Reportable situations and internal dispute resolution data publication: HSF submission

On 10 April 2025, ASIC published Consultation Paper 383: Reportable situations and internal dispute resolution data publication (CP 383). CP 383 outlines ASIC’s plan to publish interactive dashboards containing firm-level data about reportable situations (RS) and internal dispute resolution (IDR).

Our team has made a formal submission on this consultation.

In summary, our submission addresses ASIC’s proposal to:

• publish firm-level data in an interactive dashboard that enables users to search and filter the data to obtain insights; and
• provide explanatory information to help users understand and interpret the data elements.

In short, our submission is that information should not be published at a firm-level, nor should the underlying data, without context, be accessible to the public.

In our view, there is a tangible risk that publication of firm-level data would be inconsistent with certain objectives of the RS and IDR regimes, including the objectives of enhancing transparency, encouraging breach reporting, and maintaining (and improving) trust and confidence in the financial system. From this perspective, the regulatory cost associated with the proposed changes are likely to outweigh any potential regulatory benefit.

It is our view that ASIC’s current approach to publishing information should be retained. That is, publishing an annual report summarising aggregated data regarding reported breaches and internal complaints. This approach, in our view, correctly and appropriately balances transparency in relation to breach reporting and compliance by providing consumers with contextual information and trends, while still upholding trust and confidence in the financial system.

If you would like to read a copy of our submission, download a copy here.

If you have any questions, get in touch with one of our experts below.