APRA APS 330 Public Disclosure: Pillar 3 reporting for ADIs

What APS 330 is

APS 330 is the Australian prudential standard that requires authorised deposit-taking institutions (ADIs) — banks, building societies and credit unions — to publicly disclose key prudential information about their capital, liquidity and risk. It is APRA's implementation of "Pillar 3" of the Basel capital framework, the market-discipline pillar that sits alongside minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2). The purpose is to give depositors, investors and analysts a consistent, comparable view of an ADI's financial resilience.

The standard is administered by the Australian Prudential Regulation Authority (APRA) and is published on the APRA website. The current version of APS 330 commenced on 1 January 2025 and aligns Australia's disclosure regime with the Basel Committee on Banking Supervision (BCBS) revised Pillar 3 framework.

If you are searching for "APS 330", you are almost certainly trying to work out one of three things: whether it applies to your institution, what you have to publish, and when. This explainer covers each in turn. It sits within the broader financial services regulatory framework.

Who APS 330 applies to

Under the version that commenced on 1 January 2025, the disclosure obligations apply to ADIs that are locally-incorporated significant financial institutions (SFIs).

In broad terms:

• Locally-incorporated SFI ADIs — typically the larger banks — carry the full disclosure burden under the standard.
• Non-SFI ADIs (smaller banks, mutuals and credit unions) are excluded from APS 330.
• Foreign ADIs (branches of overseas banks) and purchased payment facility providers are also excluded.
• APRA may determine in a particular case that the standard applies to a foreign ADI or a non-SFI.

Whether an ADI is an SFI is determined under APRA's prudential framework, and APRA publishes a list of significant financial institutions. Because the line between SFI and non-SFI determines your entire obligation, check your institution's classification against APRA's current list.

What must be disclosed

APS 330 requires an ADI to make disclosures that are clear, comprehensive, meaningful, consistent and comparable, so as to contribute to the transparency of financial markets and enhance market discipline. The substance follows the BCBS Pillar 3 disclosure templates, adjusted by APRA for the Australian context.

The disclosures cover an ADI's risk profile and financial resilience across areas including:

• Regulatory capital — composition of capital, capital ratios and the reconciliation to the balance sheet.
• Key prudential metrics — a summary of an ADI's main capital, leverage and liquidity figures.
• Leverage ratio — the non-risk-based capital backstop.
• Liquidity — including liquidity coverage and net stable funding measures, where applicable.
• Credit risk and counterparty credit risk.
• Securitisation exposures.
• Market risk and interest rate risk in the banking book.
• Operational risk.
• Macroprudential / capital-buffer indicators.

The standard works hand-in-hand with the rest of APRA's capital framework — the disclosed figures are derived from the same definitions used for capital adequacy and liquidity reporting. The disclosures should therefore be consistent with an ADI's regulatory returns and financial statements; APS 330 also requires information on the links between financial statements and regulatory exposures.

Disclosure frequency, timing and format

Disclosure frequency under APS 330 is not uniform — it tracks the underlying BCBS templates, which are variously quarterly, semi-annual or annual depending on the metric. Capital and leverage summaries are typically more frequent; some narrative and detailed credit-risk tables are annual.

Key timing and format expectations:

• Concurrent publication — the prudential disclosures must be published concurrently with the lodgement of the ADI's financial reports under the Corporations Act.
• Dedicated location — an ADI must include an easily identifiable "Regulatory Disclosures" section on its website and publish all required disclosures there in a standalone document.
• Machine-readable data — all quantitative information must also be disclosed in a CSV file, Microsoft Excel file or other APRA-approved format, made available in the same section.

Because exact frequencies attach to individual templates, check the relevant template requirements in the APS 330 standard rather than applying a single blanket deadline.

Governance, attestation and archives

APS 330 adds several governance requirements on top of the BCBS templates:

• Disclosure policy. An ADI must have a formal, Board-approved policy on its prudential disclosures, and summarise its key elements in the year-end disclosure.
• Attestation. An Accountable Person of the ADI (as defined in the Banking Act) must attest in writing that the disclosures have been prepared in accordance with the disclosure policy, and the attestation must be included in the disclosure.
• Archive. An ADI must keep an archive of prudential disclosures for at least the 12 months before the most recent publication in its "Regulatory Disclosures" section.
• Audit. APRA may require an ADI to commission an independent audit of its prudential disclosures, for example where it believes information disclosed is incorrect or misleading.

APRA's ADI public disclosure consultation page sets out the background to the current standard.

What ADIs should do

A practical compliance path for an in-scope ADI:

1. Confirm scope. Establish whether your ADI is a locally-incorporated SFI, and therefore subject to the standard, or whether APRA has determined that it applies to you.
2. Map the templates. Identify every BCBS/APRA disclosure template that applies to you and its frequency (quarterly, semi-annual or annual).
3. Build the data lineage. Ensure the figures trace directly to your regulatory returns and audited accounts so disclosures reconcile and cannot diverge.
4. Set the calendar. Align each disclosure to the lodgement of the relevant financial report and build internal sign-off time before publication.
5. Document governance. Maintain a Board-approved disclosure policy, obtain the Accountable Person attestation, and keep at least 12 months of prior disclosures archived.
6. Publish accessibly. Provide both readable and machine-readable formats in a clearly labelled regulatory disclosures section.

Common pitfalls

• Assuming the old regime still applies. The standard changed materially from 1 January 2025; disclosure suites built for the previous version may over- or under-disclose. Re-map against the current standard.
• Treating APS 330 as a separate calculation. Disclosed numbers should be consistent with regulatory reporting and financial statements. Divergence is a red flag for both auditors and APRA.
• Misjudging SFI status. Getting the SFI classification wrong leads either to unnecessary effort or to a genuine compliance gap. Confirm it with APRA.
• Late or non-concurrent publication. Publishing disclosures well after the related financial report undermines the market-discipline purpose and can breach timing expectations.
• Neglecting machine-readable data. Publishing only a PDF narrative when structured data is required is a frequent and easily avoided failure.
• Relying on out-of-date figures. Frequencies and templates can change. Where you are unsure of a specific requirement, verify the current position with APRA before publishing.

APS 330 is ultimately about transparency: giving the market a reliable, comparable window into an ADI's capital and risk. For in-scope institutions, the work is less about new calculations and more about disciplined mapping, reconciliation and timely publication.