Our guide to the latest IDR reporting changes
Key takeaways
Changes to the IDR data reporting deadlines mean smaller financial firms will not be required to lodge an initial IDR data report until February 2024.
Additionally, for all reporting firms, the time to lodge an IDR data report with ASIC has been increased from one month to two months after the end of a reporting period.
These changes are welcome, especially for smaller financial firms, that now have an additional six months before reporting commences.
Extended initial reporting deadline for smaller financial firms
Previously, all financial firms were to lodge their first IDR data report with ASIC by 31 August 2023, covering the reporting period 1 January 2023 to 30 June 2023: see our previous article here.
Now, the reporting obligation for smaller financial firms has been deferred by six months, meaning smaller financial firms have until 29 February 2024 to lodge their first report covering the period 1 July to 31 December 2023.
ASIC has staged the requirement to commence reporting into three tranches of reporting financial firms. These are:
First tranche firms: A group of 11 large financial firms lodged their first IDR data report on 28 February 2023 for the reporting period 1 July 2022 to 31 December 2022. The obligation to lodge reports is ongoing for this tranche.
Second tranche firms: A group of approximately 260 large or medium sized financial firms are required to submit their first IDR data reports by 31 August 2023 for the reporting period 1 January 2023 to 30 June 2023. The obligation to lodge reports is ongoing for this tranche after the initial report is lodged. The make-up of the second tranche is listed at Schedule 1 of ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205.
Third tranche firms: This tranche is made up of all reporting financial firms that are not First or Second tranche firms. ASIC estimates that this is about 8600 firms. Third tranche firms are required to submit their first IDR data report by 29 February 2024 for the reporting period 1 July 2023 to 31 December 2023. The obligation to lodge reports is ongoing for this tranche after the initial report is lodged.
All reporting firms have more time to lodge IDR data reports after reporting period ends
In addition, the period for lodging a report (submission window) has now been extended to two months after the end of each reporting period . Previously, there was only a two month submission window for the first reporting period, with a one month for all reporting periods after that.
Summary table of updated IDR data reporting timeline
Other changes
There are several other changes that seek to clarify some of the IDR reporting requirements. These include:
Definition of closed complaint: The definition of “closed” in relation to a complaint has been replaced to clarify that it relates to complaints received by financial firms and does not include complaints that were subsequently reopened by the financial firm and remain open at the time.
Firms to notify ASIC if no complaints: If there are no complaints for which the financial firm is required to give ASIC IDR information for a reporting period, the firm must give ASIC a confirmation that it did not have any complaints for the reporting period. This confirmation must be given within two months after the end of the reporting period.
IDR Data handbook: ASIC has also updated the IDR data reporting handbook based on industry feedback to support firms to consistently report their IDR data. ASIC has additionally detailed the updates in their Overview of changes.
Publication of IDR data by ASIC
ASIC has stated it will not publish IDR data until all financial firms have commenced reporting after 29 February 2024.
What to do now
In our last article on IDR reporting we gave some practical tips on preparing for the new regime.
Contact us if you need help with reviewing your processes, other advice or staff training.