APRA’s new remuneration reporting requirements are now a reality for APRA regulated entities. APRA-regulated entities with a financial year ending on or after 31 December 2024, will be required to publish their first disclosure within six months of the end of that financial year.
The CPS 511 disclosure requirements require entities to make detailed public disclosures in respect of their remuneration framework and practices, with such disclosures to be clear, comprehensive, meaningful, consistent and comparable.
The disclosure requirements replace the previous remuneration disclosure requirements under APS 330, but operate alongside other remuneration disclosure regimes, including under s300A of the Corporations Act 2001 (Cth) for listed companies and remuneration disclosure and targets disclosures under the Workplace Gender Equality Act 2012 (Cth).
CPS 511 – overview of the disclosure requirements
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Requirement
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INDIVIDUAL
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Example
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When does it start?
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The disclosure requirements apply to an entity’s first full financial year commencing on or after 1 January 2024. Entities must report within 6 months of the end of their financial year. |
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Who is in scope?
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APRA regulated banks, insurers, and superannuation entities, including both Significant Financial Institutions (SFIs) and non-SFIs. Disclosure obligations for non-SFIs are less onerous than SFI disclosure obligations, noting that SFIs are required to disclose (among other things) detailed quantitative information for the CEO, senior managers and material risk-takers. |
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Disclosures required
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Remuneration framework – this includes qualitative descriptions of the positions caught by ‘specified role’ designations, how variable remuneration is structured, how awards of variable remuneration align to performance and risk outcomes, how the entity defers and adjusts variable remunerations. Disclosures relevant to the remuneration framework apply to SFIs and non-SFIs. Variable remuneration outcomes – quantitative information regarding remuneration outcomes and variable remuneration awards for the financial year, including variable remuneration paid/vests, deferred, and downwardly adjusted. Entities must also disclose the reasons for downward adjustment. This obligation applies only to SFIs. Special awards – quantitative information regarding guaranteed bonuses, sign-on awards, and termination awards made to persons in specified roles. This obligation applies only to SFIs. |
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Public disclosure requirement
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Disclosures must be made by entities on their website or as part of other disclosures (for example, in an annual report). |
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These requirements have been covered in more detail in our previous articles: Show me the Money! Remuneration disclosure under CPS 511 and Navigating Australia’s Remuneration Disclosure Rules in 2025.
The quantitative disclosure requirements are particularly onerous and will require collection of a range of remuneration data and the publication of details of remuneration adjustments (although collective) represents a significant increase in transparency in this area.
Next steps
The disclosure requirements under CPS 511 are detailed and onerous, and from a practical perspective, will require significant time to prepare and collate, comparable to the process already undertaken by listed entities for remuneration disclosures under the Corporations Act 2001 (Cth).
Companies should also expect that the information disclosed will be the subject of regulatory, media, public and government attention, and for such information to be used and scrutinised for a variety of purposes, including benchmarking and comparison of remuneration adjustments and outcomes.
The disclosures are also likely to be of significant public interest where companies have suffered risk and compliance events, with potential for there to be focus and debate as to whether the remuneration adjustments applied are proportionate to the severity of the risk and conduct outcomes.
We have been assisting several financial institutions with preparation of their disclosures under the regime and would welcome the opportunity to support you with these new reporting requirements.
