Finding the Blind Spots in Your
ASIC Transaction Reporting

The High Cost of Passive Reporting

It is incredibly risky to treat transaction reporting as a process you can just set and forget. When reporting errors go unnoticed, they compound.

Just recently, in late 2025, Macquarie Securities admitted to systemic misleading conduct for misreporting millions of short sales over a decade, resulting in an agreed AUD 35 million penalty. This came on the heels of other actions, including an approximately AUD 5 million fine and the discovery of over 375,000 misreported OTC derivative transactions. ASIC specifically pointed to weak compliance controls and poor data governance as the root causes of these long-standing failures.

While it happened a bit further back in 2017, Westpac also faced a penalty of AUD 127,250 for failing to report OTC derivative transactions in a timely manner.

What ASIC Actually Expects

To keep these kinds of data failures from happening, ASIC laid out some very clear expectations. In the ASIC Derivative Transaction Rules (Reporting) 2024 guide, the regulator encourages reporting entities to perform reconciliations at least monthly. This isn't just a suggestion for firms doing their own reporting; it applies even if you outsource the function to a delegate or fund manager.

ASIC wants to see that the outstanding derivative records held by the trade repository perfectly match your own books and records. It's about ensuring both completeness and accuracy. In fact, RG 251.89 goes a step further, noting that best practice involves pulling your transaction, position, collateral and valuation records directly from the trade repository and checking them against your source data, rather than just taking your delegate's word for it.

Who Needs to Be Doing This?

ASIC mentions that this expectation depends on the nature, scale, and complexity of your activities.

In practical terms, Qomply advises that if your portfolio is large enough to require lifecycle reporting, you should be meeting or even exceeding this monthly frequency. For context, the threshold for lifecycle reporting is essentially any licensee with a gross notional outstanding of uncleared derivative transactions over AUD 12bn, which captures all banks and all but the smallest fund managers.

The Hidden Danger of Open Positions

One of the most valuable reasons to run these 30-day reconciliations is to catch lingering open positions. Trades are constantly being modified, canceled, or reaching maturity. If you aren't doing routine, end-to-end checks, a trade that is technically dead might stay open on the regulator's ledger for years. ASIC explicitly warns in RG 251.88 that undetected reporting errors compound over extended periods of time, and the longer a breach goes on, the more inadequate your compliance arrangements look.

This is exactly where Qomply steps in to protect your firm from becoming the next cautionary tale.

Instead of wrestling with manual spreadsheets or blindly trusting a delegate, Qomply’s automated reconciliation engine, DualRec, compares your source data directly against the trade repository. It gives you the operational intelligence to spot those lingering open positions instantly, blending smart automation with deep regulatory know-how to turn a complex monthly chore into a streamlined, defensible process.