cash value of the liability.

The release says the existing EFS FAQs “will be retired” and gives no date. Procedure manuals, data dictionaries and comments in mapping code that cite “FAQ 147” or “FAQ 150” will outlive the page they point to; the September 2026 identifiers are the ones that will still resolve.

EFS due dates run on two clocks

The due-date paragraph sits in each form standard, and the two standards checked for this article use different day counts.

  • ARS 720.1 (loans and finance leases): monthly for Category B ADIs, Category A ADIs with total assets of $200 million or more, and RFCs with $400 million or more; once per financial year for RFCs below $400 million. Due within 10 business days after the end of the reporting period.
  • ARS 730.0 (financial performance): quarterly, for quarters ending 31 March, 30 June, 30 September and 31 December. Due within 28 calendar days after the end of the reporting period, which puts the September 2026 quarter at 28 October 2026. A footnote adds that where the due date falls on a day other than a usual business day, the return is still due no later than that date.

A reporting calendar that applies one convention to both forms will misstate one of them. A business-day clock stretches around weekends and public holidays; a calendar-day clock does not. APRA’s RFC reporting page summarises monthly forms as due 10 business days, and quarterly forms 20 business days, after the end of the period, which does not match the 28 calendar days written into ARS 730.0. I treat the due-date paragraph in each reporting standard as the controlling text and use web summaries as a cross-check. Paragraph 12 of both standards also lets APRA grant an extension of a due date in writing, in which case the date on the notice becomes the due date.

Submitting EFS returns after D2A: APRA Connect

ARS 730.0’s 2021 text requires electronic submission through the Direct to APRA (D2A) application or by a method, namely a web-based solution, that APRA notifies in writing before submission; the current ARS 720.1 text (F2022L00212, 2022) requires submission by an electronic method available on APRA’s website or by a method APRA notifies before submission, without naming D2A. With D2A gone, ARS 730.0 is left with its notified-method limb, while APRA Connect can fit either of the two limbs in ARS 720.1. APRA identified security vulnerabilities in D2A on 19 March 2026 and took the system offline on 20 March 2026. APRA is accelerating the migration of its data collections to APRA Connect, and its current migration timetable states that EFS and most ADI returns began reporting in APRA Connect from the 30 June 2026 reference period. The migration page also describes an opt-out model under which an opted-out return is lodged through the Alternate Submission Process, but that route has since closed for EFS.

APRA’s page on alternative submission arrangements states that EFS returns for the March 2026 reporting period can be found in APRA Connect in line with guidance issued on 8 April 2026, and that returns should be submitted via APRA Connect. Where SecureDoc is used, the corresponding return must also be submitted in APRA Connect, without an attachment, to support reconciliation. APRA’s letter to industry of 27 July 2026, End of Alternate Submission Process for ADIs and RFCs, requires EFS returns to be submitted through APRA Connect from the reference period ending 31 August 2026. Superannuation returns are going through their own migration, covered in our note on APRA’s superannuation data collections and the move to APRA Connect.

Data quality under RPG 702.0: when a netting correction becomes a reporting error

An entity that has been netting set-off balances changes its reported loan and deposit stocks when it moves to gross. Whether the historic difference counts as a reporting error is a question RPG 702.0 ABS/RBA Data Quality for the EFS Collection (October 2024) answers with benchmarks. Every data item carries a standard, high or very high priority in the EFS Priority Listing for Data Items, effective 1 November 2024, and the tolerances are calibrated by priority, by entity size and by whether the item is a stock or a flow.

A large institution is an ADI or RFC with $200 billion or more in total assets on a domestic books basis. For a large institution, Table 1a sets stock benchmarks of 0.50 per cent and $2,000 million for very high priority items and 5.00 per cent for high priority items. For other reporting entities, Table 1b sets 2.00 per cent and $500 million for very high priority items and 10.00 per cent for high priority items, and the guide’s Example 1 also tests a high priority stock item against the $500 million figure. Flow items carry wider percentages, and standard priority items expressed as a dollar value, count or proportion are left to the entity’s judgement. Items reported as a rate, such as interest rates, are tested against separate basis-point benchmarks in Tables 2a and 2b, which set 15 basis points for a large institution and 20 basis points for other entities even for standard priority items.

Where a reporting error occurs, the agencies expect the entity to notify APRA, and APRA, in consultation with the ABS and RBA, may require the data to be resubmitted depending on the size of the error and its effect on their use of the data. They also expect the entity to review its data quality processes and controls. Behind that guidance sits a hard requirement in each form standard: EFS information must be the product of systems, processes and controls reviewed and tested by the external auditor under APS 310 Audit and Related Matters for ADIs, or RRS 710.0 for RFCs, on an annual basis or more often if the auditor requires.

