The Australian Securities and Investments Commission (ASIC) has rolled out a major overhaul of the derivative transaction reporting regime. These ASIC changes bring new rules, reporting formats, and expanded obligations for firms dealing in over-the-counter (OTC) derivatives.

With implementation spread across multiple phases, financial institutions must act early to ensure their infrastructure, data mapping, and validation logic are ready in time.

Understanding the ASIC Changes

The ASIC Derivative Transaction Rules (Reporting) 2024 introduce a staged timeline, with obligations taking effect in 2024 and 2025. Together with amendment instrument 2024/416, they reshape the reporting landscape for entities operating in Australia or connected to Australian counterparties.

The key driver is to improve data quality and align Australian rules with international standards such as ISO 20022, UTI (Unique Transaction Identifier), and UPI (Unique Product Identifier).

ASIC Changes Timeline: Phases and Key Dates

These are the critical milestones firms must prepare for:

• 21 October 2024: Schedules 1, 2, and 3 took effect. These included many of the new OTC derivative reporting fields, adoption of ISO 20022 XML format, and new obligations for data mapping and validation. Firms needed to ensure systems could capture and process this expanded dataset from day one.

• 20 October 2025: Schedule 4 will take effect. This final phase introduces further obligations, including expanded asset class coverage and adjustments to single-sided reporting relief for foreign counterparties. From this date, the full rules set across all four schedules will be mandatory.

Read ASIC’s official Handbook entry here.

Who Must Report Under the ASIC Changes

The rules define clear categories of reporting entities and what each must disclose.

Australian Financial Services Licence (AFSL) Holders, ADIs, and Foreign Branches

Any firm with an AFSL, authorised deposit-taking institutions, and foreign firms with a branch in Australia are considered reporting entities if they enter into covered OTC derivatives. They must report:

• Trade economic details

• Product and entity identifiers

• Clearing status

• Valuation and collateral data

• Modifications and cancellations across the trade lifecycle

Smaller Entities Under Thresholds

Firms with gross notional outstanding positions below thresholds (for example, under AUD $5 billion) may be eligible for single-sided reporting relief. However, this relief is subject to strict conditions, and all lifecycle events must still be reported by at least one counterparty.

Firms Dealing With Foreign Counterparties

From October 2025, the ASIC changes adjust single-sided relief for cross-border trades. ASIC-regulated entities will typically need to report regardless of the counterparty’s obligations under foreign regimes.

For a full explanation of reporting responsibilities, see ASIC’s derivative reporting guidance.

What’s New in the ASIC Changes

Beyond who reports and when, firms must prepare for several new technical standards:

• ISO 20022 XML is now the required reporting format

• New data fields, such as UTI, UPI, and entity identifiers, must be populated

• A “measured compliance” approach applies during the transition, with ASIC signalling that reasonable efforts to comply will be expected in the early stages

Why These ASIC Changes Matter

For reporting entities, these updates mean upgrading infrastructure, enhancing data quality, and reviewing governance processes. Errors or late adoption could result in non-compliance risks once ASIC moves beyond transitional allowances.

The broader aim is harmonisation with global standards, ensuring that Australian derivative reporting aligns with other G20 jurisdictions and delivers the transparency regulators require.

How Reg-X Can Support Firms

At Reg-X, we help financial institutions adapt seamlessly to regulatory reporting reforms. Our regulatory reporting solutions are designed to:

• Capture, map, and populate new fields automatically

• Align reporting with ISO 20022 XML format requirements

• Manage UTI and UPI generation and matching across counterparties

• Adjust reporting logic to reflect phased obligations under the ASIC changes

Our team also provides consulting and outsourcing services to firms that need clarity on how these changes apply to their business.

With ISO/IEC 27001 and SOC 2 Type II certification, Reg-X combines security and compliance expertise to deliver reliable solutions for clients across jurisdictions.

Preparing for 2025 and Beyond

The ASIC changes represent one of the most significant shifts in Australian reporting in recent years. Firms that act early will avoid operational bottlenecks and ensure smoother adoption of both 2024 and 2025 obligations.

At Reg-X, we believe regulatory change should be an opportunity, not a burden. With the right systems and guidance, compliance can become a controlled, efficient, and trusted process.

If you would like to learn more about how Reg-X can support your reporting under the ASIC changes, please get in touch.