Annual Prudential Compliance Statement (APCS)
The Annual Prudential Compliance Statement is a mandatory annual declaration that approved residential aged care providers submit to confirm their compliance with Australia's Prudential Standards. It gives regulators confidence that a provider has maintained the financial safeguards needed to protect residents' deposits throughout the reporting period.
For any aged care organisation that holds refundable deposits, the APCS is one of the most consequential financial reporting obligations of the year.
Quick Definition
The APCS is a formal compliance statement submitted annually by eligible aged care providers. It confirms that they meet the four Prudential Standards set out under the aged care legislative framework. The statement is submitted as part of the Aged Care Financial Report (ACFR) and must be accompanied by an independent external audit opinion before lodgement.
Key Facts at a Glance
- Required for all approved providers who held a Refundable Accommodation Deposit (RAD) or bond balance at any point during the reporting period
- Submitted through the online provider portal as part of the Aged Care Financial Report (ACFR)
- Due four months after the end of the provider's financial year — 31 October for providers with a 30 June year-end
- Must be externally audited before lodgement
- From the 2025–26 financial year, all residential providers must also submit an externally audited Care Minutes Performance Statement
Why the APCS Exists
When older Australians enter residential care, many pay a Refundable Accommodation Deposit, a significant lump sum that must be returned in full when they leave or pass away. The Prudential Standards, and the APCS that reports on them, exist so providers can always honour that obligation.
The APCS is overseen by the Aged Care Quality and Safety Commission (ACQSC), which uses submitted data to monitor financial risk across the sector. Providers who held no refundable deposits during the year are generally not required to submit, but should confirm this with their external auditor before deciding not to lodge.
Who Must Submit an APCS?
Any approved provider who held a refundable deposit or bond balance at any point during the reporting period must submit an APCS. This includes:
- Residential aged care providers operating standalone or multi-purpose facilities
- Providers who held RADs or bonds even briefly during the year
- Providers whose operations spanned both the Aged Care Act 1997 and the Aged Care Act 2024
The Four Prudential Standards
The APCS confirms a provider's compliance across four Prudential Standards:
1. Liquidity Standard
Providers must hold sufficient liquid assets to refund all RAD and bond balances as required, including at short notice. This is the standard most directly protecting residents' deposited funds. The ACQSC monitors whether providers are managing their liquidity position appropriately relative to their outstanding deposit obligations.
2. Disclosure Standard
Providers must make certain financial and operational information available to current and prospective residents. This covers pricing, financial health indicators, and complaint mechanisms. The APCS documents compliance with these disclosure requirements.
3. Capital Expenditure Standard
This standard requires providers to manage and report on significant capital investments. It confirms that major spending decisions are not putting the provider's ability to meet resident obligations at risk.
4. Record-Keeping Standard
Providers must maintain accurate, accessible records of all financial transactions relating to refundable deposits, accommodation payments, and associated obligations.
Submission Timeline
| Milestone | Timing (30 June year-end providers) |
|---|---|
| Financial year ends | 30 June |
| External audit completed | Prior to lodgement |
| APCS lodgement deadline | 31 October |
| Care Minutes Performance Statement (from 2025–26) | 31 October |
Providers with a different financial year end follow the same four-month window. A provider with a 31 December year-end, for example, has until 30 April to lodge their ACFR, APCS, and Care Minutes Performance Statement.
What Changed in 2025–26
Two significant changes apply to the 2025–26 reporting year:
Care Minutes Performance Statement: All residential aged care providers, including those who do not hold RADs, must now prepare and submit an externally audited Care Minutes Performance Statement as part of the ACFR. This is a new obligation from 2025–26 onwards.
Transitional legislation: The 2025–26 APCS covers two separate legislative periods. The Aged Care Act 1997 applies from 1 July to 31 October 2025. The Aged Care Act 2024 applies from 1 November 2025 to 30 June 2026. Providers and their auditors should confirm which requirements apply to each section of the ACFR for this transitional year.
What Happens If You Miss the Deadline
Late lodgement or an incomplete APCS can trigger a prudential targeted review by the ACQSC. This is a formal regulatory process that may result in:
- Requests for additional financial documentation
- Directed audits or on-site inspections
- Conditions placed on the provider's registration
- Referral for further action under the Aged Care Act 2024
Providers who anticipate difficulty meeting the lodgement deadline should contact the Department of Health, Disability and Ageing as early as possible. The ACQSC has published specific guidance on late APCS lodgement and the regulatory consequences that follow.
Frequently Asked Questions
Does every residential aged care provider have to submit an APCS?
No. Only providers who held a Refundable Accommodation Deposit or bond balance during the reporting period are required to submit. Home care providers are not subject to this requirement.
Is the APCS the same document as the Aged Care Financial Report?
No. The APCS is one section within the ACFR. The full report also includes financial statements and, from 2025–26, the Care Minutes Performance Statement. All sections are lodged together through the online provider portal.
Who provides the audit opinion for the APCS?
An independent external auditor must review the APCS and provide a formal audit opinion before it is lodged. The ACQSC publishes clean and qualified audit opinion templates to guide this process.
Are there resources available to help prepare the APCS?
Yes. The Department of Health, Disability and Ageing publishes an APCS User Guide, audit guides, and opinion templates each financial year. The ACQSC also provides compliance guidance and publishes the outcomes of prudential targeted reviews, which can help providers understand what regulators look for during a review.
What if my financial year does not end on 30 June?
The four-month lodgement window applies regardless of when your financial year ends. A provider with a 31 December year-end, for example, has until 30 April to submit their full ACFR including the APCS.
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