AIST supports the principles of accountability, responsibility, and transparency which underpin the proposed Financial Accountability Regime. Improvements can be made to the Regime, including clarifying the definition of a “material contravention” and developing a facility to enable accountable entities to check if potential accountable person candidates have been deregistered. We recommend clarifying and narrowing the scope of ministerial powers and reconsidering the scope of how the secrecy provisions apply to the directions power in light of the APRA Capability Review which recommended that APRA depart from a ‘closed door’ approach.