Proposed new reporting requirements for managed investment schemes
The Australian Government is consulting on proposals to significantly increase the information collected about managed investment schemes (MISs).
The proposals would affect registered schemes but, importantly, also seek to increase regulatory visibility of the wholesale and unregistered MIS sector, which is currently subject to significantly less scheme-level reporting.
Expanded reporting for registered schemes
For registered schemes, Treasury is considering expanding the information collected when a scheme is registered and introducing recurring reporting requirements.
The proposed information could extend to matters such as a scheme’s investment strategy and structure, related parties and counterparties, leverage, liquidity, valuation methodology, withdrawal arrangements, fees and compliance arrangements.
For responsible entities, this could result in considerably more information being provided to regulators both at registration and on an ongoing basis.
Greater visibility of wholesale and unregistered schemes
The proposals are particularly relevant to wholesale trustees and operators of unregistered MISs.
Treasury has identified the limited information currently available about the unregistered MIS sector as a regulatory gap and is considering introducing targeted data collection for these schemes.
While the precise requirements are yet to be determined, this could include information about a scheme’s characteristics, operations and financial position. Treasury is also considering whether certain managed account arrangements should be captured.
This would represent a significant change for parts of the wholesale funds sector which have not traditionally been subject to the same scheme-level reporting requirements as registered schemes.
How far should the new requirements extend?
For fund operators, an important consideration will be the scope of the final reporting framework and how the requirements apply across different types of schemes.
Additional reporting may provide regulators with greater visibility of the sector, but broad requirements could also create substantial additional compliance obligations, particularly for wholesale and unregistered fund operators.
There is also potential for duplication where information is already provided through existing regulatory or statistical reporting. Treasury has acknowledged this issue and is seeking feedback on opportunities to rationalise existing data collections and minimise unnecessary compliance costs.
Fund operators should consider whether the proposed requirements are proportionate to the nature of their schemes and whether the information proposed to be collected is already available to government through other reporting channels.
Submissions on the consultation close on 23 October 2026.
If you require assistance in assessing how the proposed reporting requirements may affect your managed investment scheme or funds management business, please contact Chris Mee at cmee@cnmlegal.com.au or call 07 3211 4010.
This article is produced as general information in summary for clients and should not be relied upon as a substitute for detailed legal advice or as a basis for formulating business or other decisions. CNM Legal asserts copyright over the contents of this article.