AICD submission on APRA remuneration disclosure and reporting obligations

Thursday, 13 October 2022


On 7 October 2022 the AICD provided a submission to APRA's consultation on proposed remuneration disclosure and reporting obligations.

The AICD’s overarching view was that the while improvements in remuneration reporting and disclosure obligations across APRA regulated entities would be welcomed, the proposed requirements run the risk of exacerbating the existing complexity, and limited comparability, of remuneration disclosure practices.

Our key points were:

  1. We recommended APRA reduce the risk of increasing the current complexity of disclosure practices through seeking greater alignment with Corporations Act 2001(Cth) disclosure obligations and limiting where possible qualitative disclosure items.
  2. The proposed reporting requirements will impose significant regulatory costs on entities of all sizes that will outweigh any benefit to APRA’s supervision activities or stakeholder visibility of remuneration practices via APRA statistical publications.
  3. It is not apparent the policy rationale for a number of the elements of the disclosure and reporting regime, for instance the collection of very granular individual information, and how the benefit of collecting, or disclosing, these elements will outweigh the costs on entities.
  4. The commencement timeline for the proposed obligations should be extended to at least 18 months - 2 years for all APRA entities from finalisation or alternatively commencement of the obligations should be staggered across two years.

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