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Our IndustryIndustry Resources + GuidesACSA endeavours to keep its members and the industry up to date with relevant information affecting the custody industry. On this page you’ll find helpful guides, whitepapers and links to regulators and associations. The Role of the CustodianHow custodians support Australia’s wholesale superannuation and investment sectorsWholesale custodians exist to provide services to institutional investors, reduce uncertainty faced by asset owners, and support critical elements of investment infrastructure. These services reduce the frictional costs of investing, lower risk and improve efficiency through scale, expertise and technology investment. Institutional investors - in the form of superannuation funds, unit trust managers and life insurance companies - are the guardians of a significant portion of the wealth of ordinary Australians. Through the services provided to these institutions, the custodian’s role indirectly benefits individual investors and adds efficiency and safety to the wealth management industry. Read the document here Watch the full version here Video Series: Custody + Investment Services
WhitepapersT+1 Position PaperAs the financial landscape evolves, the Australian Custodial Services Association (ACSA) continues to be at the forefront of discussions surrounding market infrastructure and settlement practices. In this rapidly changing environment, the topic of T+1 settlement has emerged as a significant point of interest and debate. The move towards T+1 settlement represents a potential paradigm shift in how transactions are settled in the Australian market. It promises benefits such as reduced counterparty risk, increased efficiency, and enhanced market liquidity. However, it also raises questions and considerations that warrant thorough exploration and analysis. To gain deeper insights into the sentiments and perspectives, ACSA conducted a survey of ASX participant members aimed at capturing their thoughts and opinions on T+1 settlement. This survey sought to understand the potential implications, challenges, and opportunities associated with transitioning to a T+1 settlement cycle. The following paper presents the findings from this survey, providing a detailed overview of the diverse range of viewpoints expressed by our members. It is important to note that the views presented in this paper reflect the opinions of the respondents to the survey. Read MoreFrom vulnerability to resiliency - Insights on cyber, data and information security in a time of uncertaintyIn the wake of highly publicised cyber breaches among Australian corporations and the release of the Australian Prudential Regulation Authority (APRA) Prudential Standard CPS 230 Operational Risk Management, the Australian Custodial Services Association (ACSA) held a Cyber Roundtable on cyber, data and information security risks and best practice among the investment community. ACSA’s 2023 roundtable brought together cyber security experts from financial services firms across the globe. This paper shares their key insights and looks at:
This Practice Guide will be updated from time to time as required. Read More GuidesCPS 230 Operational Risk - Scenario TestingAustralian Prudential Regulation Authority (“APRA”) released the final CPS 230 (“CPS 230”) Operational Risk Management Prudential Standard (“Prudential Standard”) in July 2023 and the accompanying Prudential Practice Guide (“PPG”) in June 2024. The Prudential Standard is effective from 1 July 2025 and introduces substantial changes to the way APRAregulated entities are to oversee and manage arrangements with services providers, including custodians. with certain requirements in CPS 230 relating to business continuity and scenario analysis. For pre-existing contracts with service providers, CPS 230 will apply from the earlier of the next contract renewal date or 1 July 2026. APRA have indicated its expectations that APRA-regulated entities identify their critical operations and material service providers by mid-2024 and set their tolerance levels by end of 2024. APRA also included a “Day 1” checklist for entities to assist in their implementation of CPS 230. Refer to Figure 3. The checklist clarifies what information entities are not required to provide to APRA for Day 1 compliance (but which may be requested by APRA). For example, entities are not required to submit their list of critical operations or tolerance levels to APRA on Day 1 nor risk profiles or operational and senior accountabilities. Read MoreCPS 230 Operational Risk - Tolerance LevelsAustralian Prudential Regulation Authority (“APRA”) released the final CPS 230 (“CPS 230”) Operational Risk Management Prudential Standard (“Prudential Standard”) in July 2023 and the accompanying Prudential Practice Guide (“PPG”) in June 2024. The Prudential Standard is effective from 1 July 2025 and introduces substantial changes to the way APRAregulated entities are to oversee and manage arrangements with services providers, including custodians. with certain requirements in CPS 230 relating to business continuity and scenario analysis. For pre-existing contracts with service providers, CPS 230 will apply from the earlier of the next contract renewal date or 1 July 2026. APRA have indicated