CA ANZ and CPA Australia have lodged a submission to APRA on its proposed updates to the superannuation prudential framework.

Our main observations and recommendations based on feedback received from members and stakeholder outreach are:

• We support the consequential amendments arising from the Treasury Laws Amendment (2022 Measures No. 4) Act 2023 to reflect that ASIC will have oversight of the reporting and audit of financial statements of registrable superannuation entities (RSE).
• If the Approved Form should be discontinued, we recommend that APRA continues to identify the specific legislative provisions that it would like to be included in the scope of the reasonable assurance compliance engagement in an appropriate APRA pronouncement.
• We also recommend the discontinued Approved Form be adapted as an illustrative assurance report in an appropriate pronouncement issued by APRA or another relevant body.
• We recommend that Prudential Standard SPS 310 Audit and Related Matters (SPS 310) be reviewed in the context of the proposed change to exclude RSE auditors from its application, as the standard appears to continue to set requirements for RSE auditors.
• We recommend that the retirement of Prudential Practice Guide SPG 310 Audit and Related Matters is reconsidered as certain aspects continue to be useful, such as who can conduct the various components of the RSE audit, and where an RSE has wound up or is in the process of being wound up.