The requirement, in our words
A Market Participant that asks another Trading Participant to trade for a client keeps a narrower set of the client records. The amended paragraph (a) disapplies paragraphs (c) to (g) and subparagraphs (iv) to (vi) of subrule 4.1.1(2); the client name in paragraph (b), the derivatives particular in paragraph (h) and the first three stage timestamps in paragraph (i) remain in scope. Paragraph (b) adds a record of the representative who acted on the instruction, the representative who received it, the representative who passed it to the other participant, and the time it was passed on. The record must still be sufficiently detailed to show the handoff.
What the rule is trying to do
The concession is narrow and conditional. The instructing participant keeps the responsibility for the handoff, even though the executing participant holds the market-side record. The test is whether the client instruction can be traced into the other participant and back.
What good practice looks like
Identify every route where the firm instructs another Trading Participant, including give-up and prime brokerage arrangements. Capture the representative at receipt, the person who passed it on, and the time of the pass. Reconcile the pass time with the executing participant acknowledgement. Do not use the concession for an instruction the firm executes itself.
What changed in the instrument
Items 55 and 56 replace paragraph 4.1.7(a) and (b). The new (a) disapplies a different set of paragraphs, and the new (b) requires the representative who acted, received and passed on the instruction, and the time it was passed on.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Route inventory | A list of every arrangement in which the firm instructs another Trading Participant, with the system and the acknowledgement method. | Current. |
| Handoff record | A sample instruction showing the receiving representative, the passing representative and the time passed on. | Seven years. |
| Acknowledgement | The executing participant acknowledgement or fill record that closes the handoff. | Seven years. |
| Scope check | The control that prevents the narrower set being used for an instruction the firm executes on its own systems. | Current, with test result. |
Common gaps
- The firm uses the narrower record set for all client orders, including those it executes itself.
- The pass time is the time the order appears at the other participant, not the time the instruction was passed.
- The representative who received the instruction is not recorded when the instruction arrived electronically.
- No acknowledgement links the handoff to the executed transaction.
What to do before 17 March 2028
- Inventory every instruct-another-participant route.
- Add the three representative fields and the pass time to the handoff record.
- Obtain and store the executing acknowledgement.
- Test the scope control with one in-house and one passed instruction.
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.
Read with: 4.1.1, 4.1.3, 4.1.8, 5.5.1.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, items 55 and 56, 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.