its expectations that APRA-regulated entities identify their critical operations and material service providers by mid-2024 and set their tolerance levels by end of 2024. APRA also included a “Day 1” checklist for entities to assist in their implementation of CPS 230. Refer to Figure 3. The checklist clarifies what information entities are not required to provide to APRA for Day 1 compliance (but which may be requested by APRA). For example, entities are not required to submit their list of critical operations or tolerance levels to APRA on Day 1 nor risk profiles or operational and senior accountabilities. This guidance note continues the work of The Australian Custodial Services Association (“ACSA”) and buildson the issuance of its CPS 230 Guidance Note on Critical Operations issued in July 2024 and Tolerance Setting in December 2024 Read More CPS 230 Operational Risk - Oversight ArrangementAustralian Prudential Regulation Authority (“APRA”) released the final CPS 230 (“CPS 230”) Operational Risk Management Prudential Standard (“Prudential Standard”) in July 2023 and the accompanying Prudential Practice Guide (“PPG”) in June 2024. The Prudential Standard is effective from 1 July 2025 and introduces substantial changes to the way APRAregulated entities are to oversee and manage arrangements with services providers, including custodians. with certain requirements in CPS 230 relating to business continuity and scenario analysis. For pre-existing contracts with service providers, CPS 230 will apply from the earlier of the next contract renewal date or 1 July 2026. This guidance note continues the work of The Australian Custodial Services Association (“ACSA”) and builds on the issuance of its CPS 230 Guidance Note on Critical Operations issued in July 2024 and Tolerance Setting in December 2024 Read More CPS 230 Operational Risk - Critical operationAustralian Prudential Regulation Authority (“APRA”) released the final CPS 230 (“CPS 230”) Operational Risk Management Prudential Standard (“Prudential Standard”) in July 2023 and the accompanying Prudential Practice Guide (“PPG”) in June 2024. The Prudential Standard is effective from 1 July 2025 and introduces substantial changes to the way APRAregulated entities are to oversee and manage arrangements with services providers, including custodians. with certain requirements in CPS 230 relating to business continuity and scenario analysis. For pre-existing contracts with service providers, CPS 230 will apply from the earlier of the next contract renewal date or 1 July 2026. APRA have indicated its expectations that APRA-regulated entities identify their critical operations and material service providers by mid-2024 and set their tolerance levels by end of 2024. APRA also included a “Day 1” checklist for entities to assist in their implementation of CPS 230. Refer to Figure 3. The checklist clarifies what information entities are not required to provide to APRA for Day 1 compliance (but which may be requested by APRA). For example, entities are not required to submit their list of critical operations or tolerance levels to APRA on Day 1 nor risk profiles or operational and senior accountabilities. The impact of CPS 230 on the members of the Australian Custodial Services Association (“ACSA”), as material service providers to many APRA-regulated clients (“ACSA member clients”), will be significant, increasing client expectations with respect to reporting, escalation, access, and data. Whilst not all ACSA members are regulated by APRA, custodians are captured under CPS 230 as a Material Service Provider. This Guide will be updated from time to time as required. Read More A Practice Guide on Stronger Super.....for Australian asset owners and managersIn 2009, the Federal Government commenced its review, the “Cooper Review”, into the superannuation sector – Super System Review. The key outcomes of this review were:
Introduction of the significant reforms (referred to as Stronger Super) has resulted in improved and increased regulatory oversight by the regulatory bodies. New disclosure and reporting requirements have necessitated the need for a consistent approach by industry participants. To this end, ACSA established the Stronger Super Task Force to collaboratively review
reporting requirements and determine the best way to efficiently and pragmatically fulfil them. This Practice Guide brings together the outcomes of the industry collaboration and engagement with APRA to provide a description of the approach that ACSA expects members to implement in providing their own response to the Stronger Super regime, especially as regards the RSE regulatory reporting. By its very nature, this Practice Guide is general in nature and does not look to take into account every possible circumstance. It is still the responsibility of each RSE and custodian to perform their own independent assessment and if necessary secure their own independent advice on the regulations and ensure their own individual compliance to the regulations. This Practice Guide aims to summarise the outcome of the collaboration to date to give wider industry transparency. ACSA expects all members to be compliant with the outcomes described in this guide or otherwise be able to explain to an RSE client their rationale for any areas of non-compliance.
