ASIC has approved a no-action stance to instantly decrease small banks’ internal dispute resolution (IDR) data reporting from six months to one year. Following its Review of Small and Medium-sized Banks, the Council of Financial Regulators (CFR) proposed changing IDR reporting frequency to lower regulatory costs for small banks and make them more competitive. 
 

ASIC has proactively taken the no-action position before formalising technological and system improvements in 2027. Small banks are exempt from the upcoming IDR data submission window, per the class no-action letter.  
 

ASIC does not expect to take action against small banks for failing to submit an IDR report in the January-February 2026 and 2027 filing windows, under Instrument 2022/205. The no-action letter details the no-action position and which small banks are covered. Third parties can sue for that activity despite the no-action letter. 

Oct 2025