Assessment of ASX Clearing and Settlement Facilities – September 2025 Appendix A: Summary of Progress 2024/25

The tables below summarise actions taken by the ASX CS facilities during the 12 months to June 2025 (the assessment period) to address recommendations identified in the RBA’s 2024 Assessment of ASX Clearing and Settlement Facilities, as well as outstanding recommendations from previous years. Table A.1 summarises all open recommendations as of 30 June 2025, including a summary of progress against the outstanding recommendations. Table A.2 provides a summary of recommendations that have been closed or superseded during the assessment period.

Table A.1: Summary of All Open Recommendations at 30 June 2025
Reference^(a)	Recommendation	Standard	Facility	Update	Timeframe
2022-8	Legal basis: PSNA. ASX Settlement should apply for approvals as an approved RTGS system and as a multilateral netting arrangement under the Payment Systems and Netting Act 1998 (PSNA), or in the case of the multilateral netting approval provide the RBA with legal analysis demonstrating why its existing approval remains valid once changes to the ASX Settlement operating rules required to support the introduction of the CHESS replacement have been made.	CCP/SSF 1	ASX Settlement	This recommendation is linked to work on the CHESS Replacement. Progress is to be reviewed once the work on the second release of the CHESS Replacement Program (settlement and sub-register replacement) has progressed.
2025-8	Governance: Risk strategy. ASX boards should obtain independent assurance, through an internal audit, that gaps relating to ASX’s risk appetite statement and return-to-risk appetite strategy have been addressed in a way that enables the boards to: take a holistic view of ASX’s risks embed risk management as part of ASX’s overall business strategy.	CCP/SSF 2	All	New recommendation.	30 June 2026
2025-9	Governance: Board reporting. ASX boards should obtain independent assurance, through an internal audit, that the gaps around board KRIs have been addressed.	CCP/SSF 2	All	New recommendation.	30 April 2026
2023-4	Governance: Stakeholder engagement. The ASX boards should continue their emphasis on stakeholder management. ASX should continue to actively consult stakeholders on the detailed design, project timeline, testing and implementation for the CHESS replacement and ClearStar.	CCP/SSF 2	All	ASX continues to engage with stakeholders of the CHESS Replacement project on the solution design and the project and implementation timeline through the industry Business Committee, Technical Committee, and related working groups. ASX has run a number of consultations on both phases of CHESS Replacement. ASX has launched a website for the ClearStar program, conducted formal consultations on the ETD Futures Clearing and Trade Accept replacement projects, and established a ClearStar Program Committee.	December 2029
2025-5	Framework for the comprehensive management of risks: Risk transformation plan. ASX should produce and implement appropriate reporting on the progress of the transformation plan. This should include regular reporting to ASX boards, detailed quarterly status updates to regulators and regular public disclosures.	CCP/SSF 3	All	New recommendation.	30 June 2026
2025-6	Framework for the comprehensive management of risks: Risk transformation plan. ASX should ensure that resourcing allocated to its risk transformation plan and target operating model are sufficient to support the uplift required to meet expectations under the CCP and SSF Standard 2.6.	CCP/SSF 3	All	New recommendation.	30 June 2026
2025-7	Framework for the comprehensive management of risks: Risk culture. ASX should: continue to have a strong focus on risk culture as part of its Accelerate program and outline detailed milestones in relation to risk culture, including clear actions to generate the required behavioural change across the organisation, especially from leaders allocate adequate funding to risk culture initiatives evidence its progress via specific risk culture metrics, as well as improved risk management outcomes.	CCP/SSF 3	All	New recommendation. Replaces 2024-1.
