The requirement, in our words
Ahead of a Material Change to a Trading System, or to the controls, arrangements or resources around it, a Trading Participant must conduct a Material Change Review and obtain a written statement from at least one responsible officer on completion. The statement must say that the controls, arrangements and resources around the change allow compliance with 5.5.2 together with Part 5.6 for the relevant Market, with the officer name, position and date. The review must assess compliance, read the policies, procedures, design and other documents, review how the change is implemented, and test the controls, arrangements and resources. It must be conducted by a suitably qualified and experienced person, and the methodology, scope, results and applied changes are kept for at least seven years.
What the rule is trying to do
The review is triggered by the change, before implementation. It is not a post-implementation sign-off. The responsible officer statement is a separate condition and must be in writing. The definition of Material Change is supplied by this rule, so the firm must document its own trigger assessment.
What good practice looks like
Define a material change threshold and a triage record. For each change, record the trigger assessment, the review, the test result and the officer statement. Use the same reviewer competence standard as the Initial Certification Review. Apply the recommended changes and record the residual risk. Keep the pre-change baseline so the change can be reversed.
What changed in the instrument
Item 79 replaces Rule 5.6.8. The old AOP material change review becomes a Trading System Material Change Review, the definition is supplied by subrule (1), the responsible officer statement replaces the old written representations, and the seven year record is retained.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Trigger assessment | The material change criteria and the dated triage record for each change, including changes treated as non-material. | At least seven years. |
| Review report | The Material Change Review covering the assessment, documentation review, change implementation review and testing. | At least seven years. |
| Officer statement | The written responsible officer statement with name, position and date, and the evidence the officer relied on. | At least seven years. |
| Change record | The applied changes, the test result, the approval and the residual risk. | At least seven years. |
Common gaps
- The material change threshold is undefined, so every change is treated as non-material, including a vendor release.
- The review happens after deployment.
- The officer statement is an email approval, not a statement about compliance with 5.5.2 together with Part 5.6.
- The test result is recorded but the methodology and scope are not.
What to do before 17 March 2028
- Define the material change criteria and a triage record, and decide how a vendor release is assessed.
- Write the review template and the officer statement template.
- Set the reviewer competence standard.
- Test the process on one real change before commencement.
Dates and cross-references
Commences: 17 March 2028 (Rule 2 of F2026L01223 and the registration date). Retention: At least seven years.
Read with: 5.6.3, 5.6.4, 5.6.8A.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, item 79, 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.