Chartered Accountants Australia and New Zealand (CA ANZ), CPA Australia and the Institute of Public Accountants (IPA) ( “the Joint Accounting Bodies”) have lodged a joint submission with Treasury supporting improved regulatory visibility of the managed investment scheme (MIS) sector, while calling for new data requirements to be targeted, proportionate and clearly linked to regulatory needs.
The submission supports the objective of giving regulators access to more timely and reliable information to help identify emerging risks. However, the Joint Accounting Bodies caution that enhanced data collection should not become an open-ended expansion of regulatory reporting or inadvertently extend ASIC’s role into prudential supervision of MISs.

We recommend that Treasury apply five key design tests to the framework: regulatory purpose, proportionality, avoiding unnecessary duplication, recognising the availability of data, and appropriate governance of information collected.

A central recommendation is for government agencies to adopt a “collect once and reuse” approach. Where equivalent information is already held by ASIC, the Australian Bureau of Statistics, Australian Taxation Office, APRA or another Commonwealth agency and can lawfully be shared. The government should consider reusing that information before imposing new reporting obligations.

The submission also supports recurrent reporting for registered MISs in principle but argues against automatically requiring every data field to be reported quarterly. Reporting frequency should instead reflect the regulatory value and nature of the information. For unregistered wholesale MISs, additional reporting should remain targeted and proportionate.

The Joint Accounting Bodies also emphasise protecting personal, confidential and commercially sensitive information and distinguishing between information required by regulators and information suitable for public release. We recommend co-designing and testing the framework with affected entities, providing appropriate transition arrangements and reviewing its effectiveness after implementation.