The requirement, in our words
A Market Participant that receives an instruction to trade for a client must keep records detailed enough to reconstruct the instruction from the moment it is given to the resulting Market transaction. The amended rule names the person who gave the instruction, the representatives who were responsible for it, received it, entered it into a Trading System or submitted a Trading Message, every amendment, the corresponding Trading Message, the Market and transaction, any nominated Derivatives Market Contracts, and the date and time of each processing stage. It applies whether or not a Trading Message is entered or matched.
What the rule is trying to do
The rule makes the audit trail follow the instruction, not only the order that reached the market. A firm must be able to show who did what, in what order, and when, including where the instruction was never executed or was changed several times before submission.
What good practice looks like
Map each field in the amended rule to a system field or a controlled manual record. Test a cancelled client instruction, a partially filled order, an instruction passed between representatives, and a Managed Discretionary Account decision. Reconcile the front-end timestamp against the Trading Platform record where you rely on it. Keep the linkage between the instruction and the Trading Message explicit rather than inferred from a client account and a time window.
What changed in the instrument
Items 37 to 47 rewrite subrule 4.1.1(1) and (2). The amended rule uses one instruction rather than instructions, adds a Managed Discretionary Account instruction to the scope, replaces the old paragraphs (b) to (j) with new (b) to (i), and makes the date and time of each processing stage an express particular. The old reference to Rule 5.5.3 for automated order processing is removed.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Record design | The record schema or data dictionary, showing the field that holds each amended particular, including the name and capacity of each representative and the stage timestamps. | Current, plus the version history. |
| Sample reconstruction | A tested reconstruction of one client instruction from receipt to Market transaction, with each amendment and the matching Trading Message identified. | Seven years from the record date. |
| Exception record | The log of instructions that were cancelled, never submitted, or not executed, showing the same fields are captured. | Seven years from the record date. |
| Control evidence | The reconciliation or completeness check that proves no instruction lacks a representative, a timestamp or a linked Trading Message. | Current, with the last test result. |
Common gaps
- The record starts at the order, not at the instruction, so a cancelled or amended instruction is invisible.
- The representative who received the instruction is stored as free text or is missing when the order was routed automatically.
- The Market transaction is linked by account and time rather than by the Trading Message.
- The record carries the submission time but not the time the instruction was given or amended.
What to do before 17 March 2028
- List every channel through which a client instruction arrives, including voice, email, portal and a Managed Discretionary Account.
- Add the representative name and capacity, the processing stage times and the Trading Message link to the record design.
- Test the four hard cases: cancelled, amended, unexecuted and passed-on instructions.
- Write the fallback procedure for a field the Trading Platform cannot supply.
Dates and cross-references
Commences: 17 March 2028 (Rule 2 of F2026L01223 and the registration date). Retention: Seven years from the date the record is made (Rule 4.1.4).
Read with: 4.1.3, 4.1.4, 4.1.6, 4.1.7, 5.5.1.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, items 37 to 47, 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.