2025-10	Data and reporting controls: ASX should comprehensively improve data and reporting controls for its financial risk models to ensure that data processing, and the outputs generated, are of high quality.	CCP 3,4,5,6,7	Both CCPs	New recommendation.	To be determined
2025-11	Model validation and control testing: In response to the financial risk model issues identified in the 2025 assessment, ASX should take a holistic approach to identifying and implementing any necessary improvements to its model validation and control testing frameworks. By March 2026, ASX should have completed identifying the necessary improvements and commenced implementation. Once ASX has completed implementing these improvements, ASX’s internal audit function or a suitably qualified independent third party should conduct a review.	CCP 3,4,5,6,7	Both CCPs	New recommendation.	To be determined
2023-10	Credit risk: Outstanding margin in stress tests. ASX should account for outstanding margin payments in its stress test calculations.	CCP 4	Both CCPs	Timeframe updated. During the assessment period, ASX developed methodologies to account for outstanding margin payments in its stress test calculations. Due to additional complexities, ASX now expects to finalise and implement the changes at ASX Clear (Futures) by September 2025 and ASX Clear by June 2026.	30 June 2026
2018-1a	CCP Resilience Guidance. The ASX CCPs should enhance the comprehensiveness of stress testing to ensure risks are appropriately identified, captured and stressed.	CCP 4, 7	Both CCPs	Timeframe updated. During the assessment period, ASX upgraded their credit and liquidity stress tests for ASX Clear. ASX expects to enhance their credit and liquidity stress tests for ASX Clear (Futures) over the coming assessment periods. ASX previously expected to complete the recommendation by June 2026, but it has been delayed due to flow-on effects from other dependencies.	Expected completion by June 2027
2023-13	Margin: ASX Clear intraday margin. ASX Clear should enhance its capacity to monitor the build-up of current exposures to participants and to make intraday margin calls to participants.	CCP 6	ASX Clear	During the assessment period, ASX commenced quantitative work on a new margin model for cash market products. However, the work is behind schedule. ASX will continue this work in the coming assessment periods.	Indicative timing is prior to June 2029
2024-3	Segregation and portability. By 30 June 2026, ASX should incorporate client porting into its default management fire drills.	CCP 13	Both CCPs	Recommendation updated. During the assessment period, ASX completed a benchmarking exercise of its client portability arrangements against other CCPs. This found that ASX faces similar porting challenges to peer CCPs but ASX lagged in the frequency of its client portability fire drills. ASX intends to include client portability in its default management fire drills in the next assessment period.	30 June 2026
2024-6	Operational risk: Implement PPPM recommendations. By 30 June 2026, ASX should complete and sustainably implement the recommendations from the PPPM Reports. ASX should prioritise those regarding: the useability of the PPPM framework documents project resource forecasting, forecasting capacity/demand planning and portfolio management functions clarifying roles and decision-making responsibilities stage-gate reviews.	CCP 16 SSF 14	All	During the assessment period, ASX implemented a range of improvements to its project and program delivery stemming from the PPPM reports. This has included updating and simplifying frameworks, introducing a new stage-gate review process and implementing a PPM tool. ASX has engaged an external expert to evaluate the effectiveness of its new frameworks and processes in the next assessment period. The RBA will continue to monitor ASX’s implementation of its new PPPM frameworks and their application to its suite of projects.	30 June 2026
2024-10	Operational risk: Fourth party vendor management risks. By 31 December 2026, ASX should have developed and implemented formal frameworks to monitor and manage fourth party and concentration risks for vendors servicing the CS facilities. This should include identification of fourth-party single points of failure.	CCP 16 SSF 14	All	ASX expects to develop and implement formal frameworks to monitor and manage fourth-party and concentration risks for vendors servicing the CS facilities in the next assessment period. In reviewing the response to this recommendation, the RBA will also assess the ongoing implementation of ASX’s new supplier frameworks.	31 December 2026
