On 24 September 2025, the Australian Securities and Investments Commission (ASIC), issued a no-action letter reducing the internal dispute resolution (IDR) reporting frequency for certain small banks, ahead of formalising ASIC’s technical and system changes for IDR reporting in approximately 2027.
ASIC does not intend to take action against a small bank for a contravention of:
- subparagraph 912A(1)(g)(ii) of the Corporations Act 2001; or
- paragraph 47(1)(ha) of the National Consumer Credit Protection Act 2009,
to the extent they require the small bank to give ASIC the information (the IDR Report) specified in ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205 in relation to a 6-month reporting period ending on 31 December 2025 or 31 December 2026.
ASIC’s no-action position is conditional on the small bank:
- preparing their next IDR Report (full-year IDR Report) to cover the 12-month period from 1 July 2025 to 30 June 2026 or 1 July 2026 to 30 June 2027 (as applicable); and
- submitting the full-year IDR Report to ASIC by 31 August 2026 or 31 August 2027 (as applicable).
Third parties
The no-action letter does not prevent third parties from taking legal action in relation to that conduct.