Proposed changes to governance
Submission Date: 1 September 2026
The Law Council of Australia provided a submission to provide input to the consultation by the Australian Prudential Regulation Authority (APRA) on Draft Prudential Standard CPS 510 (draft CPS 510). This submission reflects input from the Superannuation Committee of the Law Council’s Legal Practice Section and the Corporations Committee and Financial Services Committee of the Law Council’s Business Law Section.
APRA is inviting feedback on the draft CPS 510, the proposed removal of routine fit and proper reporting, and related definitional changes in Prudential Standard CPS 001 Defined terms
This submission commences with preliminary observations before providing detailed commentary on specific issues raised by draft CPS 510.
The Law Council looks forward to continuing to engage with APRA on these important governance reforms.
Preliminary observations
The Law Council acknowledges APRA’s engagement with industry during the consultation process and recognises that APRA has, in a number of respects, fairly responded to industry feedback. However, as set out below, the Law Council has significant residual concerns, which it urges APRA to address before the standard is finalised.
The Law Council is broadly supportive of the objectives of draft CPS 510 and its underlying policy intent. However, the Law Council holds serious concerns—several of which are fundamental—with the draft standard as presently formulated. These concerns relate to legal certainty, practical operability, jurisdictional scope, and the risk of unnecessary duplication with existing regulatory frameworks, including the Financial Accountability Regime.
Last Updated on 01/09/2026
Share
Tags
Most recent items
Trending Items
Law Council
National Public Register of Child Sex Offenders
Business Law Section