No. ASIC does not explicitly require AFS licensees to implement automated monitoring or surveillance systems. ASIC expects licensees to have effective compliance and supervision arrangements, but remains technology-neutral. Automated systems may support these outcomes, but manual processes are acceptable if they are adequate and operate effectively.
Expanded Answer
ASIC’s expectations focus on outcomes rather than specific tools. AFS licensees must maintain adequate systems for monitoring adviser conduct, supervising representatives, and identifying and reporting breaches. This includes processes for detecting misconduct, escalating issues, and taking corrective action. However, ASIC does not mandate automation or prescribe surveillance technology.
In practice, automated monitoring systems are often used to improve consistency, coverage, and timeliness—particularly in larger or more complex businesses. These systems can assist with identifying patterns, flagging anomalies, and supporting real-time oversight. That said, manual monitoring can still meet ASIC expectations when it is structured, well-documented, and sufficiently resourced.
Regulatory risk increases where monitoring is inconsistent, delayed, or unable to detect issues in a timely way. As scale and complexity increase, reliance on purely manual processes may become harder to justify.
Why it matters
Weak monitoring and supervision are common drivers of compliance failures. If licensees cannot demonstrate effective oversight, ASIC may question whether they are meeting their obligations, particularly where misconduct or reportable situations are identified late.
Practical guidance
- Assess whether current monitoring processes can detect issues consistently and in a timely manner
- Introduce automation where it improves coverage, efficiency, and escalation of risks
- Document and test monitoring frameworks to demonstrate effectiveness