CS 65 Proposed remake of IDR data reporting instrument

Released 16 October 2026. Comments close 13 November 2026.

We are seeking feedback on our proposal to remake ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205. The instrument is scheduled to expire on 1 April 2027.

We propose to remake the instrument for a period of 5 years. The effect of the instrument will remain largely unchanged. The only substantive change proposed is to give small banks the option to report their internal dispute resolution (IDR) data annually rather than every 6 months.

We have also made minor amendments to update and simplify the instrument, including:

removing outdated information on transitional arrangements
amending the definition of a ‘closed’ complaint to include complaints that have been withdrawn, discontinued or referred to another licensee to resolve, to align with the existing complaint outcome codes in the IDR data reporting handbook (IDR handbook), and
including a streamlined definition of ‘IDR response’ from Regulatory Guide 271 Internal dispute resolution (RG 271) directly in the instrument, to improve clarity and accessibility.

See Related information for copies of the draft instrument. We also intend to update the IDR handbook to align with the remade instrument and make other minor amendments.

A consultation paper was not issued for this consultation.

Consideration of annual reporting for all firms

We invite feedback specifically on whether the proposal to reduce the reporting frequency from six-monthly to annually for small banks (on an optional basis) should be extended to all reporting firms.

If annual reporting were extended to all firms, we consider that a mandatory annual approach would be necessary for consistency and comparability across firms. This means there would be no option to report on a six-monthly basis, and all firms would report on an annual basis. This would reduce the currency of IDR data published through our IDR data dashboard.

We welcome feedback on whether the benefits of broader reporting relief would outweigh the reduction in the timeliness of available data. Please provide reasons, including estimated costs or savings and any other impacts.

Impact analysis

Before settling on a final instrument, we will comply with the Australian government impact analysis framework. To assist us to understand the impact of our proposal to remake ASIC Instrument 2022/205, we invite feedback on the questions below. Please explain the basis and key assumptions for your estimates:

What processes do you currently have in place to report IDR data to ASIC? To what extent would you undertake these processes anyway even if not required to report to ASIC (e.g. for internal management purposes)?
If we remake the instrument as proposed, what compliance costs or savings would you expect to incur? Please provide specific details and dollar estimates for any upfront and ongoing costs or savings.
Would remaking the instrument as proposed have any other impacts on your organisation? Please provide specific details.

Providing feedback

We invite feedback on our proposal. You should send your submission to rri.consultation@asic.gov.au by 5 pm AEDT on Friday 13 November 2026.

You may choose to remain anonymous or use an alias when providing feedback. However, if you do remain anonymous, we will not be able to contact you to discuss your feedback should we need to.

We will not treat your feedback as confidential unless you specifically request that we treat the whole or part of it (such as any personal or financial information) as confidential.

Please see our privacy policy for more information on how we handle personal information, your rights to seek access to and correct personal information, and your right to complain about breaches of privacy by ASIC.

Background

ASIC Instrument 2022/205 specifies the information that financial services licensees must give ASIC on their IDR procedures and the operation of those procedures. The instrument requires IDR information to be reported to ASIC every six months in the manner and format specified in the IDR data reporting handbook. The law also requires certain other types of firms, including credit licensees, to report to ASIC as if they were financial services licensees.

The reduction in IDR reporting frequency for small banks was a commitment made in the Council of Financial Regulators’ Final report of the review into small and medium-sized banks. In September 2025, we published a no-action position allowing eligible small banks to immediately move to annual reporting, pending formal implementation through the remade instrument.