SRS 604.0 Confidentiality: 6 November Close on Director and Board Data

ByRegReportingDesk
RegReportingDesk card: APRA, Australian Prudential Regulation Authority, Australia

On 23 October 2026 the Australian Prudential Regulation Authority (APRA) opened a two-week SRS 604.0 confidentiality consultation. It proposes to determine, under section 57 of the Australian Prudential Regulation Authority Act 1998 (APRA Act), that five fields RSE licensees report under Reporting Standard SRS 604.0 RSE Licensee Profile do not contain confidential information. Written submissions close on 6 November 2026.

The five fields are director type, director representative type, gender and director remuneration from Table 3A, plus board or board committee type from Table 4. APRA already publishes this data in its annual fund-level superannuation statistics and annual superannuation bulletin for 2025 and earlier years, and says the determination would let it keep both publications in their existing format, with no change to the scope of data published.

For a trustee, the most visible output is the trustee-level table. APRA’s mock-up of it prints director counts by gender and the total and average remuneration of the board against each named RSE licensee.

Related reading: APRA Superannuation Data Collections: The 21 August 2026 Consultation

Dates in the SRS 604.0 confidentiality consultation

  • 23 October 2026: APRA publishes a media release, a consultation letter with an Appendix 1 field list, and two mock-up workbooks on its Superannuation Data Transformation: Phase 2 Depth consultation page.
  • 6 November 2026: written submissions due by email to dataconsultations@apra.gov.au.
  • December 2026: next scheduled release of both the annual fund-level superannuation statistics and the annual superannuation bulletin (June 2026 editions), according to APRA’s publication pages.
  • Decision: no date given. APRA will consider the feedback before deciding whether to make the determination, then communicate the outcome.

APRA considers two weeks appropriate because the data is already published. The letter does not say whether it intends the determination to be in place before the December 2026 releases.

Appendix 1: the five SRF 604.0 columns APRA names

Appendix 1 to the letter lists the data by table and column of Reporting Form SRF 604.0; the field values below have been checked against the SRF 604.0 instructions in the reporting standard determined on 30 April 2025.

SRF 604.0 location Field What the instructions ask for
Table 3A, column 2 Director Type Independent, non-affiliated, executive, non-executive or alternate director
Table 3A, column 3 Director Representative Type Member, employer or parent company representative; independent directors take a separate not-applicable value
Table 3A, column 9 Gender Female, male, non-binary, other, or not stated or inadequately described
Table 3A, column 11 Director Remuneration Whole dollars: total remuneration, including superannuation, paid to or in relation to the director for the financial year, including committee and consulting fees in relation to the RSE licensee; where a director is not directly remunerated for the role but is compensated by another organisation, the value apportioned to the director role
Table 4, column 2 Board Or Board Committee Type The board, one of nine named committee types (audit, investments and risk and compliance among them) or “Other Committees”

The list is column-specific. Table 3A also carries each director’s Director Identification Number, title, given and family names, year of birth, position dates, the name and ABN of any entity the director represents, and counts of other directorships and other employment. None of those columns is in Appendix 1, and nor is anything from Tables 1, 2, 3B, 3C or 5.

Column 11 carries a judgement call that can shape published remuneration figures. Where a director is not directly remunerated for performing the role but is compensated by another organisation, such as an employer-sponsor, the instructions require the licensee to apportion the value of remuneration that relates to the role as director and report that value. For those directors, the number APRA aggregates is the licensee’s own apportioned figure; for a director paid directly for the role, the column calls for the total remuneration paid to or in relation to the director.

Where the fields land in APRA’s mock-ups

Both mock-up workbooks reuse the layout of the editions released on 16 December 2025 and label each line drawn from SRF 604.0 with its source reference, so an Appendix 1 field can be traced to a published number.

Mock-up table Level of publication Items sourced from SRF 604.0
Annual fund-level superannuation statistics, Table 1 “Trustee-level profile and structure” One row per RSE licensee, shown by name and ABN Number of female directors and number of male directors (Table 3A item 9); total directors on the trustee board (Table 3A); total and average director remuneration in $’000 a year (Table 3A item 11)
Annual superannuation bulletin (licensees), Table 2 “RSE licensees directorships” Industry totals, June 2015 to June 2025 series Directorships by gender (Table 3A item 9); directorships by representation (Table 3A columns 2 and 3); number of boards (Table 4 column 2); total and average director remuneration (Table 3A column 11)

In both workbooks remuneration appears as a board total and an average. The fund-level table attaches those two figures to a named licensee; the bulletin aggregates them across the industry. Neither workbook has a line for an individual director’s pay.

Two details are worth checking against a licensee’s own return. The fund-level table publishes female and male counts next to the board total, while column 9 accepts five values. If the board total counts every Table 3A line, the gap between it and the two published counts equals the number of directors reported in the other three categories; the mock-up does not say how those directors are treated. And the bulletin mock-up carries a count of directors with multiple directorships, referenced to SRF 604.0 Table 3A without a column number. Appendix 1 names no Table 3A column for that line.

