With 2026 well underway, there are a number of key dates financial services businesses need to make sure are on the radar in order to stay compliant. Here’s a useful overview of the lodgements you will need to manage during the first quarter.
IDR reporting – due by 28 February 2026:
You’ll need to submit your Internal Dispute Resolution (IDR) report covering the period from 1 July 2025 to 31 December 2025 to ASIC via the regulatory portal by the end of February. The submission window for this reporting period runs from 1 January 2026 to 28 February 2026. Ensure you submit your IDR report well before 28 February 2026 to allow sufficient time to review the results of data validation, and if necessary, fix any errors and resubmit your data for further validation.
AUSTRAC Compliance Reporting – due by 31 March 2026:
Your annual compliance report must be submitted to AUSTRAC, covering the period from 1 January 2025 to 31 December 2025. This report is due by 31 March 2026. You can make a start now by reviewing the 2025 preview questions. Changes from 2024 include:
- Additional questions on:
– Outsourcing of risk assessments
– AML/CTF reform 2026 readiness understanding
– Reporting entities views on AUSTRAC’S engagement and feedback - A new section on Enhanced Customer Due Diligence (ECDD)
- Moving from free text fields to structured multiple choice options
- Increased clarity on explicit references (e.g KYC, terminology).
ASIC Industry Levy FY25 – payment due in the first quarter of 2026:
Final ASIC levies are published in December 2025 with invoices issued between January and March 2026. Summary of levies charged for FY25 can be viewed here.
Additionally, you may have specific ATO lodgement requirements which we are not fully privy to. Please ensure you are meeting your obligations with the ATO as well.
In other news…ASIC has been busy! Stay compliant, stay ahead.
Review your PDSs
ASIC has updated its guidance document (RG168) in December 2025. Key changes include:
- Increased focus on ESG and ethical considerations in relevant products
- Greater flexibility for digital delivery of PDSs
- Enhanced consumer protection through clearer communication requirements in time-critical situations
- Expanded exceptions to reduce regulatory burden where appropriate.
Are you a Responsible Entity with digital asset products? Time for a risk review!
ASIC has updated its guidance document INFO sheet 225 with clarifications on how ASIC expects providers of these products to operate. Key items to consider are:
- Responsible Managers – Do they have relevant digital asset experience and skills?
- Due diligence on outsourced providers – Have you conducted due diligence on digital exchanges used and that it is registered with AUSTRAC (or overseas equivalent)?
- Custody requirements – minimum Net Tangible Asset (NTA) requirements
- Disclosure Requirements – Ensure PDSs include all key elements of digital assets.
Time to update your Conflict of Interest policies and processes
ASIC updated its guidance document RG181 in December 2025 after increased incidents and a need for clarification. Comprehensive updates include:
- Expanded scope of the obligation – links to inside and outside business activities
- Taking a risk-based approach – not a ‘set and forget’ activity
- Clarifying types of conflicts with specific examples – practical guidance
- New materiality assessment guidance – covering the seriousness of the situation
- Increased penalties and fines
- Links to other AFSL obligations
