“Well, what’s the use in complaining
when you’ve got what you don’t need” — New Order, “Run 2”, 2005
Are your IDR reports ASIC-ready every six months?
The Treasury Laws Amendment (Putting Consumers First – Establishment of the Australian Financial Complaints Authority) Act 2018 (AFCA Act) reshaped the financial services dispute resolution framework. The AFCA Act provided ASIC with additional powers with the aim of improving transparency around internal dispute resolution (IDR). These reforms;
- require financial firms to report their IDR activities to ASIC in accordance with ASIC requirements
- give ASIC the power to determine the content and form of IDR reporting; and
- enable ASIC to publish the IDR data, including at the firm level.
Most firms are now in ongoing six-monthly IDR reporting, with reports due through ASIC’s Regulatory Portal after each reporting period.
If you fail to submit your IDR data before the deadline, you will be in breach of the IDR reporting requirements, which may have serious consequences, including civil penalties.
Who must report IDR data to ASIC?
ASIC requires the following to submit reports:
- All Australian Financial Service Licensees with authorisation to provide advice to retail clients;
- All Australian Credit Licensees;
- Unlicensed product issuers and unlicensed secondary sellers; and
- Superannuation trustees.
Has IDR reporting commenced?
In March, 2022 11 large financial firms (initial tranche) were chosen to lodge their first IDR data by 28 February 2023, for the reporting period 1 July 2022 to 31 December 2022.
Reporting deadline for all other financial firms?
ASIC introduced a staged approach for the remaining financial firms (those not in the initial cohort), being:
Reporting period: 1 July 2022 to 31 December 2022. Who: Initial tranche. Deadline for lodgement: 28 February 2023
Reporting period: 1 January 2023 to 30 June 2023. Who: Second tranche. Deadline for lodgement: 31 August 2023
Reporting period: 1 July 2023 to 31 December 2023. Who: Third tranche. Deadline for lodgement: 29 February 2024
This means all Licensees will be reporting their IDR data to ASIC by the end of February 2024. The updated timeline provides Licensees with more time to prepare for this reporting obligation.
What is the deadline for IDR reporting?
A reporting period is defined as a period of 6 months, ending:
- 30 June; and
- 31 December.
As mentioned earlier, ASIC has provided an extension for your initial IDR lodgement, meaning Licensees have 2 months after the end of the reporting period to lodge their data. All future reporting periods must lodge by the end of the following calendar month, the table below will help Licensees in the third tranche:
Reporting period: 1 July 2023 to 31 December 2023. Deadline for lodgement: 29 February 2024.
Reporting period: 1 January 2024 to 30 June 2024. Deadline for lodgement: 31 July 2024.
Reporting period: 1 July 2024 to 31 December 2024. Deadline for lodgement: 31 January 2025.
What complaints need to be reported?
ASIC has specified the data to be included within your reporting period. Licensees should report on:
- Complaints covered by your IDR procedure, and
- Complaints made either in the reporting period, or complaints open at any time during the reporting period.
ASIC has noted that complaints received before the beginning of the first IDR reporting period should not be included within your data. Meaning third tranche firms will not include data about complaints received before 1 July 2023, this includes complaints that are open at the start of the initial reporting period.
In the event a client escalates their complaint to AFCA after going through your IDR process, the IDR complaint is included within reporting for that period. Any revised outcomes, timeframes or other details about the complaint at EDR level (AFCA) will be out of scope for IDR reporting, i.e. you do not include the complaint again.
What happens if there is no complaint data for the reporting period?
Licensees will still be required to submit a ‘nil submission’ through ASIC’s Regulatory Portal. ASIC’s IDR data reporting handbook provides Licensees with step-by-step guidance.
What data is required?
ASIC released the IDR Data Reporting Handbook, which sets out the mandatory IDR data reporting obligations, including how to collate IDR data and lodge it with ASIC.
The handbook provides Licensees with information on:
- the data reporting process;
- the IDR data dictionary;
- the IDR data glossary; and
- step-by-step instructions on how to submit IDR data to ASIC via the ASIC Regulatory Portal.
Licensees should familiarise themselves with the requirements, formatting and codes to ensure your IDR report will meet ASICs requirements for lodgement. To successfully submit an IDR report your report must pass two stages of validation before being accepted by ASIC. Until a report has passed both of ASIC’s validation checks, it will not be deemed to have been lodged. ASIC will send an email notifying firms if their submissions has passed or failed the deep validation.
For those clients that have subscribed to [complye], you will be pleased to know our system is coded and ready to report when you are.
For those clients that haven’t subscribed to [complye], well, I am afraid you will need to familiarise yourself with ASIC’s additional resources:
- IDR Data Reporting Excel template
- IDR Validation Rules examples
- IDR data reporting handbook; and
- ASIC FAQs
Treat the complaint register as the source record, not a spreadsheet created at deadline. If the register does not capture ASIC-required fields as complaints arise, lodgement becomes reconstruction rather than reporting.
