What We Learned When Funds Shared Honestly About APRA SDT Phase 2

The regulatory reporting landscape for superannuation has never been more complex. With SDT Phase 2 submissions approaching the critical 15 December deadline, Nuj recently hosted a series of private, one-to-one sessions with funds, administrators, and trustees to discuss their most pressing challenges.

What emerged from these conversations was striking: whilst every organisation faces unique operational circumstances, the themes of confusion, resource pressure, and desire for clarity were remarkably consistent. More importantly, we heard a strong appetite for collaboration, albeit tempered by an understandable reluctance to acknowledge struggle publicly.

The Paradox of Competitive Compliance

One participant captured the sentiment perfectly: APRA reporting isn't a point of differentiation; it's a fundamental requirement. Yet the industry still operates in silos, each fund, administrator, and trustee navigating the same regulatory maze independently.

As another attendee noted, "Why are people not talking about this more?" It's a valid question. When faced with identical reporting obligations, collective problem-solving becomes not just efficient, but essential.

The Technical Hurdles Everyone's Facing

The Forms SRS551.0 Liquidity & SRS553.0 Investment Exposure Concentrations and Valuations Challenge. 

If there was a single issue that united every conversation, it was Forms SRS551.0 and SRS553.0 . The complexity isn't just technical, it's organisational. These forms require detailed liquidity profiling for non-traded assets, significant data manipulation, and input from investment operations, finance, products, and strategy teams.

The coordination bottleneck is real. "What we're struggling with is so many different teams needed for this particular form, and we really want to use Nuj to, basically, build the tables from the different teams," shared one representative. Organisations often find themselves constrained by sequential workflows where only one person can work on the form at a time, creating a "ping pong" effect as forms bounce between stakeholders.

"We're waiting on one person to do 1 table, when there are so many other tables that need to be done too," noted another organisation, capturing the frustration of workflow constraints that don't match the collaborative reality of how these forms need to be built.

The scale of effort is substantial. One administrator estimated spending 250 hours preparing the SRS 332.0 Expense reporting form alone, a figure that underscores both the granularity of APRA's requirements and the resource intensity of compliance.

The interest in tools that could facilitate simultaneous multi-team contribution was evident across sessions. It's precisely this challenge, forms that need multiple experts but can only be updated by one person at a time, that drove us to build Form Builder's collaborative workflow capabilities. When four teams need to contribute to one form, the workflow itself can't be the bottleneck.

The interest in tools that could facilitate simultaneous multi-team contribution was evident across sessions, a clear signal that the industry is seeking better ways to manage the inherent complexity of cross-functional reporting requirements.

Beyond workflows, many organisations struggled with understanding how the forms relate to each other.

Cross-Form Validation and the Circular Dependency Problem

Uncertainty about which forms should reconcile with each other emerged as a recurring concern. The relationship between Form 332.1 and other reporting obligations has proven particularly confusing, with some discovering that service provider identifiers needed for Phase 2 should reference back to Phase 1 data, but Phase 1 submissions have already been lodged.

"There's something called a service provider identifier that is referenced back to 332.0, so it needs to be first set up in 332.0 for the 332.1 to work," explained one team. The subsequent challenge: "So there are many service provider identifiers that are not relevant to 332.0. It needs to be defined as part of 332.1."

This circular dependency highlights a fundamental tension in the reporting framework, one that APRA will need to address for future reporting periods. Understanding these dependencies is precisely why our platform flags cross-form inconsistencies before lodgement, catching circular dependency issues that might otherwise surface as APRA rejections.

Version Control, What's Actually Changed?

As reporting standards evolve, organisations struggle to identify what's genuinely changed between versions. "I'm thinking, what's actually changed? I don't know if anything's actually changed in those two tables," remarked one participant, expressing frustration that's particularly acute for those managing multiple fund acquisitions or complex corporate structures. The uncertainty makes planning harder, especially for organisations dealing with multiple entities or recent acquisitions. Which is why we're prioritising taxonomy change notifications, so users can see exactly what's changed between reporting periods before they start preparing their submissions. 

