CLARIFICATION: REQUIREMENTS FOR FINANCIAL STATEMENTS OF
SMALL APRA FUNDS (SAFs)
APRA has recognised that, following the transfer of the regulation of self-managed
superannuation funds to the Australian Taxation Office, there may be some SAFs that
can, in the professional judgement of the auditor, appropriately be classified as non-
In February 2001 APRA announced that APRA will continue to rely on the audit
profession to ensure that SAFs are given the appropriate reporting definition. This
position was advised in Addendum to APRA Superannuation Circular IV.A.4 "Responsibilities of
the Approved Auditor".
SAFs are APRA regulated superannuation funds with fewer than 5 members who may
or may not be related. The trustee of the fund must be an independent corporate
trustee approved by APRA under Part 2 of the Superannuation Industry (Supervision)
Act 1993 (SIS).
In December 2000 APRA had issued APRA Superannuation Circular III.E.1 "Regulation of
Small APRA Funds". Paragraph 17 of that Circular set out the requirements under the
SIS legislation in respect of preparation and audit of financial statements for SAFs.
In particular, it stated that "SAFs are reporting entities for the purpose of preparation
of financial statements and audit requirements." This position had been based on the
premise that, as trustees of SAFs are now at arms-length from the members, there was
a case for more detailed formal reporting to the members. Whilst this will be the
general position, as noted above, it is now recognised that there there may be some
SAFs that can be appropriately treated as non-reporting entities.
Set out below is a summary of financial reporting requirements for SAFs for the year
of income ended June 30, 2001.
Reporting entities - AAS25 applies in full.
Non-reporting entities - the approved auditor has the discretion as to whether to
apply AAS25 in full. Where members of a SAF have access to or are able to
command the disclosure of the information they require, the SAF would not