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Self-reporting vs Delegated Reporting under ASIC

Australian Securities and Investments Commission

Data Extraction

Data Enrichment

Specialist Advisory

Compliance Support

Reduce Costs

Reduce Costs

Ensuring compliance within your firm can quickly become unweildy. We recommend you consider maximising the effectiveness of your team by using specialist regtech companies. 

The resources (financial, people, technology) required for ongoing compliance need to continually improve processes at an investment firm to stay abreast of changing regulatory requirements.

TRAction understands the struggles that many firms are facing. We have compared the steps required to complete an onboarding process with us as opposed to onboarding with an Australian Derivative Trade Repository (ADTR).

Self-reportingReporting through TRAction
Complete onboarding with the ADTRComplete onboarding with TRAction
Obtain file specifications from the ADTRProvide a file sample or access to data (for automated data transfer)
Review field requirementsWork with the onboarding team to ensure that the data is in the correct format
Test connections to ensure you can submit filesFinalise submission procedures
Populate files and upload to the ADTR in the User Acceptance Testing (UAT) environmentReview the output file and contact TRAction to make any corrections
Review the output file and correct if necessary

Additionally, we have summarised the top 3 ways in which delegated reporting can benefit you and maximise the effectiveness of your team.

Self-reportingReporting through TRAction
Limited Internal Resources


Meeting the reporting requirements may required re-training existing staff or hiring additional staff. The former can divert human resources from existing projects and the latter adds to employment expenses.

Free up Internal Resources


Free up internal resources and allow your team to focus on your firm's core offering.
Burden on Infrastructure


Firms need to spend time and resources to develop ways of generating transaction reports in the correct formats. This in addition to the procurement and storage of all the required data.

Reduce Infrastructure Cost


Limit the infrastructure expenditure you incur. We have IT specialists who can work with your IT team to adjust your systems to be reporting-ready, again without additional charge.
Trade Repository Fees


Firms can directly engage with the ADTR. Charges are generally a fixed monthly or annual account fee plus a per-transaction charge.

Cost Efficiency


Reduce the need to obtain and pay for external advice. At TRAction, we provide regular regulatory guidance in our fees to improve your reporting obligations without engaging expensive external consultants. Best of all, we don't add these charges to our base reporting offering.

When you onboard with us, we offer:

  1. Easy transfer of data – we can either set up direct connection with your platform to extract data or you can provide us with your data files for a seamless transition
  2. High level of expertise – trade reporting is TRAction’s core business offering which means we invest all of our time and energy into streamlining your reporting processes as well as providing guidance on the regulation
  3. Friendly and dedicated team – we have an enthusiastic team with customer-focused mindset which helps us deliver more effective solutions. With our talented staff, we can also provide services in multiple languages if required.

Interested to know more about how TRAction can make your business operations easier? Contact us for a free demo and we can talk you through how to simplify your trade and transaction reporting processes.

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Further Information

Reporting entities need to consider their obligations and put procedures in place which promote compliance with the ASIC Derivative Transaction Rules (Reporting) 2022. Find out more about what needs to be reported.

Under ASIC’s Regulatory Guide (RG) 251, firms reporting OTC derivatives are required to make regular enquiries with their reporting delegate to ensure that the delegate continues to meet its obligations to report your trades (ASIC Reporting Rule 2.2.7).

As a reporting entity, you also need to take all reasonable steps to ensure the completeness, accuracy and currency of the information reported. (ASIC Reporting Rule 2.2.6). Read more about what is required.

ASIC currently requires OTC derivative transactions on CFDs, margin FX and equity derivatives to be reported using the ‘lifecycle’ method.

From 21 October 2024, this will be expanded even further to nearly all OTC derivatives. Read more about the requirements.

Australia’s reporting regime requires both parties to a derivative transaction to report to an Australian Derivative Trade Repository (ADTR). However, there is relief from this principle allowing single-sided reporting, i.e. where only one party is required to report. Read more for further details on single-sided reporting.

Until the commencement of the new ASIC trade reporting rules on 21 October 2024, a reporting entity receives a safe harbour benefit when it appoints one or more persons (each a delegate) to report OTC derivatives on its behalf.

After 21 October 2024, firms can continue to delegate their reporting, however the safe harbour provisions will be mostly removed from the ASIC rules. This means that firms will need to implement greater monitoring and reconciliations of their ASIC trade reporting.

For those firms already delegating their reporting, we encourage you to use this transition period to build an understanding of how to conduct regular reconciliations and monitoring. TRAction have compiled resources for both clients and non-clients. Read more for assistance with this process. 

TRAction has identified common mistakes in ASIC trade reporting data. Ensuring the completeness and accuracy of your ASIC trade reporting is important and hence you should take time to review your reporting process against the list below:

  1. Reporting all trading platforms and systems
  2. Full visibility of your reportable trade accounts (only applicable to clients using MT4 API, MT4 & MT5 linked servers)
  3. Addition of Symbols
  4. Missing or wrong identifier of Non-Reporting Counterparty
  5. Wrong notional amount
  6. Incorrect Datetime/Timestamp format
  7. UTI/USI format in csv file
  8. Not informing your reporting delegate of any addition/removal of liquidity providers
  9. Incorrectly rely on single sided relief

For TRAction’s guidance on how to prevent or rectify the above errors read more.

Are you aware of the penalties for non-compliance with ASIC’s trade reporting rules? To find out about what you can be fined for and how to avoid these read more.

It’s a fair concern and it’s a question we’ve been asked by a few brokers, so we’ve taken the time to answer the questions fully and share with the industry as a whole. In the case that the client is an individual, the ASIC Reporting Rules require a unique ID and the client’s legal name. No phone numbers, emails or address are required in the reports. Read more about what data needs to be provided.

Is the trust or trustee required to obtain a Legal Entity Identifier (“LEI”) under ASIC OTC derivative reporting?  As an Australian reporting entity, if your non-individual clients do not have an LEI, you cannot allow them to enter into an OTC derivatives transaction with you. Read more here.