APRA Governance Review—Discussion Paper
Submission date: 13 June 2025
This submission has been prepared by members of the following Committees of the Law Council of Australia:
- the Superannuation Committee and the Insurance Committee of the Law Council’s Legal Practice Section; and
- the Corporations Committee and the Financial Services Committee of the Law Council’s Business Law Section
(collectively, the Committees).
Consultation
The Committees thank the Australian Prudential Regulation Authority (APRA) for the opportunity to provide feedback on the Governance Review Discussion Paper, which was released by APRA for public consultation on 6 March 2025.
The Discussion Paper contains eight proposals designed to uplift governance standards and practices for APRA-regulated entities.
This submission sets out our comments on each of the proposals, highlighting areas where we believe the proposals may not achieve APRA’s objectives and offering constructive suggestions for improvement to ensure that any amendments to existing standards are more likely to achieve APRA’s objectives.
In summary, the Committees are supportive of some proposals but are concerned that a number of the proposals would, if implemented in their current form, not result in the desired governance uplifts and instead could result in conflicts with the general law regulating boards of companies and departures from standard board operations and thereby increasing governance risk.
Last Updated on 17/06/2025
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