GRC Report Staff

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.

EIOPA's final Q&A (ID 3528) states that derivatives, including forward bond contracts, should not be included in the market value of fixed-income assets (MVFI). Whether repacks are included depends on their contractual specifics. Insurers using long-term guarantee measures should review how they classify these exposures, because the classification affects the calculation.

ASIC's Form 397 is the mechanism for notifying ASIC that directors of a listed company or listed registered scheme have approved an auditor's continuation for up to two successive financial years beyond the five-year limit in s324DA(1). The resolution must be lodged within 14 days of its date to be relied upon, and late lodgement means the form is rejected and a new resolution is required. Compliance and company secretarial teams should build this timing and the s324DAB content requirements into their auditor rotation calendars.

ASIC's Form 5240 is the mechanism a corporate collective investment vehicle (CCIV) must use to notify ASIC of a proposed sub-fund name change under the Corporations Act 2001. The form carries strict lodgement windows of 14 or 60 days depending on the trigger, and late fees apply. Compliance teams at CCIV operators should confirm that their name-change workflows meet these deadlines and the related requirements.