What ASIC’s Roadmap Means for Compliance Teams  

Earlier this month, the Australian Securities and Investments Commission (ASIC) released a consequential set of responses to industry feedback regarding the evolution of capital markets in Australia. The document, Report 823, Advancing Australia’s evolving capital markets, outlines ASIC’s priorities, including reforms in private credit, data reporting and transparency, and market infrastructure. It presents a forward-looking view for any firm operating in or connected to the Australian market as well as thoughtful considerations for any globally regulated firm. 

At a high level, ASIC looks to reframe oversight around a few critical questions:  

• Who knew what and when?  
• How did that information move through the firm?  
• Were conflicts properly identified and managed?  
• And did any of it leak into prices, allocations, or client outcomes? 

That framing applies to private markets, superannuation, the reporting and transparency of structured data like strategies, valuations, and fund flows, and public markets. It proposes a behavioral shift that brings comms surveillance functions into focus, particularly with how they monitor communications, manage conflicts, and evidence decision-making patterns. 

What’s On ASIC’s Radar 

Before we jump into the details, here’s a quick snapshot of the direction ASIC is headed:  

1. Private markets, ASIC is pushing for higher standards in wholesale funds: clearer duties, stronger conflicts controls, simpler and more transparent fees, more robust valuations and better liquidity management. 
2. Data reporting, the paper recommends structured, recurrent and machine-readable information about funds and market activity, and is preparing pilots and possible law reforms to get there. 
3. Superannuation, trustees are treated as central transmission points between private markets and the real economy, with scrutiny concentrated on valuations, performance monitoring and disclosure. 
4. Public markets, ASIC is focused on declining listings, the resilience of market infrastructure and “market cleanliness” across equities, government and corporate bonds, and take-private deals. 

At Shield, we see all of these risks converge in the same place: digital communications. Whether it’s side letters, fee discussions, allocation preferences, or mentions of MNPI, these decisions are regularly hashed out in chats, emails, voice calls and collaboration tools. That’s exactly where AI-powered communications surveillance and information barrier monitoring become critical. They elevate policy into practice, and practice into evidence. 

The section below explore each theme and show how surveillance can help you satisfy not just to the letter of ASIC’s direction, but to its spirit.

Private Markets and the Governance Lift in Wholesale Funds 

Wholesale funds and private credit products are under heavier scrutiny, with ASIC signaling an expectation that they operate to standards closer to those of regulated products. 

ASIC’s own surveillance findings have highlighted a consistent set of challenges that continue to undermine transparency and investor protection. Many firms still struggle to provide clear, consistent transparency around their investment strategies, risk profiles, and assets they hold. Fees are often wrapped in layers of complexity, making it hard for investors to understand the true cost. Some conflicts of interest go unchallenged, and governance processes can lack the teeth to enforce accountability. At the same time, liquidity terms are sometimes offered without a realistic assessment of how liquid those underlying assets actually are. 

ASIC outlines a potential reform package, including mandatory notification for new funds, annual financial reporting, extended operator duties, event-driven investor disclosures, and a re-examination of the wholesale investor test. It also introduces a framework of “private credit done well” principles—a signal that compliance expectations are no longer ambiguous. 

This is where policy becomes proof, or risk. For compliance teams overseeing wholesale funds or private credit, the challenge isn’t just setting the right rules. It’s showing that those rules are working day to day. 

Side letters, fee arrangements, and allocation preferences often surface in chats and emails—not in formal documentation. Surveillance helps you catch what policy can’t: Informal valuation pressure, sensitive deal terms discussed across desks, or governance steps skipped in practice. 

Shield’s Info Barriers module helps your team detect, document, and respond to information barrier breaches across deals and mandates. By connecting HR data, deal activity, and communication flow, it gives you a clear audit trail—and the ability to prove that conflicts and MNPI are being actively managed. It’s how firms stay ahead of regulatory expectations and move from reactive oversight to proactive control. 

Data Transparency and ASIC’s Push for Machine-Readable Supervision 

ASIC wants a richer, more uniform and usable view of fund and market activity. Current reporting is often fragmented, backward-looking, and inconsistent, especially in wholesale markets. The regulator is laying the groundwork for standardized, recurrent, and machine-readable reporting that covers strategy, flows, leverage, fees, redemptions, and service provider relationships. 

This vision calls for more than technical architecture. It requires firms to align their data model with the decisions they make and the risks they monitor. That includes understanding how structured data relates to conduct, and where communication signals can serve as early warnings. 

