When the Platform Does the Reporting, What Does the MDA Provider Still Need to Do?
“The platform can do the reporting, but the MDA Provider still owns the MDA compliance outcome.”
At MDA Guru, we work with a range of AFSLs that provide Managed Discretionary Account (MDA) services through regulated platforms.
One issue we believe deserves greater attention is the way annual MDA client reporting is managed where the regulated platform produces and sends the annual report directly to the client.
For many AFSLs, this arrangement works extremely well operationally. The platform maintains the portfolio information, calculates valuations, records transactions and fees, and provides the client with their annual investment report.
It is therefore understandable that an MDA Provider may consider its annual reporting obligations largely dealt with once the platform has issued the report.
However, relying on the regulated platform's annual reporting does not completely absolve the MDA Provider from its own MDA reporting obligations.
Importantly, this does not mean the AFSL needs to duplicate the platform's report or conduct another annual suitability review. The issue is more subtle — and it arises from the specific requirements of s912AEF of ASIC Corporations (Managed Discretionary Account Services) Instrument 2016/968.
The issue
There are two related, but separate, annual requirements within the MDA framework.
The first is the requirement for the MDA Provider to ensure that the client receives personal advice about whether the MDA Contract, including the Investment Program, remains suitable for the client's relevant personal circumstances. The relevant requirement is for this advice to be provided at least once every 13 months.
This is the substantive suitability review.
Many MDA Providers already have a well-established process for doing this, commonly around the anniversary of the client's MDA Contract.
The second requirement is annual client reporting under s912AEF.
This is where the regulated-platform model can create a compliance gap.
The platform may provide the client with the annual portfolio and transaction reporting required under the MDA framework. However, the platform will not necessarily have the information concerning the MDA Provider's own suitability advice.
That is because the platform generally does not determine:
when the MDA Provider or External MDA Adviser last provided the suitability advice;
the basis on which that advice was given; or
where the relevant Statement of Advice can be obtained.
Those matters remain connected to the MDA Provider's advice relationship with the client.
What does s912AEF actually require?
The important provision is s912AEF(4)(d) of Instrument 2016/968.
Where the relevant suitability Statement of Advice is not included with the annual report, the Instrument provides an alternative under s912AEF(4)(d)(ii).
The annual reporting can instead contain statements:
"(A) that a Statement of Advice which includes advice on whether the MDA contract for the person is suitable for the person’s relevant personal circumstances at a specified date from either the licensee or an external MDA adviser has been given to the person; and
(B) that a copy of the Statement of Advice is available from the licensee free of charge on request; and
(C) of the basis for the advice in the Statement of Advice."
This wording is important.
The requirement is not simply to tell the client that their MDA has been reviewed.
The reporting must identify the date of the relevant suitability advice, confirm that the Statement of Advice is available to the client free of charge on request, and provide a statement of the basis for that advice.
This is the part of the MDA reporting framework that can potentially be overlooked when the regulated platform is responsible for sending the annual report directly to the client.
The current Instrument also specifically accommodates MDA arrangements operated through regulated platforms. ASIC confirmed when the Instrument was introduced that the MDA regime incorporated relief for MDAs operated on regulated platforms.
But platform involvement does not mean that every MDA-specific obligation automatically becomes the platform's responsibility.
The solution does not require another suitability review
If the MDA Provider has already completed its suitability review around the client's MDA Contract anniversary, there is no reason to duplicate that review simply because the platform's annual report is subsequently issued.
Instead, the MDA Provider can use a short MDA Annual Reporting Notification to connect the platform's reporting with the suitability advice that has already been provided.
The notification could confirm that the client has previously received personal advice concerning the suitability of their MDA Contract and Investment Program, identify the date of that advice, briefly explain the basis on which the advice was provided, and advise the client that a copy of the relevant Statement of Advice is available from the MDA Provider free of charge upon request.
The letter can also remind the client to notify their adviser if there have been changes to their circumstances that could affect the suitability of their MDA.
This creates a simple division of responsibility:
The platform provides the portfolio and investment reporting.
The MDA Provider provides the MDA-specific information relating to the client's suitability advice.
There is no need to reproduce the entire SOA, and no need to conduct a second suitability review.
It can be a highly standardised process
From an operational perspective, the solution can be considerably simpler than it might initially appear.
The MDA Provider can develop one standard annual notification that is sent to clients whose annual platform reporting is provided directly by the platform.
Most of the letter can remain identical for every client.
The client-specific information can be limited to the relevant date of the suitability advice and an appropriate standard statement describing the basis of that advice.
For example:
Our records confirm that you were provided with personal advice regarding the suitability of your MDA Contract and Investment Program on [DATE].
The advice considered your relevant personal circumstances, including your investment objectives, financial circumstances, investment timeframe and tolerance for investment risk, together with the objectives and parameters of your Investment Program.
A copy of the relevant Statement of Advice is available from us free of charge upon request.
The precise wording should reflect the actual basis on which the MDA Provider or External MDA Adviser conducts its suitability assessment. However, the important point is that this can be systematised rather than recreated for every client each year.
Where MDA Guru can help
At MDA Guru, we see this as a relatively straightforward compliance issue that can be addressed without adding unnecessary administration to an MDA Provider's existing annual review process.
We can assist AFSLs to review their current MDA reporting arrangements, identify where responsibility sits between the MDA Provider and regulated platform, and develop a practical annual reporting process that addresses the requirements of the MDA Instrument.
This can include developing a standard MDA Annual Reporting Notification, establishing the appropriate wording for the statement concerning the basis of the suitability advice, determining what client-specific information needs to be populated, and integrating the communication into the AFSL's existing annual suitability-review cycle.
The objective is not to create another compliance process for the AFSL.
It is to close the gap between what the regulated platform provides and what the MDA Provider remains responsible for under the MDA framework — in a way that is simple, repeatable and capable of being applied across the entire MDA client book.
The MDA Guru view
The lesson is not that MDA Providers should stop relying on regulated platforms.
Quite the opposite. Platforms can provide significant operational efficiencies and are an important part of the modern MDA environment. ASIC's MDA framework expressly accommodates regulated-platform arrangements.
The lesson is that platform reporting and MDA reporting are not necessarily the same thing.
An MDA Provider can quite properly rely on the platform to deliver the portfolio and transaction information to the client while retaining responsibility for ensuring that the MDA-specific reporting requirements relating to the client's suitability advice are addressed.
For many AFSLs, the solution may be as simple as a well-designed annual client notification. The platform can do the heavy lifting on the investment reporting. The AFSL just needs to make sure the MDA-specific compliance piece does not get left behind.
“The platform can do the reporting, but the MDA Provider still owns the MDA compliance outcome.”
That is exactly the type of practical MDA compliance issue that MDA Guru helps AFSLs identify, document and resolve.
Regulatory references
ASIC Regulatory Guide 179 – Managed discretionary accounts (RG 179) provides ASIC's regulatory guidance on MDA services provided to retail clients. ASIC's current RG 179 was updated on 16 June 2025.
ASIC Corporations (Managed Discretionary Account Services) Instrument 2016/968, particularly the provisions relating to suitability, client reporting and regulated-platform arrangements, provides the legislative framework for the MDA relief and associated conditions. ASIC's current MDA page identifies RG 179 and Instrument 2016/968 as the key sources for MDA providers.
Regulatory status: ASIC consulted in March 2026 on the proposed remake of Instrument 2016/968, which is due to expire on 1 October 2026.