2025-1	Operational risk: Operational resilience. By June 2026, ASX should demonstrate how it has enhanced resourcing for current CHESS, to ensure it can reliably access and utilise well-trained and competent personnel, as well as technical and other resources. This should include required upskilling of newly hired engineers and third-party support staff.	CCP 16 SSF 14	ASX Clear ASX Settlement	Update of March 2025 out-of-cycle recommendation on resourcing and third-party support arrangements for current CHESS. ASX’s initial response to the out-of-cycle recommendation was insufficient. ASX has subsequently outlined a clearer plan to enhance resourcing and third-party support arrangements for current CHESS. The RBA is closely monitoring progress against this plan.	30 June 2026
2025-2	Operational risk: Operational resilience. By June 2026, ASX should demonstrate how it has improved contingency arrangements for current CHESS, designed to enable resumption of operations within two hours following a disruptive event.	CCP 16 SSF 14	ASX Clear ASX Settlement	Update of March 2025 out-of-cycle recommendation on contingency arrangements for CHESS. ASX’s initial response to the out-of-cycle recommendation was insufficient. ASX has subsequently provided a clearer plan to improve contingency arrangements for current CHESS. The RBA is closely monitoring progress against this plan.	30 June 2026
2025-4	Operational risk: Strengthening operational resilience across all critical services. By June 2026, ASX is to complete an end-to-end review of its business continuity and contingency arrangements for ASX Clear, ASX Clear (Futures), ASX Settlement, Austraclear, and develop a plan to prioritise remediation of any gaps identified.	CCP 16 SSF 14	All	New recommendation.	30 June 2026
2025-3	Operational risk: Ageing assets. ASX should continue to place high priority on remediating ageing technology assets, including: continued implementation of new frameworks and processes for asset lifecycle management; measurable progress in remediating outstanding high and medium severity technology issues. Progress reports should be provided to the RBA on a quarterly basis.	CCP 16 SSF 14	All	New recommendation. Replaces 2024-4 and 2024-5.	30 June 2026
2020-8	Operational risk: Risk management systems. The ASX CCPs should implement plans to ensure that their core systems have the functionality to fully support their risk management approach, including by migrating processes currently operated on non-core systems to core systems.	CCP 16	Both CCPs	The derivatives component of this work will be completed as part of the Clearstar program. The cash component will be addressed under recommendation 2023-13. This work will also be supported by ASX’s data platform project. The RBA will be seeking an update on the status of this work in the next assessment period.	Expected completion by June 2029
2023-21	Operational risk: CHESS – Upgrades to comply with the FSS. ASX should identify any upgrades that are required for CHESS to comply with the FSS and communicate its plans to consult stakeholders and implement these changes in a safe and timely way. ASX is to consult stakeholders in relation to any material changes to the current CHESS and publish key details and timelines for all upgrades to CHESS.	CCP 16 SSF 14	ASX Clear ASX Settlement	Timeframe updated. ASX has progressed items on the current CHESS Roadmap and produced a public report on the Roadmap, which will be shared with industry in July 2025. The RBA expects that upgrades to current CHESS will be ongoing until it is replaced.	31 December 2029
2020-5	Operational risk: CHESS – Capacity and system replacement. ASX should implement the new clearing and settlement system for cash market transactions as soon as this can be safely achieved by ASX and users of CHESS. In the short term, ASX should complete work underway to increase the joint capacity of the current CHESS and CORE systems.	CCP 16 SSF 14	ASX Clear ASX Settlement	The first release of CHESS Replacement (scheduled for April 2026) is expected to address the capacity issues in the current trade registration process in CHESS. A proof of Technology (PoT) exercise was conducted to test the capacity of the new clearing solution. This demonstrated that the new system would be able to meet a peak volume of 15 million trades in a day. For current CHESS, ASX completed stress tests in the previous assessment period and implemented a fix for a breakpoint identified at a peak of 15 million trades per day.
