ASIC REP 830: Key Watch Items

ASIC's Report 830 (REP 830) is a regulatory simplification progress report that primarily addresses work already underway. It flags two developments for AFS licensees and fund managers: 

• Signals of support for broader reportable situations reform.
• Active consultation on simplifying the substantial holding notice regime.

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The goal of the simplification is to ease specific “burdensome” reporting requirements that consume resources while adding limited, if any, consumer benefit. 

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What REP 830 Signals

ASIC has publicly expressed support for extending reportable situations reforms beyond the banking sector to all other AFS licensees, which may include removing the requirement to automatically report specific breaches. This signals a meaningful shift toward a cleaner, across-the-board approach.

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Incremental changes are already in force. In June 2025, the investigation reporting threshold for AFS and credit licensees was extended from 30 to 60 days. That means certain misleading and deceptive conduct breaches are now exempt from reporting obligations; however, note that the underlying provisions still apply.

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Additional Key Regulatory Updates in ASIC's REP 830

Beyond reportable situations, REP 830 also flags several other developments. These are worth noting, though at an earlier stage or of narrower application.

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• Substantial holding notice regime: Under its new power to approve the manner and form of substantial holding notices, ASIC is consulting through Consultation Paper 387 on replacing the three existing prescribed forms (Form 603, Form 604 and Form 605) with a single simplified notice. ASIC is also consulting on a web-based notice and digital submission format for submitting substantial holder information. Fund managers running multiple funds or dealing with fast-moving positions may find this directly relevant, given how operationally sensitive and time-critical these notices are.
• Platforms instrument*: ASIC will make a new simplified instrument consolidating the two existing IDPS instruments, with updated guidance to follow. 
• Financial reporting and audit relief: ASIC will proceed with two separate consolidated instruments (one for financial reporting, one for audit), with further consultation on simplification to come.
• Financial advice roadmap: ASIC published pilot sector-roadmaps for financial advice businesses. These initiatives are designed to assist stakeholders to easily access guidance relevant to their specific needs.
• Private credit: ASIC issued a catalogue of key legal obligations for private credit funds in December 2025. Fund managers in this sector should treat it as a signal of ASIC’s compliance expectations.
• IPO timetable: A faster ASX IPO listing process is now in a two-year trial, aimed at reducing deal execution risk and providing greater deal certainty for capital markets transactions.
• Data collection: ASIC and APRA are working on reducing duplicated data requests, though this remains at an early, high-level stage.
• ASIC portal changes: The Register of Relevant Providers and the Authorised Representative Register will migrate to the ASIC Regulatory Portal, with pre-filling and reduced duplication across transactions.

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With those developments in mind, here's what AFS licensees and fund managers should be doing now.

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What You Need To Do Now

Review your current reportable situations framework against the relief already in place. Pay particular attention to the 60-day investigation threshold and the misleading and deceptive conduct exemption, if you have not done so already.

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Monitor developments closely, as broader reform will require government action and likely legislation. For now, ASIC's direction of travel is clearer than it has been previously.

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Stay Ahead of Regulatory Change

REP 830 is a progress report, not a final position. However, the signals it contains may be meaningful to AFS licensees and fund managers with a significant breach-reporting load.

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Aligning your compliance framework with current relief now puts you in a stronger position for future updates. Speak with PMC Legal to ensure your compliance framework is ready for when broader reform does arrive. 

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*Note: The consolidated instrument, ASIC Corporations (Platforms—IDPSs and IDPS-like Schemes) Instrument 2026/395, was published on 6 July 2026. An updated Regulatory Guide 148 is expected to follow.

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