Registrable superannuation entities to prepare remuneration reports for 30 June 2024

Registrable superannuation entities to prepare remuneration reports for 30 June 2024

For years ending 30 June 2024, registrable superannuation entities (RSEs) must prepare, audit, and lodge financial statements with the Australian Securities and Investments Commission (ASIC) in the same way as companies, registered schemes and disclosing entities reporting under Chapter 2M of the Corporations Act 2001.

These new financial reporting obligations for RSEs are similar, but distinct from those in place for listed companies. While RSEs must present a remuneration report and disclosures about non-audit fees, they are not required to prepare half-year financial reports.

The Chapter 2M reporting requirements are in addition to an RSE’s existing obligations to submit quarterly returns to APRA, prepare annual financial statements, have them audited, and lodge them with APRA within three months of the reporting date (i.e. 30 September for the vast majority of the population).

This article considers in more detail what information RSEs have to provide in remuneration reports for years ending on 30 June 2024 and beyond under Chapter 2M of the Corporations Act 2001.

What is an RSE?

For Chapter 2M of the Corporations Act 2001, RSEs include:

  • Regulated superannuation funds
  • Approved deposit funds and
  • Pooled superannuation trusts.

Self-managed superannuation funds, exempt public sector superannuation schemes, excluded approved deposit funds and small APRA funds are not RSEs for Chapter 2M reporting purposes. Therefore, the new, more onerous reporting obligations will not apply to them.

Where to find?

It is important to note that the disclosures required for an RSE’s remuneration report are similar but distinct from those applicable to listed companies. The new remuneration report requirements for RSEs are in section 300C of the Corporations Act 2001 and Regulation 2M.3.04. The corresponding requirements applicable to listed companies can be found in section 300A and Regulation 2M.3.03.

Section 300C

The remuneration report of an RSE must be presented as part of the directors’ report in a separate and clearly identified section called ‘Remuneration Report’, and must include the prescribed details regarding the remuneration of each member of the RSE’s key management personnel (KMP) (these are contained in Regulation 2M.3.04).

Regulation 2M.3.04

Although worded differently, the prescribed details in Regulation 2M.3.04 are consistent with the corresponding requirements applicable to listed companies to the extent that both require the following disclosure for each KMP:

  • Name of KMP
  • The date they began holding a KMP position if they became a KMP during the financial year
  • The date they retired from a KMP position if this occurred during the financial year
  • The date they changed from one KMP position to another if this occurred during the financial year
  • Details of remuneration for the financial year, including short-term employee benefits, post-employment benefits, long-term employee benefits, termination benefits and share-based payments
  • Details of cash bonuses, performance-related bonuses or share-based payment compensation paid or receivable for the financial year
  • Details of any in-force service contracts
  • Alterations to any in-force share-based payment arrangements (including options or rights) during the financial year
  • Details of any options or rights over equity instruments provided as compensation during the financial year, and
  • Details of any equity instruments issued due to the KMP exercising options or rights previously granted as compensation during the financial year.

If an amount attributable to a KMP of the RSE is paid to an organisation or entity rather than to the KMP, the remuneration report must disclose the amount paid and the name of the organisation or entity.

Payments, benefits or compensation received by KMPs from RSE-related parties for work performed for the RSE are treated as if they were given to the KMPs by the RSE.

The details of an RSE’s remuneration report disclosures are to be determined in accordance with the requirements of any applicable Australian Accounting Standards.

The following disclosures apply to listed companies but are not required for RSEs:

  • Reconciliations of KMP options and rights holdings during the financial year
  • Reconciliations of KMP equity instrument holdings during the financial year, and
  • Loans to KMPs.

Please refer to Regulation 2M.3.04 for the precise disclosure requirements.

More information

Please refer to our previous article for more information about the additional contents of the financial report, including the directors’ report and the auditor’s independence declaration.

Need help?

Please contact our IFRS & Corporate Reporting team if you require assistance with your new RSE financial reporting obligations.