IDR reporting for multiple licence holders
Where a parent company has multiple subsidiaries with AFSLs, it cannot submit a consolidated or aggregated IDR report. Each AFSL will need to submit their own IDR report to ASIC.
AFSLs that hold both an AFS licence and a Credit licence (with the same number) are able to submit a consolidated report to ASIC each reporting period.
IDR information published by ASIC
ASIC now publishes IDR data through its IDR data dashboard. The dashboard gives Licensees, consumers and regulators greater visibility over complaint volumes, products, issues and outcomes across the financial system. ASIC’s updated dashboard also includes demographic information and downloadable data for benchmarking, reporting, and trend analysis.
ASIC will analyse the IDR data as it receives the information and will communicate its final approach well in advance of publication.
What this means in practice
The amendment should make one clear point: IDR data has become a supervision signal. ASIC can use it to identify outliers. Licensees can use it to identify weaknesses before ASIC does.
What should you be doing now?
IDR reporting is now part of the normal compliance cycle. The key issue is no longer whether the first reporting deadline is approaching. It’s about whether your complaint framework captures reliable data, supports timely reporting, and helps you identify conduct, service, and systemic issues before they become larger problems.
Licensees should review whether their IDR process still meets RG 271 and whether staff are applying it consistently. This includes confirming that complaints are identified correctly, acknowledged on time, recorded accurately, resolved within the required timeframes, and escalated when they indicate broader risk.
Your complaint register should capture all information needed for ASIC IDR reporting. It should also support internal analysis. At a minimum, it should allow you to identify complaint volumes, products, issues, outcomes, timeframes, responsible business areas, recurring causes and potential systemic issues.
Staff should remain clear about the definition of a complaint. A complaint is not limited to a formal written grievance. It can arise through calls, emails, online forms, adviser interactions, review meetings and informal expressions of dissatisfaction where a response or resolution is expected. Training should reinforce when matters must be recorded, when they must be escalated and how staff should distinguish complaints from general enquiries.
Licensees should also benchmark their complaint data against ASIC’s IDR dashboard. ASIC’s updated dashboard includes complaint volumes, products, issues, outcomes and demographic indicators by age group, gender and location, together with downloadable data for reporting, benchmarking and trend analysis. This gives Licensees a practical way to compare their own complaint profile against broader industry patterns.
That comparison should be used in compliance reporting, board papers, breach assessment, adviser supervision, product governance and remediation activity. A low complaint count should not be assumed to mean good performance. It may indicate strong service, but it may also indicate poor complaint identification, under-reporting or weak escalation. Higher complaint volumes may indicate problems, but they may also reflect better capture and a healthier complaints culture.
In practice, Licensees should now be asking:
- Are we identifying complaints consistently?
- Are we lodging complete and accurate IDR data?
- Are complaint trends being reported to management and the board?
- Are recurring issues being assessed for systemic impact?
- Are complaint themes being linked to breach reporting, monitoring and remediation?
- Are our complaint volumes and outcomes materially different from comparable industry data?
If the answer to any of these questions is unclear, the IDR framework should be reviewed before the next reporting cycle.
ASIC’s IDR dashboard changes the value of complaint data
ASIC has now moved beyond collecting IDR data. It has updated its IDR data dashboard with complaints opened, received or closed between 1 July and 31 December 2025. The dashboard shows aggregated complaint volumes, products, issues and outcomes across the financial system. It also includes demographic data by age group, gender and location, and ASIC has released a downloadable data file for reporting, benchmarking and trend analysis.
That matters because IDR data is no longer just a regulatory submission. It is now a comparative governance tool. Licensees can use ASIC’s published data to assess whether their complaint volumes, issue types, products, closure outcomes and timeframes are broadly consistent with industry patterns or indicate potential outliers.
For boards, Responsible Managers and compliance teams, the practical question is not simply whether the IDR report was lodged on time. The better question is whether the complaint data says anything about service failures, advice quality, product governance, vulnerable clients, systemic issues or emerging conduct risk.
A low number of complaints should not be treated as automatic evidence of good performance. It may indicate effective service. It may also indicate poor complaint identification, under-reporting, weak staff training or a culture that discourages escalation. Equally, higher complaint volumes are not necessarily a failure if they reflect better capture, clearer client pathways and stronger internal escalation.
Licensees should use ASIC’s dashboard before each reporting cycle to benchmark their own complaint profile against broader industry data, identify recurring issues, test whether complaint categories are being used consistently and improve board reporting. Complaint data should be connected to breach reporting, monitoring, adviser supervision, product governance and remediation processes.
ASIC’S IDR Dashboard
Figure 1: ASIC’s Internal Dispute Resolution (IDR) data dashboard provides aggregate complaint statistics across financial firms, including complaint volumes, resolution times, product categories and outcomes. Firms can filter the dashboard by reporting period, product and individual licensee.
