CA ANZ has responded to ASIC’s consultation (CS 54), which proposes consolidating 14 financial reporting and 3 auditing legislative instruments into two consolidated instruments.

ASIC first proposed this concept in its Regulatory Simplification consultation (REP 813) back in September 2025, with a pilot that proposed consolidating 21 of the 25 financial reporting and auditing instruments into one. In our submission to that consultation we recognised that the proposal had both benefits and drawbacks. ASIC’s Regulatory Simplification progress report (REP 830) noted that most stakeholders supported consolidation, but some recommended keeping financial reporting and audit instruments separate. Although feedback has been implemented, some members suggested dividing the draft financial reporting instrument into smaller, more manageable, instruments because it covers such a broad range of topics.

A key concern is the lack of clarity around which instruments are excluded from the consolidation. Transparency over the excluded instruments, and the reasons for their exclusion, would help stakeholders assess ASIC’s decisions.

CA ANZ continues to recommend that ASIC enhances its regulatory index, allowing users to search for legislative instruments by topic, and/or create a dedicated webpage listing all financial reporting and audit instruments. This approach would improve navigation and reduce the risk of non-compliance with the instruments that are not included in the consolidation.

Finally, CA ANZ urges ASIC to carefully consider the timing of any changes, noting that implementing changes during reporting season could create challenges for members.