2020-6	Operational risk: CHESS – IBM Review. ASX should ensure that the findings and lessons learned from the IBM Review of the Trade Refresh project are applied to the CHESS Replacement Program.	CCP 16 SSF 14	All	Timeframe updated. ASX has now implemented all 59 IBM Review recommendations. An independent expert (EY) has confirmed all recommendations are fully closed. EY has been performing spot checks to assess the continued adherence to these recommendations. Tranche 1 of these spot checks was completed in March 2024. During the assessment period, Tranche 2 of spot checking was completed by an ASX internal review team and validated by an independent observer. Lessons learned from the IBM Review have been built into the CHESS Replacement project with the remaining two action items having defined milestones tied to the delivery of CHESS Replacement. ASX’s CHESS Replacement Assurance plan will track these actions to closure.	31 July 2026
2022-6	Operational risk: CHESS – CHESS replacement go-live. ASX should prepare for cutover, migration and go-live of the CHESS replacement system, including by: having comprehensive and effective contingency plans in place for dealing with an issue on the go-live weekend or subsequent to go-live successful execution of migration dress rehearsals effective arrangements for go-live decision-making, including ASX’s compliance with relevant 2021 License Conditions.	CCP 16 SSF 14	ASX Clear ASX Settlement	CHESS Replacement will be implemented in two releases. The first release (clearing) is expected to go live in April 2026, and the second release (settlement and sub-registry) in 2029. ASX has designed an assurance program to assist with risk management and decision-making at key milestones across both releases. During the assessment period, ASX has published a number of documents on the first release. These include its Cutover Approach, AMO User Technical Documentation, AMO Readiness – Release Notes, and its Response to Consultation on Release 1 (Clearing Services). In July 2025, ASX commenced the AMO Readiness phase for the first release, which provides a production-like test environment for AMOs and vendors.
2024-11	Tiered participation arrangements: Tiered participation policies. By 31 December 2026, ASX should address the identified gaps in its tiered participation policies to effectively identify, monitor and manage risks that arise from tiered participation arrangements.	CCP 18 SSF 16	All	Recommendation updated. During the assessment period, ASX developed tiered participation policies for each CCP and SSF. ASX identified gaps in its framework as a part of this process, including the lack of a formal periodic review of clearing participants’ client risk management frameworks. ASX plans to address these gaps in 2026.	31 December 2026
2025-12	Regulatory reporting. ASX should remediate all issues identified in its 2024 internal audit report on regulatory reporting and consistently demonstrate timely, complete and accurate regulatory reporting by June 2026.	CCP 21 SSF 19	All	New recommendation.	30 June 2026
(a) Reference indicates the year a recommendation was raised and the order in which it appears in the assessment. Recommendations have been grouped by standard and topic.

Table A.2: Previous Recommendations Closed or Superseded
Reference^(a)	Previous Recommendation	Standard	Facility	Progress and outcome
2021-18	Framework for the comprehensive management of risks: Risks to and from other entities. ASX should establish a process to periodically conduct systematic assessments of the range of potential risks other entities may pose to its CS facilities and the risks ASX CS facilities could potentially pose to other entities.	CCP/SSF 3	All	Outcome: Closed ASX completed an initial assessment of risks posed to and from other entities in the 2024 assessment period. The RBA requested more information, including on individual ASX entity risk profiles. ASX was granted an extension to June 2025. ASX has provided its final assessment and identified a number of areas for future work, which will be addressed through its risk transformation plan. ASX will annually review its risk profiles and present them to the board.
2024-1	Framework for the comprehensive management of risks: Risk culture. In the 2025 assessment period, ASX should continue implementing its plan to improve risk culture. ASX should also implement the recommendations of the external review of this plan, which include defining a target state and ensuring consistent risk communication and leadership.	CCP/SSF 3	All	Outcome: Replaced by 2025-7. ASX has included further work on risk culture as part of its Accelerate program. A new recommendation has been made in relation to this work.
2024-2	Framework for the comprehensive management of risks: Methodology of return to risk appetite strategy. By 30 June 2025, ASX should obtain an independent review (conducted by either its Internal Audit or an external expert) of its strategy to address its heightened level of risk. This should include consideration of its KRIs. The review should also consider whether its strategy is responsive to evolving risks.	CCP/SSF 3	All	Outcome: Closed. During the 2025 assessment period, internal audit conducted a review into ‘Board Key Risk Indicators (KRI) Management and Return to Risk Appetite’. ASX intends to address these findings through its Risk Transformation Plan. The RBA has made two new recommendations related to these findings: 2025-8 and 2025-9.
