Limiting the size of large contribution files
The purpose of this document is to provide additional guidance on appropriate limits to the size of large member registration request and contribution transaction request files under the SuperStream Data Standard (the Standard).
It is expected that this guidance will need to be applied only by a small number of industry participants, specifically:
- employers generating XBRL instance documents for more than 10,000 registrations or contributions to the same unique superannuation identifier (USI) in a single transaction (this is generally limited to employers with more than 10,000 employees)
- service providers (such as clearing houses) who are in a position to generate XBRL instance documents that aggregate beyond 10,000 registrations or contributions to the same unique superannuation identifier (USI) in a single transaction
- funds that receive registrations and contributions from employers or service providers included in scope.
Analysis undertaken by the SuperStream Standard Technical Committee (SSTC) has identified that significant performance issues may be encountered when processing member registration request (MRR) and contributions transaction request (CTR) files with large numbers of members included (for example, where more than 10,000 members are included in the same XBRL business document). These performance issues present a risk to successful allocation of member contributions within the required regulatory timeframes.
The SSTC has examined the issue and devised a workaround to address the performance concerns. The proposed solution is to limit the maximum number of members included in a single MRR or CTR XBRL business document.
Dividing files with large numbers of members
In order to avoid significant processing delays member registration request (MRR) and contribution transaction request (CTR) files should be limited to no more than 10,000 members. This should result in an XBRL business document of no more than 50 MB in size.
Where more than 10,000 members would otherwise be aggregated into the same XBRL business document, employers and their service providers should divide the members across multiple XBRL business documents such that no individual CTR or MRR contains more than 10,000 members.
The rules for transmitting the divided CTR and MRR XBRL business documents then apply as normal under the Standard, including:
- the divided XBRL business documents may be sent in individual ebMS3 envelopes or sent as multiple parts within a single envelope
- there must be one payment per XBRL business document, and one XBRL business document per payment.
It is important to note that the concept of ‘dividing’ a CTR or MRR is not the same as the concept of ‘splitting’ those files under either the Large Volume or Application Gateway profiles. In this context ‘dividing’ a file is the process for apportioning members across multiple XBRL business documents instead of including them all in a single XBRL business document. The question of whether files then need to be ‘split’ would be considered on the basis of the size of the resulting ebMS3 envelope created and the rules in the Superannuation Data and Payment Standard Schedule 5 document Message Orchestration and Profiles.
Implications for an associated member registration request
In addition to the requirement to divide a member registration request (MRR) where more than 10,000 members would otherwise be included, the MRR may need also to be divided for its travel together with the divided CTR if the divided CTR documents are to be sent via separate ebMS3 envelopes. This is to ensure that the intent of the requirement for all member registrations in the original file to be processed prior to the processing of contributions in the original file is still met (reference paragraph 2.2.2(c), Superannuation Data and Payment Standard Schedule 4(a) document Contributions Message Implementation Guide).
In dividing the MRR the following rules must be applied:
- if a member is included in the original CTR, any divided MRR containing that member’s details must travel together (in the same ebMS3 envelope) with the divided CTR that also includes that member’s details
- if a member is not included in the original CTR (i.e. member registration/update without a contribution), that member’s details may be included in any of the divided MRR documents that are sent with the divided CTR documents.
Implications for payments
A requirement of the Standard is that there must be a one-to-one relationship between a payment and a contributions transaction request (CTR) message (refer to second dot point of the explanatory notes to Section 6, Superannuation Data and Payment Standard Schedule 4(a) document Contributions Message Implementation Guide).
What this means is that when a large CTR is divided into multiple, smaller, CTR documents it necessarily follows that there will be multiple payments associated with those divided CTR documents (that is, a separate payment associated with each divided CTR document).
As payment details form a critical part of a CTR it is important that employers and their service providers consider any need to divide a CTR prior to the point when payment instructions are made.
Employers and their service providers should limit member registration request and contribution transaction request XBRL business documents to include no more than 10,000 members. This should result in an XBRL business document of no more than 50 MB in size.
Employers and their service providers should divide member registration request and contribution transaction request messages into multiple XBRL business documents where more than 10,000 members would otherwise be included. This should result in an XBRL business document of no more than 50 MB in size.
Employers and their service providers should be mindful of the need to divide contribution transaction request XBRL business documents before issuing payment instructions.
Funds should identify and work with affected employers and service providers to support their adoption of this guidance. Where a fund receives a file that exceeds the limits established by this guidance, the fund should still attempt to process the file, but should engage with the employer to avoid this circumstance in the future.