On the pulse
ASIC renews guidance on managing conflicts of interest in financial services – see media release.
ASIC extends relief for litigation funding arrangements and conditional costs schemes – see media release.
ASIC makes minor updates to expert independence guidance – see guide.
Update to AUSTRAC’s regulatory expectations for implementation of the AML/CTF reforms – see statement.
ASIC
ASIC renews guidance on managing conflicts of interest in financial services
On 16 December 2025, the Australian Securities and Investments Commission (ASIC) announced that it has reissued Regulatory Guide 181 AFS licensing: Managing conflicts of interest (RG 181), which contains ASIC's regulatory guidance on managing conflicts of interest for financial services licensees. RG 181 has been updated to align ASIC's guidance with developments in law and policy and draw on ASIC's regulatory experience and insights from its surveillance of private markets, with key updates including:
How the law applies to conflicts of interest, including the scope of the conflicts management obligation and links to other related obligations.
The types of conflicts licensees should identify and manage.
The need for robust, tailored arrangements to manage conflicts.
Practical steps for effective conflict management.
A non-exhaustive catalogue of related legal obligations and information.
The revised RG 181 replaces guidance issued in August 2004 and is part of ASIC's ongoing regulatory maintenance and simplification agenda.
ASIC makes minor updates to expert independence guidance
On 16 December 2025, ASIC released an updated version of Regulatory Guide 112 Independence of experts (RG 112), which explains how ASIC interprets the requirement that an expert is independent of the party that commissions the expert report and other interested parties (for example, where the target of a takeover bid is required, or chooses, to commission an independent expert report).
ASIC extends relief for litigation funding arrangements and conditional costs schemes
On 17 December 2025, ASIC announced that it is extending the operation of two instruments related to litigation funding until 31 January 2029. ASIC Credit (Litigation Funding-Exclusion) Instrument 2020/37 and ASIC Corporations (Conditional Costs Schemes) Instrument 2020/38 (the Instruments) provide relief for litigation funding arrangements, conditional costs schemes and proof of debt arrangements not covered by exemptions in the Corporations Regulations 2001.
ASIC has issued ASIC Corporations & Credit (Amendment) Instrument 2025/809 to extend the operation of the Instruments. The extension will provide certainty for litigation funders, lawyers and members of litigation funding and proof of debt funding arrangements while the Government considers its policy position for these arrangements.
ASIC consulted on this proposal to extend the operation of the Instruments in Proposed extension of relief for litigation funding arrangements and conditional costs schemes and received two submissions in support of this.
AUSTRAC
Update to AUSTRAC’s regulatory expectations for implementation of the AML/CTF reforms
On 18 December 2025, AUSTRAC published an updated statement detailing that obligations for businesses currently regulated under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation change on 31 March 2026. This update sets out AUSTRAC’s expectations for current regulated businesses in progressing towards implementing these changes and meeting their obligations. It also sets out AUSTRAC’s expectations in respect of implementation plans.
The updated statement builds on, and should be read together with, AUSTRAC’s regulatory expectations for implementation of the AML/CTF reforms of 3 July 2025.
APRA
APRA releases the Annual Superannuation Bulletin for the 2024-2025 financial year
The Annual Superannuation Bulletin reflects key statistics for the superannuation industry as at 30 June 2025 and key statistics for entities with more than six members for the year ended 30 June 2025
See APRA media release.
G+T articles
Merger reforms: Government publishes important amendments ahead of 1 January 2026 commencement – Elizabeth Avery, Haidee Leung, Emily Woolbank and Manus Chauhan (19 December 2025).
Social sector spotlight – December 2025 – Darren Fittler, Elizabeth Wighton (Lathlean), John Vaughan-Williams and Neha Sharma (18 December 2025).
Federal Court orders NDIS provider to pay $500,000 – Peter Munro and David Baddeley (17 December 2025).
Australia reshapes digital asset regulation – Peter Reeves, Georgina Wilcock, Vince Battaglia, Emily Shen, Anthony Basa, Amiinah Dulull and Maya Ruber (17 December 2025).
NDIS in focus: regulatory priorities, restrictive practices and reporting requirements – Peter Munro and David Baddeley (17 December 2025).
Calendar dates
31 March 2026 – Amended AML/CTF obligations commence for existing reporting entities.
31 March 2026 – Tranche 2 entities may enrol as reporting entities with AUSTRAC.
13 July 2026 – Key CDR obligations commence for non-bank lenders.