2023-9	Credit risk: Specific wrong way risk. ASX should introduce additional stress test scenarios to monitor and mitigate specific wrong way risks at ASX Clear by 31 December 2024.	CCP 4	ASX Clear	Outcome: Closed. During the assessment period, ASX implemented additional stress test scenarios to monitor and mitigate specific wrong way risks at ASX Clear.
2020-1	Margin. Consistent with the CCP Resilience Guidance, by 31 December 2024, the ASX CCPs should develop a systematic framework to avoid destabilising increases in margin and other financial risk requirements during periods of heightened market volatility. This framework should include an appropriate methodology for measuring the degree of procyclicality in the CCPs’ risk models and should consider the potential effect of expert judgement on procyclicality when determining margin and other financial risk requirements.	CCP 6	Both CCPs	Outcome: Closed. During the assessment period, ASX completed work to improve its procyclicality framework. This follows work in previous assessment periods to implement floors in its margin models, implement a margin forward guidance framework, and develop a methodology for measuring procyclicality.
2023-12	Margin: Overnight variation margin. ASX Clear (Futures) should develop a long-term strategy for its overnight margin operations by December 2024.	CCP 6	ASX Clear (Futures)	Outcome: Closed. In December 2024 ASX presented a long-term strategy with a focus on using NPP PayTo to collect overnight variation margin in AUD. However, a number of impediments mean that this is unlikely to be prioritised by industry in the near future. ASX will consider expanding collateral options for overnight margin payments as part of the ClearStar program.
2023-15	Operational risk: Evergreen strategy. ASX should develop and begin implementing a long-term strategy to proactively identify ageing assets and remediate the risks before they materialise.	CCP 16 SSF 14	All	Outcome: Closed ASX delivered its Long-Term Technology Sustainability Strategy in the previous assessment period. ASX has demonstrated that it is implementing this strategy via progress on other recommendations related to aged assets (e.g. 2024-4 and 2024-5).
2023-17	Operational risk: CHESS – Independent review recommendations. ASX should implement the 45 recommendations from the independent review of CHESS replacement, conducted by Accenture. ASX should also ensure that any relevant steps are taken to apply lessons learnt from the external review more holistically across the enterprise.	CCP 16 SSF14	ASX Clear ASX Settlement	Outcome: Closed In this assessment period, ASX had four outstanding actions to complete from the independent review of CHESS replacement. Two of the remaining actions were completed as part of the CHESS Replacement project. The other two actions required further evidence of implementation; ASX has obtained independent assurance that these actions have been completed.
2023-24	Operational risk: CHESS – Backup plan. ASX should clearly communicate to regulators what their backup plan will be in the event that the replacement system is not delivered before supportability of the current CHESS is severely compromised. The risks around the backup plan should be appropriately identified, assessed and monitored, with appropriate controls put in place to mitigate these risks. This communication to the regulators on the backup plan should be at the same time as communication on the solution selection decision. ASX should also clearly communicate to stakeholders what their backup plan will be if the selected CHESS replacement solution is unable to be implemented. This communication to stakeholders should be well in advance of the current CHESS being severely compromised to ensure stakeholders have sufficient and appropriate notice to test and implement the backup plan in a safe manner.	CCP 16 SSF 14	ASX Clear ASX Settlement	Outcome: Closed ASX has provided an updated CHESS Replacement contingency plan. ASX has added detail to the plan, identified key risks and potential mitigants, and implemented a new framework to guide management should CHESS Replacement fail. The plan is supported by ASX’s commitment to maintain the current CHESS system to at least 2032.
2023-26	Operational risk: CHESS – Implementation timeline. ASX should publish on its website its project and implementation timeline with dates for key milestones. This plan should have a new and credible go-live date for CHESS replacement.	CCP 16 SSF 14	ASX Clear ASX Settlement	Outcome: Closed In June 2024, ASX completed industry consultation on the first release of CHESS Replacement. In November 2024, ASX completed industry consultation on the second release of CHESS Replacement. As part of both consultations, ASX published a project and implementation timeline with key milestones. ASX has communicated that go-live for the first release is targeted for between mid-March and end-April 2026. For the second release, ASX has a go-live window of between April and December 2029. It will provide industry with 12 months’ notice of its target go-live date as the second release approaches.