This Practice Guide will be updated from time to time as required. Read More Suspicious Matter and Breach ReportingAs providers of custodial and depository services, ACSA members will typically have obligations in their master custody agreements (or equivalent document) to notify a responsible entity (“the Client”) of material
or systemic breaches of the agreement. The requirement to have such provisions in the agreement is reinforced by Regulatory Guide 133 – Managed investments and custodial or depository services: Holding assets
(RG 133). Further, ACSA members in the provision of custodial and depository services will hold an Australian Financial Services Licence (AFS Licence) authorising the provision of these services. In addition to obligations imposed on ACSA members to report significant breaches under s912D of the Corporations Act 2001 (Cth) (Act), RG 133 extends the requirement such that agreements between the Client and the custodian must contain provisions to the effect that the custodian must establish and maintain adequate arrangements to ensure that if the custodian suspects a Client (also being the holder of an AFS Licence) has not met its own obligations under the Act to report a significant breach of the Client to ASIC, then the custodian will make the necessary report to ASIC within 10 business days. Such required arrangements are not the source of any obligation to make enquiries, however, the custodian may eg. in the ordinary course of business or from another source, have both the knowledge of that breach and form such a suspicion. Read MoreACSA RG133 Industry Guide – Omnibus Account SectionAs outlined in Section F of ASIC RG133, generally unless an exemption applies, ASIC expects that a responsible entity (R.E.) holding scheme property on trust must ensure that the property is (a) clearly identified
as scheme property and (b) held separately from the RE’s own property and the property of any other scheme. Similar obligations also apply to custodians holding scheme property. However ASIC has acknowledged that in some circumstances it may not be appropriate to separate assets from those of other persons or schemes, as this may be inconsistent with market practice where it is likely to substantially add to the cost of holding scheme property. Read MoreSpecial Custody AssetsASIC Class Order 13/1413 amending Class Order 13/760 (Class Order) broadly states that Responsible Entities (REs) that do not meet the minimum net tangible assets (NTA) requirements of an NTA (the greater of A$10m or 10% of average RE revenue of the licensee) are required to hold assets with a custodian. The Class Order provides limited relief from this obligation for certain assets meeting the definition of a ‘special custody asset’ (such as derivatives) upon satisfying certain conditions as prescribed in the Class Order. Read MoreTax Data StandardThis document sets out a standard data set and common market practice guidelines for automating the exchange of Australian managed fund tax data. Use of the standard will benefit both publishers and recipients
of tax data (and ultimately end investors) by improving operational efficiency and reduced risks. The objective an operating environment where fund tax data elements are digitally exchanged and can be interpreted
without ambiguity driving greater integrity, timeliness and consistency of tax data for distributions, withholding taxes, annual tax statements and regulatory reporting obligations. The intended users of the standard are organisations that exchange tax data, including:
Access the Tax Data Schema here. See Tax Return and AIIR mapping for 2021 here. Tax Data StandardDeferred DividendsIn early 2020 a significant number of listed companies cancelled or deferred dividends. This is understandable in the environment of extreme uncertainty that prevailed under COVID-19 and related measures, escalating business impact and the need for companies to preserve cash. Notwithstanding the needs of companies to retain flexibility in extraordinary circumstances, cancellation and deferrals of dividends has significant down-stream impact to investors. This communique outlines impacts and encourages dialogue with stakeholders to identify lessons learned and opportunities for potential positive change. Read MoreMandatory Use of Cheques - Corporate ActionsThe mandated use of cheques (to the exclusion of electronic payment alternatives) creates inefficiency and risk for institutional investors and their administration service partners (including custodians and registries). Risks and time delays have been amplified by Pandemic disruptions to the operating environment. This communique is intended as a general reference and to assist in communicating to clients, listed companies and their corporate advisers on the down-stream implications to investors of mandating the use of cheques to the exclusion of electronic alternatives. ACSA encourages listed companies to work with their corporate advisers and share registries to offer electronic payment and receipt mechanisms for all corporate event types and avoid the mandated use of cheques. Mandatory Use of ChequesACSA Practice Guide PHD ReportingACSA Practice Guide on the Implementation of Portfolio Holdings Disclosure (“PHD”) Reporting. The recommendations of the Cooper Review were handed to Government in 2010 and formed the basis for the Stronger Super reforms, which were targeted at the superannuation industry. The Cooper Review made recommendations aimed at improving the superannuation system’s focus on operating in members’ best interests, leading to a series of reforms to the regulatory framework for superannuation funds. In relation to transparency, the Cooper Review specifically recommended a complete PHD regime. Improved disclosure on portfolio holdings will enable members to communicate their preferences to funds about exposure to certain asset classes. This should promote efficiency and enhance competition. If a member is dissatisfied with the asset classes of their investment option, they can switch to an alternative investment option, or change superannuation providers. Enhanced transparency supports superannuation funds being more accountable for their requirement to act in the best financial interests of members. Although Custodians are not required to report PHD to the Australian Securities and Investments Commission (“ASIC”) themselves, they do prepare PHD reporting on behalf of their registrable superannuation entities (“RSEs”) clients. ACSA has been working closely with both ASIC and the Australian Prudential Regulatory Authority (“APRA”) to resolve interpretation issues and establish pragmatic reporting solutions to meet these disclosure requirements. This practise guide aims to summarise the outcome of these workshops to give the wider industry transparency on how the regulatory reporting requirements are being practically implemented. ACSA expects all members to be compliant with the outcomes described in this guide or otherwise be able to explain to an RSE client their rationale for any areas of non-compliance. PRACTICE GUIDE PHD REPORTINGRegulators
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1/10/2025ACSA Industry Wrap - September 2025
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