Why section 57 still matters for data APRA already publishes

SRS 604.0 is made under section 13 of the Financial Sector (Collection of Data) Act 2001, so the returns lodged under it are reporting documents to which section 57 of the APRA Act applies. Section 57(2) lets APRA determine, by legislative instrument, that all or a specified part of reporting documents of a specified kind does not contain confidential information. Section 57(4) sets the test: APRA may do so if it considers that the benefit to the public from disclosure outweighs any detriment to commercial interests that the disclosure may cause. Section 57(3) bars a determination unless interested parties have had a reasonable opportunity to make representations. Once a determination is made, section 56(5C) provides that disclosing the covered document, part or information is not an offence under the APRA Act’s secrecy provision.

The collection vehicle has changed underneath the publications. APRA’s letter says it previously published this data from returns under SRS 600.0 Profile and Structure (RSE Licensee), and now collects similar data under SRS 604.0. A 22 December 2025 APRA letter on the revocation of seven superannuation reporting standards set SRS 600.0’s last reporting period at 30 June 2025, with a last submission date of 30 September 2025.

SRS 604.0 appears on APRA’s list of superannuation standards as in force from 1 May 2025. Its first reporting period is the first financial year ending on or after 30 June 2025; returns are due within three months of year end, with 15 December 2025 set for the first return of licensees with a 30 June year end. The standard requires the data to come from systems the RSE auditor has reviewed and tested under at least a limited assurance engagement.

SRS 604.0 is read with Prudential Standard SPS 510 Governance, which APRA proposed in June 2026 to fold into a cross-industry CPS 510 (see our note on APRA’s governance reform and CPS 510). Its bold-italic defined terms take their definitions from SRS 101.0 Definitions for Superannuation Data Collections, which APRA updated in March 2025 for the APRA Connect taxonomy; our note on the APRA retirement reporting framework covers the SRS 101.0 changes proposed for that collection.

Section 57 permits APRA to make confidentiality determinations covering specified reporting documents or parts of them. Whether the move from SRS 600.0 to SRS 604.0 legally requires a fresh determination depends on the wording and scope of existing confidentiality instruments. A determination under section 57 would specify the confidentiality treatment of the reporting information to which it applies. The letter gives the purpose of the consultation as facilitating APRA maintaining the existing format of the two publications.

Making a representation by 6 November 2026

The letter invites interested parties to make representations on whether any of the Appendix 1 data should be treated as confidential, and asks for specific information about any detriment to commercial interests that disclosure may cause. That request mirrors the section 57(4) weighing of public benefit against commercial detriment.

APRA’s policy is to publish submissions unless the respondent tells APRA in writing that all or part is to remain confidential. An automatically generated confidentiality statement in an email does not meet that requirement; confidential material goes in a separate attachment marked “confidential”. Submissions may be subject to requests under the Freedom of Information Act 1982. Under section 56(11) of the APRA Act, a document that is a protected document or contains protected information is exempt for the purposes of section 38 of the FOI Act. Marking material confidential does not, by itself, establish that the statutory exemption applies.

That default matters for this consultation in particular. A licensee arguing that its board remuneration figures are commercially sensitive would be making the case in a document APRA publishes unless told otherwise, so the supporting detail belongs in the marked attachment.

Section 57(5)(b) defines the interested parties for a determination about reporting documents of a specified kind as associations or other bodies representing the entities that lodge them. The media release and the letter both invite “interested parties” without listing them, and neither says whether APRA would weigh a submission from an individual licensee differently from one lodged through an industry body.

Frequently Asked Questions

What happens to the December 2026 publications if APRA decides against the determination?

The letter does not say. APRA will consider the feedback, decide whether to make the determination and communicate the outcome; its only statement on format is that the determination, if made, would let it keep the existing format of both publications.

Does a director who left the board part-way through the year count in the published totals?

Table 3A requires a line for each individual who was a director on the board at any time during the reporting period, and column 11 is remuneration for the financial year being reported. APRA’s glossary for the annual fund-level statistics defines average remuneration as total director remuneration of directors on the trustee board over the total number of directors on the trustee board, while the annual bulletin glossary defines average director remuneration as total director remuneration over the total number of directorships. Neither definition, nor the two mock-up workbooks, states how a director who served for only part of the period is treated.

Key Takeaways

  • Reconcile first: compare the licensee’s latest SRF 604.0 director and board data with APRA’s published statistical definitions. Confirm the mock-up’s aggregation, population and presentation rules before treating any calculation as the figure APRA would publish against the licensee’s name.
  • On my reading of section 57(4), a representation carries most weight when it sets out specific commercial detriment in writing.
  • Table 3B duties continue: a change that makes reported other directorships inaccurate triggers an update within 28 calendar days after the calendar quarter end, or within 3 months after the period end if it falls in the year-end quarter.
  • Existing reporting continues: a confidentiality determination does not, by itself, amend SRS 604.0 or create an additional periodic return. Under section 17 of the Financial Sector (Collection of Data) Act 2001, APRA may require an RSE licensee to explain or vary an existing reporting document where the statutory conditions are met.
  • Route option: a submission lodged through an association representing RSE licensees falls within the section 57(5)(b) definition of interested party.

Sources and References

What goes to APRA by 6 November

APRA has set no date for its decision, and the next editions of both publications are scheduled for December 2026. A licensee with a commercial detriment argument has until 6 November 2026 to lodge it with dataconsultations@apra.gov.au, with anything meant to stay confidential in a separate attachment marked “confidential”.

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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