In April 2013, APRA released a discussion paper Basel III disclosure requirements: composition of capital and remuneration and draft Prudential Standard APS 330 Public Disclosure (APS 330) (Background).

APRA has written to ADIs to make it clear that it will finalise APS 330 this month and that it does not propose to change the 30 June 2013 effective date of the disclosure requirements.

Several submissions asked APRA to relax the proposed requirement that an ADI publish its remuneration disclosures concurrent with the publication of its financial statements. It was submitted that remuneration, particularly for non-key management personnel that might be captured under APS 330, was often not finalised prior to the release of financial statements. In view of these submissions, APRA now proposes to allow the publication of remuneration disclosures no later than three months from the release of an ADI’s financial statements.

Unless specifically required by APRA, it is not intended that disclosures under APS 330 would be subject to external audit. APRA only requires that such disclosures are consistent with information that has been subject to review by an external auditor and that is published elsewhere, or has already been supplied to APRA. Consequently, APRA proposes that the relevant prudential disclosures (or link thereto) need not be included in an ADI’s financial statements but can be in an ADI’s directors’ report or other information accompanying an ADI’s financial statements.