ASIC’s dashboard is more than a public reporting tool. It allows licensees to benchmark their complaint profile against industry trends. While complaint numbers alone don’t indicate poor performance, unusually high complaint volumes, extended resolution times or concentrations in particular products or issues may indicate weaknesses in processes, training or governance that warrant further review.
Explore ASIC’s live Internal Dispute Resolution Data Dashboard to compare industry complaint trends and view firm-level reporting.
A high complaint count does not necessarily indicate poor performance. It can reflect a firm’s size, product offerings, or complaint recording and reporting practices.
ASIC cautions that complaint volume should not be interpreted in isolation. Larger firms naturally receive more complaints, while differences in products, customer numbers, and complaint-recording practices can significantly influence the figures. The more useful comparison is often the trend in complaints over time, resolution performance, and the underlying causes of complaints.
Managing Reporting Risk
Complaint data is no longer just something you lodge with ASIC. It is evidence of how well your business identifies client dissatisfaction, escalates risk and responds to emerging conduct issues.
If you are unsure whether your IDR framework is capturing the right information, or whether your complaint data would stand up to ASIC scrutiny, we can help.
Talk to Assured Support about reviewing your IDR process, complaint register and reporting controls before your next lodgement cycle.
Further reading
Frequently Asked Questions
Most Australian financial services licensees (AFSLs) and Australian credit licensees (ACLs) that provide services to retail clients are required to submit internal dispute resolution (IDR) data to ASIC. The obligation extends beyond simply handling complaints—it requires firms to report prescribed complaint information through ASIC’s Regulatory Portal every six months, even where no reportable complaints have been received in some circumstances.
The obligation is designed to give ASIC greater visibility of complaint trends, emerging consumer issues and whether firms are complying with Regulatory Guide 271 (RG 271). It also allows ASIC to identify systemic issues that may warrant further regulatory attention.
If your complaints process relies on manual spreadsheets or inconsistent record keeping, producing an accurate submission can quickly become difficult. Your complaints register should therefore capture all required reporting fields as complaints are received, rather than reconstructing the information at reporting time.
Having no complaints does not necessarily mean you have no reporting obligations. Many licensees are still required to lodge a nil IDR submission through ASIC’s Regulatory Portal for the relevant reporting period.
Nil reporting provides ASIC with confirmation that a firm has met its reporting obligation and allows ASIC to distinguish between firms that genuinely had no complaints and firms that simply failed to report.
Before lodging a nil return, you should confirm that your organisation has applied the RG 271 definition of a complaint consistently across all business areas. Informal expressions of dissatisfaction, complaints resolved at first contact and complaints received through different business channels should all be assessed against the regulatory definition rather than internal assumptions.
A nil submission should be the result of good governance—not the discovery that no one was recording complaints.
ASIC requires IDR data to be reported every six months. Reporting periods run from 1 January to 30 June and from 1 July to 31 December, with submissions lodged through ASIC’s Regulatory Portal during the applicable reporting window.
Rather than viewing reporting as a twice-yearly compliance exercise, licensees should treat complaint reporting as an ongoing governance process. Complaint data should be reviewed throughout the reporting period so emerging trends, recurring root causes and systemic issues can be identified well before a submission is due.
Firms that maintain accurate complaint records throughout the year generally find reporting straightforward. Those relying on end-of-period data collection often encounter validation errors, missing information and unnecessary remediation work.
Most reporting issues are caused by poor data quality rather than problems with ASIC’s reporting system. Common issues include complaints being recorded inconsistently, mandatory data fields being left blank, incorrect complaint classifications, inaccurate dates and outcomes that do not align with ASIC’s reporting taxonomy.
Many organisations also discover that complaints have been captured differently across advisers, customer service teams and compliance staff, making the final submission difficult to reconcile.
The most effective way to avoid these issues is to build reporting requirements into the complaints process itself. If complaint information is collected correctly at the time the complaint is received, reporting becomes largely administrative rather than investigative.
Regular reviews of complaint data can also identify process weaknesses before they affect reporting accuracy.
Complaint data is one of the most valuable governance datasets available to a licensee. While it satisfies ASIC’s reporting requirements, it also provides early warning of operational weaknesses, adviser conduct issues, product problems and customer service failures before they develop into systemic compliance breaches.
Analysing complaint trends can reveal recurring root causes, ineffective controls, training gaps and areas where client expectations are not being met. Combined with breach reporting, file reviews and risk monitoring, complaint data becomes an important indicator of an organisation’s overall compliance health.
Organisations that treat complaints simply as an administrative obligation often miss these insights. Those that actively analyse complaint data are better positioned to improve customer outcomes, strengthen governance and demonstrate to ASIC that their compliance framework is operating effectively.