The Dependency Chain: When Third Parties Become Blockers

Third-party data providers, including custodians, frequently delay organisations' ability to complete their own forms, creating a cascade effect where tight deadlines become impossible. This is particularly challenging for funds that have recently acquired other entities and are still integrating data models and custodian data feeds.

The Resource Reality

Larger organisations tend to have dedicated APRA reporting specialists. Smaller funds, platforms, and some administrators, however, are navigating these requirements without specialised resources, relying instead on generalist finance and compliance teams who are simultaneously managing multiple other priorities.

The Post-Lodgement Validation Approach

A repeated pattern began to emerge, with several participants sharing that they conduct detailed validations and quality improvements after submission, rather than before. The time pressures and complexity of Phase 2 mean that lodging files by the deadline takes priority, with refinement and error correction occurring in subsequent quarters.

This post-lodgement refinement approach, whilst pragmatic given the circumstances, underscores the pressure the industry is operating under and the iterative reality of Phase 2 compliance.

It's also a natural part of the learning curve. When teams first joined the platform, working on SDT Phase 1, the focus was on meeting deadlines; lodging returns first and refining them later. But as they integrated validations and the cross-fund insights of Nudges into their workflow, the approach shifted. Those teams now see fewer rejections, faster sign-offs, and stronger collaboration.

The post-lodgement approach isn't ideal, but it's proving temporary. Phase 2's increased complexity and expanded collaboration requirements have created a temporary step back, but the foundation is in place. As teams mature their validation workflows and tools like Form Builder enable better pre-lodgement coordination, they're shifting from reactive correction to proactive quality assurance.

APRA Communication and the Guidance Gap

If there was one issue that came up more than any other, it was APRA's communication. Or, more accurately, the lack of useful communication.

"They didn't answer the question. They just sent us the regs and said figure it out," one participant said, and that frustration echoed through multiple conversations.

The guidance exists, but it's high-level. The practical, operational details that would help teams are missing. And when funds reach out for clarification, they're often met with slow responses or answers that don't quite address what they're actually asking. Teams want clear examples, not just principle-based instructions.

The Square Peg, Round Hole Problem

"They've given us a square peg to fit into a round hole, and that's becoming pretty apparent when we're trying to resolve some of these requirements in the reports," articulated one participant.

Reporting forms designed for traditional retail and industry funds don't map neatly to platforms, master trusts, or other fund structures. One trustee noted the reporting framework answers questions relevant to "an annual review kind of thing, not something that I'd look at every day and use to do the oversight of the data itself"—highlighting a disconnect between what APRA requests and what trustees actually need for effective governance.

The Trustee Oversight Mismatch

"They're not answering a question that I'm even asking. They're answering a question that potentially the relationship manager might be interested in for an annual review kind of thing, not something that I'd look at every day and use to do the oversight of the data itself," noted one trustee.

The reporting requirements are designed with specific governance and oversight models in mind; however, the actual operational needs of trustees have evolved, creating a mismatch between what the system captures and what trustees need to exercise effective oversight.

What's Working

Even with the pressure and uncertainty, there were strong examples of what's working well across the industry.

Platform Validation Catching Real Errors

Participants consistently praised Nuj's validation errors, noting that the platform catches issues across multiple touchpoints, particularly valuable for large organisations where different people complete different forms.

The Nuj quarter-on-quarter comparison feature proved particularly valuable. One organisation team was preparing their September quarter submission when they used the Nuj comparison tool to check their data against the previous quarter. Something didn't look right, a variance that didn't match their expectations. They investigated and discovered what they described as a "pretty large error" that would have made it through to formal lodgement if they hadn't caught it. The feature has since become an essential part of their pre-submission process, they said, "It's now a good go-to one."

