D2A is moving ahead of APRA's December 2027 plan

APRA has brought forward the migration of all remaining D2A collections to APRA Connect. The earlier plan, announced in APRA's 2024-25 Corporate Plan, was to migrate those collections by December 2027. APRA says the timeline has been brought forward because of early decommissioning of D2A client vulnerabilities. APRA's migration support material does not state the revised timetable.

That makes the confirmed change narrower, and more precise, than a new published deadline. The portal migration is moving faster than the earlier plan, but the official material does not identify which collection will move when.

The relevant audience is entities responsible for remaining D2A collections. APRA's material does not identify advice practices, financial advice licensees or service providers as affected categories. Each organisation therefore needs to establish whether it has responsibility for a remaining D2A collection before assuming the change applies to it.

The comfort of unchanged data

The natural assumption is that a portal change should require limited operational work if the information being reported stays the same. The prediction is reasonable: keep preparing the same data, submit it through the replacement portal and continue.

But that is not the whole announcement. The route for submitting the data is changing, and the timetable for moving away from D2A has been brought forward. Unchanged collection requirements therefore do not answer the practical questions for an entity responsible for submitting them.

Those questions are about readiness, rather than a new reporting obligation. Which collection is relevant? Who owns the process? What does the current process produce? How will the entity establish that the replacement process produces the same required result?

What APRA has confirmed

APRA says its plan is to migrate all remaining D2A collections to APRA Connect. The earlier plan, announced in its 2024-25 Corporate Plan, was to complete that migration by December 2027. APRA's current migration material says the timeline has been brought forward because of early decommissioning of D2A client vulnerabilities.

The stated objective is to deliver a single, modern data submission portal and remove the need for industry to maintain the aging D2A client on industry infrastructure. APRA also says it is not changing the collections as part of the migration, with no plans to change their data scope, format, grain or frequency.

Those are the boundaries of the confirmed change. The material does not provide a replacement date for the earlier December 2027 plan. It also does not describe changes to particular entities' access arrangements, vendor workflows, validation points or evidence requirements.

Those matters may still be appropriate for an entity to examine. They should not be treated as changes APRA has announced.

Questions for entities responsible for D2A collections

Is your entity in scope?

Start with the collection, not the organisation's general relationship with APRA. APRA refers to all remaining D2A collections, but the migration page does not list the collections or identify individual types of organisation.

An entity should establish whether it is responsible for a remaining D2A collection, which internal or external parties contribute to the process, and who will coordinate its response to the migration. That is a practical scoping exercise, not a claim that every advice business is affected.

What does the current process actually do?

Document the existing process before attempting to change it. Record how the relevant data is prepared, reviewed, submitted and retained. The purpose is to create a baseline against which the APRA Connect process can be checked.

APRA's material does not prescribe how an entity should allocate those responsibilities. The ownership and documentation questions are controls an entity may choose to apply while preparing for the migration.

What can be tested against the unchanged requirements?

APRA's statement that data scope, format, grain and frequency are not planned to change provides a clear comparison point. An entity can use its existing reporting process to define the expected output, then test whether the replacement submission process supports that output.

That recommendation does not assume that APRA will change validation, file handling or access arrangements. It simply separates what APRA has confirmed from what the entity needs to satisfy itself about before moving processes.

How will the organisation track APRA's instructions?

APRA's migration page outlines the transition plan and provides FAQs, key support materials and links to further information to assist entities through the migration. With the revised timetable not stated there, an entity responsible for a remaining D2A collection should use those materials to track the next confirmed step rather than infer a date from the earlier plan.

The accurate reading of the announcement

The earlier December 2027 plan is no longer the timetable to rely on. APRA says the migration has been brought forward because of early decommissioning of D2A client vulnerabilities, but its support material does not state the replacement date.