Our surveillance engine structures comms data into alerts, themes, cases, and metadata. This data is a powerful layer in the risk ecosystem, showing which products, desks, or regions are generating concerning patterns, how often key topics like liquidity or fee breaks are discussed, and whether comms risk is rising around specific events. Integrated into a firm’s broader analytics or compliance reporting stack, this transforms surveillance from siloed alerting into a source of operational risk intelligence, supported by Shield’s ability to generate reports, monitor data completeness, and integrate via APIs. These capabilities allow firms to embed communication insights into regular workflows, enabling meaningful, regulator-ready oversight. 

Superannuation Oversight and Trustee Accountability 

Super funds are recognized as system-level players. With their growing exposure to illiquid private markets, ASIC expects more rigorous governance of valuation, liquidity, and disclosure practices. Trustees are not just expected to oversee, they’re expected to challenge. That includes pressing external managers on marks, ensuring disclosures are meaningful, and aligning liquidity terms with actual asset behavior. 

This cultural expectation translates directly into communication flow. Board and committee conversations must reflect real oversight. Debates with asset managers should reflect skepticism, not deference. Internal product discussions need to consider switching risks and member outcomes. 

With Shield, these conversations fall within surveillance scope. Our platform captures the tone, context, and substance of decision-making moments flagging when concerns are raised (or not), when risks are downplayed, or when key decisions are made off-channel. By extending surveillance to trustee and investment teams, super funds can evidence the challenge ASIC is looking for. They can show that conduct and culture align with governance. 

Public Markets Resilience and Market Cleanliness 

ASIC’s public market focus spans three areas:  

• Infrastructure resilience 
• IPO framework reform  
• Market cleanliness 

The latter, market cleanliness, is where surveillance plays an increasingly strategic role. 

ASIC is expanding its cleanliness studies beyond equities to government bonds, corporate bonds, and take-private deals. The goal is to understand whether prices reflect fairly disseminated information, or something else. Did insider lists capture the right people? Did information stay behind barriers? Was the disclosure timely and accurate? 

Communication surveillance is essential to answering these questions. Shield’s platform links insider lists and deal codes with communication flows. It flags when sensitive terms appear outside the approved group, and it maps communication timing to trading and announcement events. It can also track case reviews and resolutions, providing a complete picture when ASIC comes calling. The ability to show how information moved, not just how trades happened, is becoming table stakes in public market oversight. 

Six Practical Steps to Align with ASIC’s Direction 

Firms don’t need to wait for rule changes to act. ASIC’s expectations are clear. Here are six actions firms can take now: 

1. Run a REP 823 gap and behavior review 
   • Map current practices where they are applicable to private markets, superannuation, and public markets. Identify where documented policy might not match actual behavior. For data reporting and transparency, consider a full review of the tools you are using to generate reports, the cleanliness and governance associated with data and how best to operationalize insight so that is it actionable.  
2. Hard-wire conflicts frameworks into communication surveillance 
   • Refresh conflicts policies and monitoring to reflect the realities of modern fund structures, especially across private credit and wholesale investors. Sync deal and fund lists with control-room and HR data. Make sure the behaviors you are looking to surface are accounted for by your comms surveillance vendor.  
3. Treat surveillance output as a core risk and regulatory dataset 
   • Integrate communication surveillance alerts, case metadata, and analytics into your central risk and data warehouse. Use those insights to define conduct KPIs and inform board-level discussions. 
4. Lift trustee oversight with communications evidence 
   • Include relevant superannuation and investment teams in the surveillance perimeter. Monitor committee and manager conversations around valuation, liquidity, and switching risk. 
5. Upgrade market cleanliness and disclosure controls 
   • Align insider lists and disclosure controls with real-time comms monitoring. Ensure surveillance tracks key deal terms, issuer discussions, and MNPI references. 
6. Embed infrastructure resilience in third-party and stress planning 
   • Classify exchanges and settlement platforms as critical third parties. Test outage scenarios, including how sensitive communications would be handled under stress. 

Surveillance is Now About Clarity, Not Just Control

ASIC’s evolving roadmap requires firms to show that policies are enforced, conflicts are managed, and sensitive information is protected in practice. 

That means communications surveillance and behavioral analytics aren’t just add-ons—they’re central to a defensible, data-driven compliance posture. Firms operating in or connected to Australia that connect communication data with governance, risk, and culture will be able to meet ASIC’s challenge head-on. 

Because when regulators move from asking “show me your framework” to “show me how it works,” the firms that win will be those who can prove it—conversation by conversation.