Frequently Asked Questions

A sole trader’s deposit account is held in the owner’s personal name. Is it household or business?

Section 1.5.7 of RPG 701.0 reports positions recorded in an individual’s name but held for a business under the category that fits the business, outside the household sector. The test runs account by account: one customer can hold a personal credit card that belongs in households and a business credit card that belongs in private unincorporated businesses. A facility that mixes business and personal use follows its predominant purpose class, and where the institution has no information suggesting business use, the account goes to households.

A trustee or custodian places a deposit on behalf of a trust. Which sector is the counterparty?

RPG 701.0 classifies the counterparty by the sector of the trust itself, looking through the trustee, responsible entity or custodian. That exception sits against the general flow-of-funds principle, under which the counterparty is the entity the reporting institution faces. A funds manager depositing on behalf of a household is treated differently under Section 1.18: the deposit is reported as one from the funds manager, and as an intra-group liability where the funds manager is a related party.

Our group holds several RFCs under one parent. Can one of them file for all?

Section 1.4.3 allows RFCs owned or controlled by the same parent entity to report individually or as a group through a single return, and the guide expects the choice to be consistent across all forms for a given period. In group mode, thresholds apply to the consolidated domestic books of all the RFCs, positions between them drop out, and each RFC informs APRA by email which institution reports on its behalf. A fresh email is only needed when the arrangement changes, at the time the form is submitted.

How are covered bond issuers, holding companies and sovereign wealth funds classified?

Section 1.5.7 classifies resident issuers of covered bonds as ADIs. Holding companies follow SESCA 2008: mainly financial subsidiaries make the holding company a financial auxiliary, while mainly non-financial subsidiaries place it in other private non-financial corporations. Sovereign wealth funds owned by the Commonwealth, such as the Future Fund Management Agency and other Australian Government Investment Funds, go to Commonwealth general government, and state-owned funds to state, territory and local general government.

Can APRA change how often an entity reports a particular EFS form?

Yes. ARS 720.1 and ARS 730.0 both let APRA, by notice in writing, require an ADI or RFC to report more or less frequently, having regard to the entity’s particular circumstances and to the extent the ABS or RBA needs the information. Where such a notice exists, the entity’s reporting calendar follows the notice for that form.

RPG 701.0 labels some methods PROXY and others TRANSITIONAL PROXY. Does the difference matter?

It does. A PROXY is acceptable on an ongoing basis. A TRANSITIONAL PROXY is acceptable only for a period, and the guide describes when its use stops being appropriate. For syndicated loans, Section 2.2.4 allows an internal allocation methodology where no business-as-usual contact with the borrower occurred before EFS reporting began in 2019, to be updated at the next business-as-usual point of contact. An entity still relying on a transitional proxy should be able to point to why its end condition has not yet arrived.

Key Takeaways

  • Set-off-linked loans and deposits: gross on the seven forms whose guidance lists Section 1.20 (ARF 720.0A/B, 720.1A/B, 720.2A/B, 720.3, 741.0, 742.0A/B and 747.0A/B), except where an instruction nets them, such as the ARF 742.0A/B credit outstanding net of offset balances covered by Section 2.15.3.
  • CBA static data: seven named treasury corporations and financing authorities only; ACT Treasury positions belong in state, territory and local government.
  • Replace references to FAQs 143 and 145 to 150 with the ARF 722.0, 730.0, 730.1 and 748.0A/B annex identifiers; FAQ 144 content now lives in Section 1.5.5.
  • Build the EFS calendar from each standard’s own due-date paragraph: ARS 720.1 counts business days, ARS 730.0 counts calendar days.
  • Thresholds test prior-year total assets as at 31 December for ADIs: $200 million for ARF 720.1B (Category A) and $5 billion for ARF 730.0.
  • Size any historic netting gap against the RPG 702.0 benchmarks for the item’s priority before deciding whether APRA needs a notification.
  • D2A has been offline since 20 March 2026. EFS reporting moved to APRA Connect from the 30 June 2026 reference period, and APRA’s letter of 27 July 2026 made APRA Connect mandatory for EFS from the reference period ending 31 August 2026, closing the Alternate Submission Process route.

Sources and References

Before the September 2026 EFS returns go in

The first EFS cycle after the release is the September 2026 reporting period. The monthly ARS 720.1 returns fall due 10 business days after 30 September, and the quarterly ARF 730.0 is due on 28 October 2026. Ahead of those submissions, the three artefacts worth producing are a gross-versus-net extract for every product with set-off functionality, a checked counterparty record for ACT Treasury, and procedure references repointed from the retired FAQ numbers to the September 2026 identifiers. If the gross extract shows a historic gap on loans or deposits beyond the RPG 702.0 benchmarks, that gap is a reporting error the agencies expect APRA to be told about.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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