ASIC Regulatory Reporting – Have We Reached Normalcy?

ASIC Derivative Transaction Rules (Reporting) 2024 went live on 21 October 2024. Since then, our clients have been asking for what lies ahead and can they really conclude that we are in “business-as-usual” state? What is clear however, is that change is still taking place, and regulatory expectations for data mapping and accuracy are arguably increasing.

Change — The Only Constant

1. Amendments to ASIC Derivative Transaction Rules (Reporting) 2024 – ASIC plans to add 9 data elements which includes sets of schedule fields such as notional quantity schedules, price schedules, strike price schedules and barrier level schedules possibly increasing the actual number of data fields to source as schedule fields require amounts, effective and end dates for example. ASIC also proposed to additionally amend 3 existing data elements amongst providing clarity on certain parts on the existing rules. These changes come at the back of The Regulatory Oversight Committee (ROC) publishing the Revised CDE Technical Guidance v4 on 23 December 2025 addressed to regulatory authorities including ASIC and these include revisions and new data elements to the September 2023 CDE Technical Guidance v3. ASIC has published the proposed amendments to the 2024 reporting rules on 27 March 2026 allowing for public comments on the proposed changes up till 8 May 2026 before finalizing implementation details.
2. DSB UPI Changes – Industry representatives in collaboration with industry associations have been discussing the creation of a UPI FX TARF product template and formal proposals have been sent to CDIDE (Committee on Derivatives Identifiers and Data Elements). It is anticipated that this information will ultimately be reflected in the CDIDE ROC “Guidance on FX TARF Derivative Transaction Reporting”. Along the same vein, DSB has published updated DSB UPI and OTC ISIN Best Practices/FAQs, which includes guidance on the use of existing and new Equity TRS templates.

Pressure on Reporting Entities’ Reported Data Quality

In 2024-25, ASIC undertook a sector wide review on Contract for Differences (CFDs) issuers culminating in a report published in January 2026 titled “Risky Business: Driving Change in CFD issues’ distribution practices”. While the report also details findings on distribution practices, what stands out in the context of regulatory reporting is the significant failures on the CFDs compliance with the reporting rules. The findings can be categorically classified as missing reportable information under the 2024 rules, data quality deficiencies and the lack of proper data governance and oversight. The number of erroneous reports that were found was a staggering 70 million.

The implications extend beyond CFD issuers in Australia and infer a broad reminder to all ASIC reporting entities including banks and asset managers that they can no longer overlook the importance of establishing a robust control framework and must be adept at staying ahead of regulatory developments whilst maintaining oversight of existing reporting obligations. An often-overlooked aspect of the ASIC rules is the requirement for proactive compliance as quoted by ASIC, “Some CFD issuers also failed to identify breaches of the law and/or report them to ASIC”. The expectation is clear that it is unacceptable to forego processes such as reconciliation, data quality health assessments via in-house processes or third parties, exception management, issue resolution and have a mechanism in place to report any detected issues promptly to ASIC.  Having such procedures would demonstrate to ASIC a clear commitment to due diligence and a robust culture of issue management and a strong controls framework.

One CFD issuer, however, was cited as consistently reported high-quality data and their success factors include effective collaboration with their industry peers and international regulators, regular reconciliations between internal records and reported data at the trade repository and adherence to ASIC’s guidance on frequency and form of third-party oversight.

Why Cappitech?

We remain committed to providing our existing and prospective clients with a dedicated solution across the breadth of the reporting requirements via a single unified platform for global transaction reporting and a control framework offering including reconciliation, data quality checks and insights.

Our value proposition remains strategically aligned to address such challenges not just for ASIC reporting but extends to every other jurisdiction that we support. Leveraging our wide industry network and proactive engagement via industry forums, we are well-positioned as your partner to provide the holistic value-add reporting suite of offerings backed by a team of experts who can help with implementation of data transformation projects supported by a comprehensive understanding of regulatory reporting requirements, health assessments centred around data quality themes of accuracy and completeness, ad-hoc support and managed services to ensure your continued compliance success.

Have Questions?

Contact Cappitech’s Consulting experts today to discuss how these changes or data quality observations could impact your reporting and how we can help you stay compliant.

About the author: Faizal Aziz

With 18 years of experience in financial services, Faizal brings a wealth of expertise and leadership most recently was the Executive Director of Product Management at DTCC Singapore managing the APAC product delivery function. Faizal is adept at navigating complex regulatory environments and has a proven track record of delivering projects within budget and timelines. Faizal started his career at Barclays Capital holding several positions across client services, client onboarding, derivatives middle office and electronic trading and is currently the Head of Business Development, APAC at S&P Global. Outside of work, Faizal is an avid runner and cyclist and is an aspiring triathlete.