Our joint submission with CPA Australia concurs that assurance can be a valuable and cost-effective way of improving integrity for financial consumers, but we point out some practical considerations and transitional requirements.

We note that the impact on the assurance work required is potentially significant for some registrable superannuation entities (RSEs) and we highlight the resource constraints that the profession is currently experiencing. We urge APRA to give auditors, and RSEs, adequate time to fully prepare for the increased scope of work and we recommend the effective date deferred for at least a year.

We also recommend APRA conducts a post-implementation review of these changes after they have been in place for two years. Such an exercise would enable APRA to determine whether these changes are meeting the policy objectives in the most cost-effective way and identify any practical implementation issues around the auditability of the data in the new reporting forms.