The following is provided courtesy of David Huppert from AFSL Compliance:
All licensees are now required to report to ASIC every 6 months on the complaints they receive. The current IDR report must be submitted by 28 February 2026.
Click here to download the IDR Data Reporting Template
This IDR report must include complaints that were open on 1 July 2025 as well as new complaints received from 1 July 2025 to 31 December 2025.
You may not have received any complaints in the period. You are still required to complete a lodgement however there is no file to upload and this will be a 5 minute task.
The lodgement is more involved if you have complaints to report as you will need to prepare a file with information prescribed by ASIC, upload the file and then wait 2 days for ASIC to validate the file. We therefore recommend you have your submission into ASIC by 14 February 2026 if you are lodging a data file.
What needs to be reported
The definition of a complaint has not changed: A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.
As per our previous guidance, this is a very broad definition:
- It includes service complaints as well as financial complaints.
- It includes complaints which may be considered minor or which are resolved immediately.
- It includes complaints which may be considered unreasonable, frivolous or vexatious.
- A complaint does not need to be in writing. It can be verbal.
- A client does not have to use the term complaint. The dissatisfaction can simply be implied in the client communication.
- A complaint does not need to be made directly. It can be made on social media eg negative comments on your practice Facebook or LinkedIn page.
Errors that you identify and fix and then communicate to the client are not complaints unless the client subsequently expresses dissatisfaction about the error or how it is resolved.
You only need to report complaints about your services. You do not include complaints you receive from clients about product providers.
Nil Complaints Lodgement
The lodgement is completed through the ASIC Regulatory Portal.
- Login to the ASIC Regulatory Portal
- You should see your Licensee name and a heading for the Internal Dispute Resolution (IDR) submission window now open: Select +Start new transaction which is below this.
- Start a new transaction: You should see a title for Internal Dispute Resolution
- Select Submit Internal Dispute Resolution data report: Scroll down to end and select Launch transaction
- Transaction settings: Select No – allow access
- Entity details and Reporting period are prefilled. Select No if you have no complaints and do not need to submit an IDR data file
- Progress through Contact Details and Review
- Declaration: This will be on behalf of the Regulated Entity and select the appropriate option. Then complete the declaration and submit.
- Save a copy of the lodgement and the acknowledgement from ASIC that you have successfully submitted the lodgement.
No more to be done and no need to read on.
Complaints Lodgement
If you received complaints during the reporting period, you are required to submit/upload your IDR report as a .csv file which meets the standards set by ASIC.
Attached is an excel file that you can use as a template to enter your complaints. This includes some example content with guidance to help you to complete. There is also guidance below:
- ComplaintUniqueID – This is your internal identifier for each complaint
- Numbering should follow on from the second reporting period. Start at 1 if you had no complaints in the previous reporting periods.
- Do not create a new entry/number if a complaint is closed and then re-opened within the reporting period. Just update the details in the first entry.
- Use the same number if a complaint was closed in a prior reporting period and has now been re-opened.
- ComplaintProduct – This is more relevant to large institutions with multiple brands
- This will usually be Not Applicable
- ComplainantType – This describes the type of client
- This would typically be 1
- The client type should match up to what is in your client engagement
- ComplainantGender – This is the gender of the client
- Leave blank unless the ComplainantType is 1
- Use 9 where it is a couple making a complaint
- ComplainantAgeGroup – This is the age of the client
- Leave blank unless the ComplainantType is 1
- Use 9 where it is a couple making a complaint
- ComplainantPostcode – This is the client postcode
- ComplaintStatus – This is the status on 31 December 2025
- Closed generally means resolved to the satisfaction of client or the final response (ie reference to AFCA) has been provided
- Complaints should generally not be open for more than 30 days as the final response is required at 30 days
- ComplaintChannel – This is how the complaint was received
- DateReceived – This is the date the complaint was received
- The date must be from 1 July 2023 to 31 December 2025
- The earliest date is 1 July 2023 as open complaints from the prior reporting period are carried forward and included
- DateClosed – This is the date the complaint was closed.
- The date must be from 1 July 2025 to 31 December 2025
- Leave blank if still open
- Complaints should generally not be open for more than 30 days as the final response is required at 30 days
- DaysOpen – This is how many days the complaint was open. It is an optional field
- Leave this blank
- ComplaintAboutRep – Is the complaint about an Authorised Representative?
- An Authorised Representative includes a Corporate AR.
- ProductOrService – This is the product or service to which the complaint relates.
- This will almost always be 186 which is for Personal Advice. The other potential options are 185 for General Advice or 187 for Credit Assistance.
- This field is repeated three times (a, b and c) so you can add other products or services if required. This will not be the case here and leave the other two fields (b and c) as 999.
- You do not need to enter the product type even where there the complaint relates to advice/services on a specific product.
- ComplaintIssue – This is the subject of the complaint.
- There is a long list of codes which ASIC provide in Table 17 (see additional tab) and you select the most appropriate. We have greyed-out the codes that are unlikely to apply.
- This field is repeated three times (a, b and c) so you can add other subjects if required. For example, a client may complain about your advice and your fees.
- Leave the other two fields (b and c) as 999 unless there is more than one subject for the complaint.
- ComplaintOutcome – This is the outcome of the complaint.
- There is a list of codes which ASIC provide in Table 18 (see additional tab) and you select the most appropriate.
- Leave blank if the complaint was still open on 31 December 2025
- This field is repeated three times (a, b and c) so you can add other outcomes if required. The order of the outcome responses do not need to match up to the subject responses.
- Leave the other two fields (b and c) as 999 unless there is more than one outcome of the complaint.
- CompensationAmount – This is financial compensation paid to the client
- Only complete if ComplaintOutcome was Monetary Remedy (2). Otherwise leave blank.
Make sure you delete the example content provided.
You can also refer to the ASIC FAQs: Internal dispute resolution data reporting | ASIC and their detailed guidance (99 pages).
Once you have completed the above you should:
- Delete all tabs in the excel file except the IDR data reporting template tab
- Delete rows 1, 2 & 3 in the IDR data reporting template
- Save as a .csv file
The lodgement is completed through the ASIC Regulatory Portal.
- Login to the ASIC Regulatory Portal
- You should see your Licensee name and a heading for the Internal Dispute Resolution (IDR) submission window now open: Select +Start new transaction which is below this.
- Start a new transaction: You should see a title for Internal Dispute Resolution
- Select Submit Internal Dispute Resolution data report: Scroll down to end and select Launch transaction
- Transaction settings: Select No – allow access
- Entity details and Reporting period are prefilled. Select Yes as you need to submit an IDR data file
- File Upload: You then Upload the .csv file
- There is an initial validation check which you will need to pass.
- Progress through Contact Details and Review
- Declaration: This will be on behalf of the Regulated Entity and select the appropriate option. Then complete the declaration and submit.
You can simply go through the process again if you make a mistake and want to upload a new file. ASIC will pick up on 28 February 2026 the last file you uploaded.
Important: ASIC will complete a second (deep) validation check on your file. This may take up to 48 hours and ASIC will send an email to confirm whether the file has passed or failed the second validation. You should log back into the Regulatory Portal if you don’t receive an email within 48 hours as the status will also be reported there. The status will show as ‘Completed’ if it has passed the second validation.