The requirement, in our words
A Market Participant that asks a Trading Participant to trade for it has a narrower record duty. The amended paragraph (a) disapplies paragraphs (b), (d) and (e), and subparagraphs (iii) to (v) of paragraph (f), of subrule 4.1.2(2). Paragraph (b) requires the representative who acted, the representative who decided to instruct and who gave the instruction, the name of the other participant, and the time the instruction was sent.
What the rule is trying to do
The rule keeps the decision trail with the instructing firm and the execution trail with the executing participant. The residual record must still identify the person who decided and the person who gave the instruction, which may be different people.
What good practice looks like
Separate the decision approval from the instruction to the broker. Capture both representatives and the exact instruction time. Match the instruction to the broker confirmation. Test a decision made by a committee and an instruction given by an operations desk.
What changed in the instrument
Items 57 and 58 replace paragraph 4.1.8(a) and (b). The new (a) disapplies paragraphs (b), (d) and (e), and subparagraphs (iii) to (v) of paragraph (f), of subrule 4.1.2(2); the new (b) requires the acting representative, the decision maker, the instructing representative, the other participant and the time instructed.
Evidence an auditor or ASIC asks for
| Category | Record to keep | Retention |
|---|---|---|
| Decision record | The own-account decision or approval, naming the representative who made it. | Seven years. |
| Instruction record | The instruction given to the other participant, naming the representative who gave it and the time. | Seven years. |
| Broker confirmation | The executing participant confirmation or contract note that matches the instruction. | Seven years. |
| Scope check | The control that distinguishes an own-account instruction from a client instruction. | Current, with test result. |
Common gaps
- The decision and the instruction are recorded as one event with one name.
- The other Trading Participant is identified only by a market code.
- The instruction time is the time of the trade, not the time the broker was instructed.
- The record is held by the broker and not by the instructing firm.
What to do before 17 March 2028
- Separate decision approval from instruction.
- Add the other participant name and the instruction time.
- Match instructions to broker confirmations for one month.
- Test the client and own-account scope split.
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: 4.1.2, 4.1.3, 4.1.7.
Source
This page reads ASIC Market Integrity Rules (Securities Markets) Amendment Instrument 2026/574 (F2026L01223), Schedule 1, items 57 and 58, 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.