Another fund noted how the validation errors help them understand not just that something's wrong, but why it's wrong. "The platform catches anomalies from large organisations where different people complete different forms, and helps administrators complete forms correctly rather than just ticking the box and moving on." This is particularly important when multiple team members work on different sections, as the validation layer catches inconsistencies that might otherwise slip through.

Workflow Visibility for Complex Coordination

For organisations navigating multi-team coordination, the ability to see where different stakeholders are in the process proved "really valuable." One organisation described how they use the Workflow Manager's visibility to manage the exact challenge we heard repeatedly: forms that require input from multiple teams but create bottlenecks when only one person can work on them at a time.

Understanding which teams have completed their sections, what remains outstanding, and where the bottlenecks lie helps project managers maintain oversight of complex, cross-functional reporting requirements. 

It's not solving the fundamental workflow challenge, which requires collaborative form-building capabilities, but it at least makes the bottleneck visible and manageable.

The Power of Collective Knowledge

"When one fund raises an issue to APRA or they get questions from APRA, we add that answer to our platform so that others benefit instantly," explained Caroline Jarvie from Nuj

.

This collective knowledge approach means that when one organisation discovers a circular dependency issue between Form 332.0 and 332.1, we can flag it for everyone else. When one fund receives clarity from APRA on the liquidity profiling methodology, that guidance is embedded in our Nudges, so the next 32 funds don't have to ask the same question.

One participant captured the sentiment: "It's been reassuring to hear that we're dealing with the same issues as the rest of the industry and very helpful."

The value isn't just emotional reassurance; it's practical. With 33 funds, administrators, and trustees sharing their learnings through the platform, everyone benefits from collective problem-solving without having to publicly expose their individual challenges.

Key Questions That Need Addressing

These sessions weren't just listening exercises. They've directly informed our platform development priorities and highlighted the questions the industry needs answered:

• Form SRS551.0 vs SRS553.0 methodology: What's the expected approach for determining liquidity profiles for non-traded assets like bonds?

• Cross-form validation clarity: Which forms should reconcile with each other, and what's the expected tolerance for variance?

• Service provider identifier structure: How should organisations handle SDT Phase 2 identifiers that reference SDT Phase 1 data that's already been submitted?

• Platform fund structure recognition: Can APRA provide guidance that acknowledges the operational differences between traditional funds and platform structures?

• Trustee oversight requirements: How can reporting better align with trustees' day-to-day governance needs rather than just periodic review requirements?

Some of these questions require fund-specific context to answer meaningfully, but they represent the clarity gap the industry is facing. Where we can raise them constructively with APRA, we will.

The Collective Knowledge Advantage

Every issue raised by a fund, administrator, or trustee, every shared question posed to APRA, and every interpretation challenge is learned from and embedded into the platform through our validation Taxonomy Warnings, Taxonomy Errors and Nuj Nudges, benefiting all users instantly.

This is the fundamental value of the collective approach. As one participant observed, APRA reporting isn't a competitive differentiator; it's a regulatory obligation. The power lies in solving it together.

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An Invitation

If you didn't participate in this round of sessions but recognise these challenges in your own organisation, we'd welcome your voice in future conversations. Whether you're a fund, administrator, or trustee, the collective knowledge grows stronger with each perspective added.

For those who did attend: thank you for your candour and collaboration. We've noticed that several of you have started engaging differently with our support team post-session, more directly, more collaboratively, and more willing to flag issues early. That's precisely the partnership approach that makes regulatory reporting more manageable.

The 15 December deadline is approaching. The challenges are substantial. However, as administrators, trustees, and funds collectively navigate SDT Phase 2, there's value in knowing you're not alone and that the insights from your experience are helping others behind you.

We're in this together. And sometimes, that's the most powerful tool we have.

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Want to discuss your specific APRA SDT Phase 2 challenges or learn how Nuj's Form Builder or cross-fund insights could support your next submission? Contact our team for a confidential conversation.