What is a Trading System under the ASIC market integrity rules?
The instrument defines a Trading System as software that records messages before they are sent to a trading venue. That is broader than a Trading Algorithm, which automatically determines order parameters. Routing, bare submission, confirmations and post-trade processing are excluded from the algorithm definition, not from the system.
The instrument inserts a definition of Trading System: software that records messages before they are sent to a trading venue. It also inserts Trading System Requirements, meaning the requirements of Part 5.6, and Trading Algorithm, which is a computer algorithm that automatically determines one or more Order parameters with limited or no human intervention.
How is a Trading System different from a Trading Algorithm?
The system is the registration and submission layer. The algorithm is a decision layer inside or alongside it. The algorithm definition excludes systems or processes used only to send Orders to one or more venues, for submission with no determination of order parameters, for producing confirmations, or for post-trade processing. A firm should test each automated function against those exclusions rather than treating every automated tool as an algorithm.
Why does the distinction matter?
Because the duties differ. Part 5.6 imposes controls and arrangements, monitoring, certification, reviews and directions on a Trading System. Rule 5.6.3B imposes a separate life cycle and testing duty on every Trading Algorithm used or made available to a client. A function that is part of the system but outside the algorithm definition still needs the system controls, but not the algorithm testing regime.
What replaces the old AOP concept?
The old Automated Order Processing definitions are repealed, including Automated Client Order Processing, Automated Order Processing Requirements, AOP Client, AOP Annual Notification and AOP Annual Review. The new terms are Trading System, Trading Algorithm and Trading System Requirements. The Part 5.6 heading becomes Trading System Requirements.
What should a firm inventory?
Every system that registers a Trading Message for submission, every algorithm that determines an order parameter, every client-facing algorithm, and every Crossing System it operates. For each, record the owner, the version, the Markets and the control that can stop it. The inventory is the base for the control tests, the Initial Certification Review, the Material Change Review and the annual review.
Where to read it in the record
- Rule 5.6.1: Responsible use of a Trading System
- Rule 5.6.3: Trading System controls
- Rule 5.6.3B: Trading Algorithm governance
- Rule 5.6.4: Initial Certification Review
The source
ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), read against compilation Compilation No. 6 (F2024C01108). Retrieved 2026-10-19. The answer is our own statement. Not legal advice; does not certify.
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