2024-4	Operational risk: Aged asset reporting. Throughout the 2025 assessment period, ASX should continue to place high priority on remediating ageing technology assets and ensure that major technology remediation activities progress to scheduled timelines. As part of this, ASX should continue to assess whether its short-term controls remain sufficient and appropriate. ASX should also ensure it has sufficient resources and capabilities to support the health of critical systems and remediation activities. ASX should provide regular reporting to the boards that clearly shows: progress against its Technology Issues Remediation Roadmap a holistic view of the health of all critical systems, and the expected impact of planned remediation activities on the risk attributes of critical systems.	CCP 16 SSF 14	All	Outcome: Replaced by 2025-3. Throughout the assessment period, ASX has made progress against issues on the Technology Issues Remediation Roadmap. At the end of June 2025, four high-severity issues remain outstanding. ASX provided regular progress reporting to its boards throughout the year. ASX’s System Operational Risk Assessment provides a holistic view of the health of its critical systems. This recommendation has been updated to reflect the RBA’s expectations that ASX make ongoing progress to improve its asset lifecycle management processes and remediate outstanding issues.
2024-5	Operational risk: Asset-lifecycle management framework. By 30 June 2025, ASX should ensure that it has an appropriate framework or policy for asset lifecycle management that mandates the proactive upgrade or replacement of technology assets before they reach end-of-life. As part of this, ASX should explicitly outline responsibilities around asset lifecycle management and ensure that the tools used to track technology assets are fit for purpose.	CCP 16 SSF 14	All	Outcome: Replaced by 2025-3. During the assessment period, ASX developed an asset lifecycle management framework, including separate IT Software Asset Management (SAM) and IT Hardware Asset Management (HAM) policies. Both policies clearly outline responsibilities for asset lifecycle management. ASX has implemented asset lifecycle monitoring via a ServiceNow tool. The RBA will continue to monitor ASX’s implementation of these new frameworks and tools over the coming year.
2024-7	Operational risk: Simplify vendor management risk policies. By 28 February 2025, ASX should simplify and streamline its frameworks and policies relating to the management of vendor risks. The frameworks and policies should ensure that requirements and responsibilities are clear, unambiguous and consistent.	CCP 16 SSF 14	All	Outcome: Closed During the assessment period, ASX condensed existing artefacts into a new Supplier Lifecycle Policy and the related Supplier Lifecycle Standard, which applies across all ASX business units and all supplier arrangements. The new policy provides a clear and consistent definition of responsibilities for accountable roles at ASX.
2024-8	Operational risk: Mandating vendor management practices. By 28 February 2025, the following should be made clearly mandatory for all key vendors supporting the CS facilities: vendor risk assessments implementation of consistent enterprise processes for monitoring vendor performance contingency plans for when a vendor ceases to provide services.	CCP 16 SSF 14	All	Outcome: Closed During the 2025 assessment period, ASX implemented a new Supplier Lifecycle Policy and Supplier Lifecycle Standard. Through a criticality assessment that is mandatory for all vendor relationships under the standard, the new framework provides a process for ensuring that critical vendors are clearly identified and categorised. The standard sets mandatory requirements for these vendors to be subject to: (i) vendor risk assessment; (ii) vendor performance monitoring; and (iii) contingency plans if a vendor ceases to provide services.
2024-9	Operational risk: Uplift vendor management capabilities. By 30 June 2025, ASX should improve its organisation-wide capabilities for vendor management. ASX should identify the skills and training required for staff with vendor management responsibilities and develop a plan for putting these skills and training in place.	CCP 16 SSF 14	All	Outcome: Closed During the assessment period, ASX established an approach to continuously improve vendor management capabilities and ensure consistency across the organisation. This includes supporting guidance, training and continued support by a central procurement team with subject matter expertise.
(a) Reference indicates year the recommendation was first raised and the order in which the recommendation appears in the assessment.