ASIC Demands Stronger Reporting Controls
Key Takeaways
- ASIC REP 828 shows that CFD issuers are now expected to demonstrate strong governance, oversight and data quality controls across the full OTC derivative transaction reporting lifecycle.
- ASIC identified more than 70 million erroneous reports, showing that transaction reporting failures are not isolated technical issues but broader indicators of weak operational controls.
- Delegated reporting does not remove a firm’s responsibility. CFD issuers must actively oversee reporting delegates, verify submitted data and reconcile trade repository records against internal books.
- Reconciliation, lifecycle event monitoring and exception management are becoming core regulatory expectations, particularly for stale positions, valuations, timestamps, collateral reporting and transaction-to-position conversions.
- Firms that rely only on report submission without proactive QA, monitoring and governance risk regulatory scrutiny, remediation pressure and potential reportable situations.
ASIC’s latest review of CFD issuers signals that the regulator is no longer focused solely on whether reports are submitted, but whether firms can demonstrate robust governance, oversight and data quality controls across the full reporting lifecycle.
With ASIC identifying more than 70 million erroneous reports, widespread failures in delegated reporting oversight and significant weaknesses in reconciliation and monitoring processes, the report reinforces the increasing regulatory expectation for firms to maintain proactive QA, exception management and supervisory-grade reporting controls.
The findings, detailed in the recently published Report 828 (REP 828) on 20 January 2026, expose a massive gap in data quality, transaction reporting governance, oversight and ongoing monitoring.
Failures were systemic enough to secure nearly $40 million in refunds for retail investors who were financially impacted by these reporting and compliance oversights.
ASIC states that “most CFD issuers had significant failures in derivative transaction reporting with minimal oversight of reporting delegates.”
Qomply has seen an increase in regulatory activity from ASIC that started last year and continued strongly in 2026. Therefore, have first-hand insight into how ASIC is approaching firms and the ensuing requests to tighten reporting.
Below are ASIC regulatory themes, highlighted in their report.
ASIC expects active oversight of delegated reporting
There is a significant gap in how the industry understands ASIC regulatory obligation to reconcile transactions. Many firms operating under a delegated model appear to believe there is no "work" left on their side. They are mistaken. Current standards require firms to verify the accuracy of each report and conduct a rolling 30-day reconciliation of the data sent to the trade repository against their internal records. ASIC specifically criticized issuers for failing to scrutinize information reported to trade repositories, maintain active oversight of third-party delegates, and identify erroneous trades and valuations before they were flagged by the regulator.
ASIC specifically criticised firms for failing to:
- scrutinise information reported to trade repositories,
- oversee third-party reporting delegates,
- and identify erroneous trades and valuations.
The scale of this issue is highlighted by the fact that out of the 52 issuers reviewed, only one was recognized for consistently producing high-quality reporting. ASIC’s intervention has forced a massive industry-wide cleanup of legacy data, with 48 issuers implementing changes to comply with OTC derivative transaction reporting requirements and 44 issuers forced to overhaul their client onboarding questionnaires. The audit identified that firms struggle most with lifecycle event quality, including unwind payments, collateral reporting, transaction-to-position conversions, and timestamp accuracy. ASIC is now treating these technical gaps as evidence of broader operational governance immaturity.
Reconciliation and controls are becoming regulatory expectations
ASIC explicitly praised firms that:
- reconciled trade repository data against internal records,
- monitored lifecycle reporting quality,
- and corrected stale or erroneous positions.
Lifecycle event quality remains a major weakness
ASIC identified recurring issues involving:
- unwind payments,
- transaction-to-position conversion,
- collateral reporting,
- timestamps,
- market valuations,
- leg direction reporting,
- and stale positions.
These are exactly the areas where firms commonly struggle operationally after major reporting rewrites.
How Qomply can help
Qomply’s advanced quality assurance tools and dedicated APAC office provide the technical precision required to identify the specific errors, such as lifecycle mismatches and reconciliation gaps, that triggered the 70-million-report audit. By enabling CFD dealers to detect reporting deficiencies before they escalate into "reportable situations," we provide the certainty needed to navigate ASIC’s new era of high-fidelity enforcement.
Frequently asked questions
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ASIC REP 828 revealed widespread weaknesses in CFD transaction reporting, including more than 70 million erroneous reports, poor delegated reporting oversight and significant data quality control failures.
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No. Firms remain responsible for the accuracy and completeness of their regulatory reporting, even when reporting is delegated to a third-party provider.
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Reconciliation helps firms compare trade repository data against internal records, identify inaccurate or stale reports and demonstrate effective oversight of reporting quality.
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ASIC identified recurring issues involving lifecycle events, collateral reporting, unwind payments, timestamps, market valuations, leg direction reporting, stale positions and transaction-to-position conversions.
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CFD issuers should strengthen reporting governance, actively oversee delegates, implement regular reconciliation, monitor lifecycle event quality and use proactive QA controls to identify issues before they escalate.