Australia: ASIC Revises its IDR Reporting Framework. Are You Ready?

By Daniel Knight and Hugo Chow

All holders of an Australian Financial Services License (AFSL) with a retail client authorisation will need to comply with ASIC’s internal dispute resolution (IDR) reporting framework. Summary reports will need to be provided to ASIC on a 6 monthly basis, highlighting the status of each client complaint. Reporting obligations commence from 1 July 2023 (for reporting in January or February 2024). AFSL holders should put systems in place now to ensure all required information is being captured.

What needs to be reported to ASIC?

The IDR data that must be reported to ASIC include specified data in relation to each complaint received by an applicable AFSL holder, that:

  • is required to be covered, or is covered, by the AFSL holder’s IDR procedure; and
  • was either:
    • made in the current reporting period; or
    • made after the start of the initial reporting period for the AFSL holder, and was not closed for the whole of the current reporting period.

Even if an AFSL holder receives no complaints in the relevant reporting period, the AFSL holder is still required to submit a ‘nil submission’ to ASIC.

If an AFSL holder’s IDR procedures also cover wholesale clients, complaints made by wholesale clients will also need to be reported to ASIC.

When do you need to report IDR data to ASIC?

For most AFSL holders with retail authorisations, the first applicable reporting period will be from 1 July to 31 December 2023. This does not apply to firms that were part of the ‘first tranche firms’ and ‘second tranche firms’ for whom reporting has already started.

The following reporting periods will apply thereafter:

  • 1 January – 30 June; and
  • 1 July – 31 December.

There is a 2 month window submission after each relevant reporting period for AFSL holders to submit an IDR report to ASIC.

For example, if an AFSL holder is captured under the 1 July to 31 December 2023 reporting period, they will have from 1 January – 28 February 2024 to submit their IDR report for the 1 July – 31 December 2023 reporting period.

AFSL holders with a retail client authorisation will need to lodge an IDR report with ASIC every six months.

How do you report IDR data to ASIC?

All IDR reports must be submitted to ASIC via the ASIC Regulatory Portal.

More information regarding the specific format ASIC requires reports to be lodged in can be found here.

Applicable AFSL holders should have appropriate systems in place in order to track complaints made from 1 July 2023.

Do not hesitate to get in touch with us if you have any questions.

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