Key management personnel

How to determine who are Key Management Personnel (KMP)

Definition of KMP

KMP has the same meaning as defined in AASB 124 Related Party Disclosures

Under AASB 124, KMP are those persons having authority and responsibility for planning, directing and controlling the activities of the entity, directly or indirectly, including any director (whether executive or otherwise) of that entity. Commonwealth entities in preparing their annual financial statements would have decided which persons meet the definition of KMP. 

Consistent with this definition, the Accountable Authority of entities, including Secretaries of Departments of State, Chief Executives of non-corporate Commonwealth entities, and non-executive Board members are considered to be KMP. 

Common examples of other KMP determined by Commonwealth entities in preparing their financial statements in accordance with AASB 124 may include, but is not limited to, the following:

Non-corporate Commonwealth entities



Corporate Commonwealth entities



There should be consistency in the reporting of KMP remuneration between the financial statements and the information reported in the body of the annual report.

The following questions may assist entities to determine the people to be reported as KMP


evaluation methods


If an entity answers ‘Yes’ to all or most of these questions, it supports the inclusion of the relevant person as a KMP for the purposes of executive remuneration reporting in the entity’s annual report. In particular, it is expected that the Accountable Authority and each member of the governing board would be reported as KMP. 

Refer to Employment arrangements to include in disclosure tables for further detail on how to determine individuals to include in the executive remuneration reporting.

What to report under KMP executive remuneration

KMP executive remuneration information must be reported in accordance with the KMP table in Schedule 3 of the PGPA Rule.

For each of the key management personnel of the entity, the following information must be included:



The Digital Annual Reporting Tool reporting table for KMP is prepopulated with the information above in the format required by the KMP table in Schedule 3 of the PGPA Rule. Entities should complete the data templates with the Digital Annual Reporting Tool to ensure that the correct information is being reported. Please refer to How to calculate & report for further details on this and general requirements on each remuneration category.

Reported KMP remuneration to be consistent with financial statements

Under AASB 124, reporting entities are already required to disclose in the notes to the financial statements total remuneration of the KMP at the aggregate level.

The key difference between what is reported in the notes to the financial statements, and what is required under the PGPA Rule for KMP is the level of detail. The financial statement disclosure is on an aggregated basis, whereas the annual report disclosure is required to be on an individual basis. Additional information that must be included in the table includes the:

  • Full name of the KMP, and
  • Position of the KMP, for example: Accountable Authority or Chief Executive Officer.

The total KMP remuneration disclosed in accordance with the PGPA Rule should match the total KMP remuneration disclosed in the notes to the financial statements.

KMP personal information disclosure

The personal detail disclosure for KMP executive remuneration reporting is ‘required or authorised by or under an Australian law’ for the purposes of the Privacy Act 1988 (see in particular Australian Privacy Principle 6.2(b)). As such, there is no requirement for Commonwealth entities to obtain the permission of the persons covered by the disclosures. 

While it is the responsibility of each entity to manage the process of gathering and publishing the required disclosures in accordance with their own governance arrangements, it would be expected that the persons covered by the disclosures, particularly KMP who are required to be individually identified, would be formally advised about the entity’s reporting obligations and provided the opportunity to review the information proposed to be reported. 

Variation in KMP membership during the reporting period

Where the composition of an entity’s KMP changes from that disclosed in the previous reporting period, it is also practice for a note to be included in the annual report to explain the variation. 

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