The requirement, in our words
Once a Trading Participant has a Trading System running in a Market, it reviews that system at least yearly, unless a Material Change Review covered the period. The Annual Review must assess whether the controls, arrangements and resources allow compliance with 5.5.2 together with Part 5.6 and, as necessary, read the policies, procedures, design and change documents and test the controls. It must be conducted by a suitably qualified and experienced person. Within 20 business days of completion, at least one responsible officer must make a written statement about whether the participant complied with its obligations in the rule, with the officer name, position and date. The methodology, scope, results and applied changes are kept for at least seven years.
What the rule is trying to do
The annual review is the steady state assurance. A Material Change Review can substitute for it in a 12 month period, but the substitution must be evidenced. The 20 business day statement is a separate deadline that runs from completion, and the statement is about compliance with the rule, not only about the system.
What good practice looks like
Put every Trading System on a 12 month calendar with the last review date and the material change reviews in the period. If a material change review substitutes, record why. Complete the review, then diarise the 20 business day officer statement. Keep the review and the statement together. Test the clock with a review completed just before the anniversary.
What changed in the instrument
Item 80 replaces Rule 5.6.8A. The AOP annual review becomes the Trading System Annual Review, the material change substitution is retained, the responsible officer statement is added with a 20 business day deadline, and the record period is at least seven years.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Review calendar | The 12 month calendar for every Trading System, with the last review, any material change review in the period and the next due date. | Current, plus seven years. |
| Review report | The Annual Review report with the assessment, documentation review, testing and methodology. | At least seven years. |
| Officer statement | The written responsible officer statement made within 20 business days of completion, with name, position and date. | At least seven years. |
| Substitution record | Where a Material Change Review substitutes for the annual review, the review and the reason it covers the period. | At least seven years. |
Common gaps
- The annual review is done but the officer statement is made months later.
- A material change review is assumed to cover the annual review without a substitution record.
- The review tests the system but not how changes are implemented.
- The calendar is maintained per system, not per Market, so a system used in two Markets is reviewed once.
What to do before 17 March 2028
- Build the calendar per Trading System and Market.
- Record any material change review that substitutes.
- Diarise the 20 business day statement at completion.
- Test one annual review end to end.
Dates and cross-references
Commences: 17 March 2028 (Rule 2 of F2026L01223 and the registration date). Retention: At least seven years. Deadline: Written statement within 20 business days of completion..
Read with: 5.6.3, 5.6.4, 5.6.8.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, item 80, against the current compilation Compilation No. 6 (F2024C01108). Retrieved 2026-10-19. The requirement above is our own statement, not the instrument's wording. Not legal advice; does not certify.