The requirement, in our words
The amended Rule 4.1.3 keeps the obligation to make the records required by Rule 4.1.1, Rule 4.1.2, Rule 4.1.7 together with Rule 4.1.8, as soon as the event happens. Item 51 removes the closing words that separately required the participant to note when the event happened. The time is not dropped from the record set: the amended Rule 4.1.1 together with Rule 4.1.2 make the date and time of each processing stage an express particular, so the timing duty now sits inside the record content.
What the rule is trying to do
The change avoids a duplicate timing obligation while keeping the same operational standard: the record is made at the time, not reconstructed later. A firm that relies on an end-of-day batch to populate a field is exposed even if the field eventually holds a timestamp.
What good practice looks like
Identify which records are written synchronously by the system and which depend on a batch or a manual step. For each batch-populated field, record the source timestamp and the time the record was written. Test a trading day with a late amendment and a cancelled instruction. Document the exception where a Market operator record supplies the time under Rule 4.1.6.
What changed in the instrument
Item 51 removes the separate timing words from Rule 4.1.3. The timing content moves into the amended 4.1.1(2)(i) and 4.1.2(2)(f), which list each stage and its date and time.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Timing map | A map of each record field to its write path, showing whether it is written at the event or later, and the source timestamp. | Current. |
| Batch evidence | The batch schedule and the reconciliation that proves a later write still carries the original event time. | Seven years, or the life of the system plus seven years. |
| Exception log | Incidents where a record was not made immediately, with the cause and the remediation. | Seven years. |
| Test result | A test that an amendment made after the event is written immediately and carries its own timestamp. | Current, with date and tester. |
Common gaps
- The event time is written by an overnight batch and cannot be distinguished from the write time.
- A manual amendment is keyed the next morning with no record of when the instruction changed.
- The firm relies on the Trading Platform timestamp without confirming that the platform records the stage the rule names.
What to do before 17 March 2028
- Map every field to its write path.
- Confirm which timestamps the Market operator records and which the firm must write.
- Test a late amendment and a cancelled instruction.
- Record the fallback when a system cannot write immediately.
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: 4.1.1, 4.1.2, 4.1.4, 4.1.6.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, item 51, 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.