APRA's Retirement Reporting Framework: 17 of Our 21 Issues Addressed, and What's Still Open
APRA has just released its response to the March 2026 consultation on the Government's Retirement Reporting Framework, along with updated draft reporting standards and a final round of consultation. Here's a summary of what the Framework involves, the key changes and the areas we're considering raising with APRA on your behalf.
The main takeaway is that APRA is listening to our feedback. Out of the 21 issues we raised with APRA in the March consultation, 17 have already been addressed. In our view, this reflects well on both APRA's willingness to engage and the quality of the feedback we put forward. If the inconsistency in issue 1 below is resolved as expected, that number will rise to 18. The three outstanding issues are minor formatting or structure points, so we don't plan to pursue those further.
This summary reflects our own reading of the released documents. For official confirmation, please get in touch with APRA directly. If you have questions or want to discuss how these changes might affect your team, feel free to reach out to us.
What is the Retirement Reporting Framework?
The Retirement Reporting Framework is a new data collection mandated by the Government and implemented by APRA. It requires RSEs to report new member cohort and product-level data about retirement-phase members, which APRA will use to produce publicly available metrics and indicators on retirement outcomes across the industry.
It introduces a new reporting standard (SRS 611.1, covering retirement-phase member profiles) and amends two existing standards (SRS 607.0, RSE Business Model, and SRS 101.0, the shared definitions standard used across all superannuation reporting).
Consultation history
APRA first consulted on draft versions of these standards in March 2026. On 10 September 2026, APRA released its response to that consultation, along with revised draft standards, and opened a further, final round of consultation. This final consultation closes on Friday 9 October 2026.
Where to find APRA's own information
Consultation page: Implementation of the Government's Retirement Reporting Framework: APRA's proposals
APRA's September 2026 response and final consultation: Retirement Reporting Framework: response to consultation and final consultation
Headline changes since March
SRS 101.0 (the shared definitions standard) has been updated. Notably, the "systemic longevity risk bearer" definition now supports arrangements with more than one risk bearer, and the purchase price reference has been aligned with Services Australia's own reporting requirements.
The added tables in SRF 607.0 (RSE Business Model) restructure the product table into three separate tables depending on how the product is accessed (replacing a single combined table), and a new repeating sub-table now allows multiple third-party providers to be reported against a single product.
SRF 611.1 (the new retirement-member reporting form) has been substantially restructured to reduce complexity: fewer age bands, fewer benefit brackets and a simplified population for members who have exited an RSE (for example, on death, rollover or benefit payment).
Legacy and defined benefit products are temporarily excluded from SRF 611.1 during the current 5-year commutation amnesty. This is the same treatment already applied to SRF 607.0's Table 6.
SRF 611.1 also now excludes members whose only product is insurance-only, and members of unknown age. These were previously reportable using a placeholder value and are now excluded from the collection entirely.
The drawdown rate metric (SRF 611.1 Table 1) is now based on members' actual pension payments, rather than a nominated or selected drawdown rate.
A new draft Reporting Practice Guide and an updated Technical Paper (explaining how the underlying metrics are calculated) have been released alongside the standards.
The timeline has moved: APRA is now targeting release of the final standards in Q4 2026 (previously Q3). The first reporting period (year ending 30 June 2027) is already underway.
All new tables will now be collected annually.
The concept of a "Member" now has a definition (see issue 2 below).
Top issues we see in the current consultation
SRF 611.1 Table 1's instruction for calculating a member's average pension drawdown rate (across multiple accounts) appears to conflict with how APRA's worked example in the Reporting Practice Guide calculates the same figure. These can produce different results, and it isn't clear which method APRA intends to be authoritative.
"Member" is defined separately, in similar but not identical terms, in both SRS 611.1 and SRF 607.0 (Table 7, items 3.1 and 3.2), rather than centrally in the shared definitions standard SRS 101.0. Given the wording doesn't quite match between the two, this looks like a reasonable case for centralising the definition rather than leaving it to drift further.
SRF 607.0 Table 7, item 4.3 uses the provider's name, rather than their ABN, as the unique identifier. This is the reverse of the approach APRA took earlier in the same standard for a similar field. In fairness, ABN can be left blank where a provider doesn't have one, which makes this harder to fix cleanly than it first appears.
SRF 611.1 Table 3, Column 4 (Years Pension Held) doesn't state, in its own instruction, the point in time the duration is measured to, though this is defined elsewhere, in the shared definitions standard.
Timing
The consultation closes on Friday 9 October 2026. With so many changes since March, if you want your views considered, don't assume the current draft standards are final. It's also worth factoring the tight timeline into your planning, with finalisation targeted for Q4 2026 and the first collection due in late 2027.
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