Spreadsheets can support specific compliance activities, but they are generally insufficient as a complete compliance infrastructure solution for most AFS licensees. ASIC’s focus is on the effectiveness of governance, monitoring, oversight and record management. The key issue is whether spreadsheets enable reliable control, accountability, reporting and evidence generation appropriate to the organisation’s size and complexity.
Expanded Answer
Many organisations use spreadsheets to manage compliance registers, monitoring programs, incidents, breaches, risk assessments and reporting activities. For smaller businesses with limited complexity, spreadsheets can provide a practical way to record and track compliance information.
However, spreadsheets are primarily data management tools rather than governance systems. As compliance obligations, staff numbers, and operational complexity increase, spreadsheet-based processes can create challenges with version control, data integrity, access management, auditability, reporting consistency, and oversight. These limitations can make it more difficult to demonstrate effective governance and compliance management.
Key considerations:
- May be appropriate for limited or low-complexity compliance activities.
- Can support registers, tracking activities and basic reporting.
- Often becomes less effective as compliance obligations and governance requirements increase.
- May create risks where compliance processes depend on manual updates or individual knowledge.
The question is not whether spreadsheets are permitted. The question is whether they allow the organisation to demonstrate effective control, oversight and compliance management. Where spreadsheets create visibility gaps, reporting delays or governance weaknesses, infrastructure improvements may be warranted.
Why it matters
Reliance on spreadsheets can increase operational risk if critical compliance information becomes fragmented, inconsistent or difficult to verify. As organisations grow, spreadsheet-based compliance processes may struggle to provide the transparency, accountability and oversight expected by regulators, responsible managers and governance bodies.
Unsure how this applies to you?
If you’re unsure whether your compliance infrastructure is fit for purpose, get a clear answer in a 15-minute call with a compliance specialist. Book your call.
Alternatively, explore [complyᵉ] to see how governance, monitoring, incidents, remediation and oversight can operate as a connected system.
Practical guidance
- Assess whether compliance information stored in spreadsheets can be consistently governed, monitored and reported.
- Review whether multiple versions of compliance records exist across different teams or individuals.
- Test whether governance, remediation and oversight activities can be evidenced without relying on manual reconciliation.
Further reading
What does a defensible compliance framework look like for AFSL and credit licensees?