ASIC has granted a no-action position to immediately reduce the frequency of internal dispute resolution (IDR) data reporting for small banks, from every six months to once per year.
The change to IDR reporting frequency, recommended by the Council of Financial Regulators (CFR) following its Review of Small and Medium-sized Banks, is intended to reduce regulatory costs for small banks and improve their competitiveness with larger banks.
ASIC has proactively decided to adopt the no-action position now, ahead of formalising the technical and system changes, expected in 2027.
As detailed in the class no-action letter (see below), small banks will be exempt from the next IDR data submission window.
No-action position
ASIC does not intend to take action against small banks for a contravention of the requirement to submit an IDR report in the January-February 2026 and January-February 2027 submission windows, as specified in Instrument 2022/205.
The full terms of the no-action position, including the small banks to whom it applies, are set out in the no-action letter. The no-action letter does not prevent third parties from taking legal action in relation to that conduct.
Please see Regulatory Guide 108 No-action letters for more details.
Download
Class no-action letter (PDF 261 KB)
Related links
ASIC to act on recommendations in CFR report on small and medium banks
Final Report of the Review into Small and Medium-sized Banks | CFR
