APRA SDT Phase 2 Industry Pulse Check: More Challenges, More Collaboration
- Team Nuj
- Sep 25
- 5 min read
Updated: Sep 26
When we hosted our Phase 2 pulse check sessions, over 70 professionals joined us. However, when we asked who wanted to share their experiences, the room went quiet.
That silence spoke volumes.
It wasn't indifference. Looking at the word cloud from our anonymous poll, the story was clear: "Overwhelmed" dominated the screen, surrounded by "Nervous," "Frustrated," "Apprehensive," and "Concerned." This is an industry feeling the pressure of Phase 2, but perhaps too cautious to voice concerns publicly in a mixed forum of funds, administrators, custodians, and service providers.
The Confidence Gap
The numbers paint a sobering picture. When asked about confidence in avoiding material resubmissions, not a single participant selected "very confident." The average rating was 3.1 out of 5, with most respondents selecting a neutral option.
This isn't about capability; the professionals attending ranged from CFOs to data analysts, from fund accountants to heads of regulatory reporting. This is about uncertainty in the face of unclear requirements and shifting technical standards.
Where Time Disappears
When we asked participants to identify their top 1-3 time consumers, our polls revealed where the real struggle lies:
74% are spending significant time sourcing the required data
As one participant explained: "It's the obscure information we have to go and collect... the interactions we've got to keep having with different people and service providers just trying to get one bit of information from you and five bits from someone else."
Wilson from Nuj specifically highlighted that Phase 2 data is "typically sourced from multiple systems," creating "significant challenges around collaboration between those putting the data together and those responsible for the form construction."
71% trying to understand what's actually being requested
The understanding challenge is compounded by APRA's limited support. As participants noted, only two APRA contacts are handling industry queries, with response times exceeding two weeks. When you're trying to interpret complex requirements and your clarification questions take weeks to answer, the entire implementation timeline gets compressed.
These aren't sequential problems; they're interconnected. As the data sourcing challenges reveal interpretation gaps, teams find themselves simultaneously chasing obscure information whilst seeking clarification on requirements, creating the 'constant bag of worms' effect one participant described.
This challenge is particularly acute with liquidity reporting (SRS 551.0), which emerged as the primary pain point for 72% of participants, requiring data that many funds simply don't collect in normal operations.
Technical Hurdles Adding to the Load
The technical challenges discussed highlighted the significant uncertainty that exists at the operational level. Gordon from our team explained the "key versus label" confusion that's become a daily headache. Phase 2's machine-readable formats remove spaces and punctuation from submission keys, but apply this inconsistently across forms. So whilst the standard shows "Not Applicable", the submission key must be "NotApplicable". The confusion runs deeper: forms now mix Phase 1 standards (where keys match labels exactly) with Phase 2's new format, making it unclear which format applies where.
Gordon also noted APRA's August taxonomy update lacked transparency: "They don't really showcase exactly what the changes are in their change logs." The industry is discovering modifications through trial and error rather than clear documentation.
These aren't trivial administrative details; they're the kind of fundamental uncertainties that leave compliance teams questioning whether they're setting themselves up for resubmission requests.
The Ecosystem Has Shifted
Phase 2 has completely restructured how the industry collaborates. Where administrators were the primary contributors in Phase 1, 76% of participants now identify custodians as their most significant ecosystem contributor. This fundamental shift creates new dependencies and communication challenges.
Platform providers managing thousands of investments face particular challenges, as they rely heavily on third-party providers like Morningstar and Clearstream for data that may not align with APRA's requirements.
APRA Support: A Marked Decrease
The contrast with Phase 1 is stark. Throughout Phase 1, APRA provided substantial regulatory support that was unusually comprehensive compared to typical banking reporting implementations, acknowledging the unique data complexity challenges in superannuation with its product variations and investment structures.
Nuj CEO Matthew observed that there was "a lot more interaction from APRA with FAQs and worked examples" in Phase 1, whereas now "it sort of feels like that is a little thin on the ground." The industry forums and co-design approach during Phase 1 specifically addressed the "how to report" challenges that are fundamental to the complexity of superannuation.
With only two APRA contacts now responding to queries and response times exceeding two weeks, APRA may be deliberately moving away from this intensive support model as the reporting framework matures. Whether this shift reflects confidence in the industry's growing capability or simply resource constraints, the industry is largely navigating Phase 2 with significantly less guidance.
Finding Light in the Tunnel
Despite the challenges, something positive emerged. When asked what's working well, participants identified "strengthening collaboration" as the top response, a natural evolution as the industry adapts to this new reality. Super industry unity is emerging from shared challenges, and engagement with custodians is improving.
The 4.1 out of 5 session value rating tells us that even those who didn't speak found value in listening, in knowing they're not alone in their struggles. Much of the detailed dialogue took place in smaller, private conversations afterwards, a natural dual-layer engagement when professionals are processing complex new standards while maintaining commercial boundaries.
Moving Forward Together
At Nuj, we're on this journey with you. We feel the pressure, we understand the frustration, and we're committed to being the collective voice for the industry. The questions raised have been compiled and sent to APRA on behalf of all participants, including critical clarifications about Form 251.4 submission processes, validation rules, and the purpose behind granular liquidity data requirements.
Our goal isn't just to highlight problems. It's to unify the industry voice, provide clear benchmarking, and continuously improve our platform to reduce compliance risk. Less stress, less overwhelm, more clarity.
What This Means
The data tells the real story. Zero participants felt highly confident about avoiding resubmissions. Three-quarters are consumed by sourcing and understanding data requirements. Yet when asked what's working, "strengthening collaboration" topped the list.
Resubmissions are now the norm, not a failure. The December deadline approaches with "best endeavours", the exact phrase we heard in Phase 1, but this is no longer a temporary concession. It's APRA's operating model: submit, review, refine, repeat. While executives and boards may still view resubmissions as indicative of poor performance, they're simply part of this iterative process until the industry develops a better understanding and collaboration around Phase 2 requirements.
The reluctance to speak up during our sessions reveals something important: many are still finding their way through Phase 2 requirements in a commercially sensitive environment. That's not weakness, it's the reality of implementing complex changes with limited guidance whilst maintaining competitive boundaries.
The path forward requires continued collaboration. Whether you're vocal or quietly listening, your participation matters. Every question raised, every challenge shared, helps build the collective understanding we all need. As we develop this collective expertise, we'll gradually move toward a point where resubmissions do reflect poor preparation, but we're not there yet. Looking ahead, we'll offer both mixed forums and focused group sessions to facilitate different levels of engagement.
Phase 2 is challenging, and the feedback reflects that. What's encouraging is seeing the industry work together more than before.
Thank you to everyone who attended our pulse check sessions. Your presence, whether speaking or listening, makes a significant contribution to our collective progress. The Nuj team will share APRA's responses to our aggregated questions with all participants.