The first internal dispute resolution data (IDR Data) reporting period for the vast majority of financial firms (which includes AFS licensees and Australian credit licensees), being 1 January to 30 June, is now well underway.

Background

Last year, ASIC published the IDR Data Reporting Handbook (Handbook) which, in conjunction with ASIC Regulatory Guide 271 (Internal dispute resolution), published in 2021, sets out the framework and requirements for financial firms who must record and report IDR Data.

Since October 2021, financial firms have been required to keep an effective record of all complaints received.

What’s changed?

Fast-forward to 28 February 2023, 11 large financial firms (including the 4 big banks) will be the first to report that IDR Data to ASIC.

By 31 August 2023, all other financial firms will be required to report IDR Data to ASIC, for the period 1 January to 30 June 2023.

The changes require a lot of information regarding complaints to be recorded, in a very specific manner, for reporting purposes.

What information do financial firms need to record?

Each six-monthly report to ASIC must cover complaints required to be covered by an entity’s IDR procedure which are made in the reporting period, or not closed as at the start of the reporting period. This does not include complaints received before the beginning of each financial firm’s first reporting period – which for all but the 11 large financial firms, are complaints received prior to 1 January 2023.

Details required to be recorded and subsequently reported for various complaint types are set out in the Handbook and include many types of information that financial firms are not likely to have collected before now. Financial firms should refer to the IDR data glossary in the Handbook to ensure accurate and consistent reporting. This provides instructions on how to classify the product or service that the complaint is about, the issue raised by the complaint, and the outcome of the complaint.

What recording format is required?

When reporting to ASIC, the report must be in CSV format. ASIC have provided an IDR Data Reporting Excel Template spreadsheet here, which is pre-filled with the correct machine-readable headers.

While this was designed for small financial firms (that do not have their own customer relationship management system, or software for recording complaints), this is likely a helpful tool for all financial firms to cross check compliance.

How and when to lodge the IDR Data?

Financial firms must lodge their IDR Data via the ASIC Regulatory Portal every six months, for the two reporting periods:

• 1 January to 30 June; and
• 1 July to 31 December.

Financial firms may submit a single report, even if they hold multiple licenses (for example, an AFSL and an ACL).

Ordinarily, entities must lodge their IDR Data with ASIC by the end of the following calendar month of each reporting period. However, ASIC has temporarily extended this lodgement deadline to within two months after the end of the reporting period.

Next steps

ASIC will begin publishing IDR Data after 31 August 2023. Financial firms must establish a compliant recording and reporting system for complaints.