GRC Report Staff

Effective July 23, 2026, the AFM has discontinued the mandatory three-yearly reliability reassessment of (co-)policymakers at financial undertakings in Bonaire, St. Eustatius, and Saba. The obligation to report relevant changes or new facts affecting reliability without delay remains fully in force. Compliance teams should shift from calendar-driven reassessment preparation to event-driven monitoring and escalation.

ASIC has published Form 5113 (version dated December 12, 2024) for compliance plan auditors seeking consent to resign from a registered scheme under section 601HH(2) of the Corporations Act 2001. The form is optional, but it consolidates the declarations, supporting documents, and timing expectations ASIC applies under Regulatory Guide 26. Responsible entities and auditors should plan any auditor transition well ahead, because ASIC consent is not automatic and cannot be back-dated.

ASIC's Form CF08 is the prescribed notice that entities must lodge to rely on Class Orders [CO 14/1000] (listed bodies) and [CO 14/1001] (unlisted bodies) for employee incentive scheme offers. There is no lodgement fee and the form is not published on ASIC's public register, but failing to lodge a valid notice could jeopardize the disclosure relief. Compliance teams should confirm that their equity plan processes include accurate and timely CF08 lodgement.

The Information Commissioner's Office has revised its Freedom of Information Act guidance on the public interest test to reflect the Supreme Court's ruling in DBT v ICO [2025] UKSC 27, which permits public interest factors supporting multiple qualified exemptions to be weighed cumulatively against disclosure. The update also sets out expectations for refusal notices and for handling ICO complaints. Compliance teams at organizations subject to FOIA, or that supply information to public authorities, should review their withholding procedures and templates.

ASIC's Form 5211 is the mechanism by which a retail corporate collective investment vehicle (CCIV) lodges its annual compliance plan audit report under s1226G(4) of the Corporations Act 2001. The corporate director must lodge within three months of financial year-end and disclose whether the auditor issued a qualified opinion on compliance or on plan adequacy. Compliance teams should build this filing into their annual calendars to avoid late fees and regulatory scrutiny.

In a speech at TradeTech FX, DNB's Bas ter Weel argued that tokenized financial markets, including FX, must be anchored in central bank money to preserve stability and trust. He highlighted the Eurosystem's Pontes wholesale CBDC bridge, MiCAR safeguards for stablecoins, and interoperability as priorities. Compliance teams should treat this as a signal of supervisory expectations for DLT settlement, stablecoin exposure, and tokenized deposit initiatives.

The SEC Office of Municipal Securities issued a staff statement explaining when a non-solicitor municipal advisor's participation in drafting, reviewing, or assembling disclosure documents is "advice" and municipal advisory activity, and how antifraud and fiduciary exposure follows. It creates no new legal obligations, but it shows how staff will assess advisor liability. Compliance teams should use it to recalibrate engagement scopes, supervisory controls, and disclosure-related practices.