ASIC and MAS shift to data scrutiny: what it means for regulatory reporting
Through recent discussions in Sydney and Singapore and ongoing work with firms in the region, I’ve seen a clear shift in APAC regulatory reporting: from implementation to data scrutiny and supervision.
It’s clear that attention has moved beyond how firms implemented the 2024 rewrites, and onto the quality of the data being reported. ASIC’s recent review of the contracts for difference (CFD) sector reinforces this position.
Where discussions previously centred on readiness and interpretation, they are now focused on identifying data issues, understanding inconsistencies, and addressing the root causes of poor data quality.
This follows a familiar pattern. In the UK and EU under EMIR Refit, regulators have moved from implementation to identifying outliers, challenging firms and ultimately enforcing remediation and fines. ASIC is already well into this process, with MAS moving in the same direction.
Gaps in data quality are increasingly visible
As supervision increases, weaknesses in reported data are becoming more apparent.
UPI is emerging as a key issue. The current framework allows for inconsistencies between the UPI and other reported fields, with limited validation to catch errors. In some cases, this creates structurally correct but fundamentally inconsistent reporting (what we call the ‘valid but wrong‘ scenario), with the added risk of distorting how trades are interpreted from a risk perspective.
At the same time, longstanding challenges remain. Collateral and valuation reporting, despite being calculated daily by firms, are still not consistently reflected in regulatory submissions. This creates a disconnect between internal systems and reported data, making it difficult for regulators to assess true exposure.
Complexity is increasing but clarity isn’t
Firms are navigating growing complexity across reporting regimes, but without a corresponding increase in regulatory clarity. A consistent theme from firms was the lack of detailed, scenario-based guidance. In its absence, interpretation varies and over time, those inconsistencies become the outliers regulators focus on.
At the same time, global firms are managing ongoing regulatory change. ESMA’s simplification agenda across MiFIR, EMIR and SFTR is being closely watched, but simplification does not reduce the cost of compliance. Each change introduces implementation effort, resource constraints, and trade-offs with other priorities.
Beyond the headline regimes, firms are also contending with requirements across KRX, JFSA, HKMA and others, all of which demand the same level of control and oversight, often with less guidance available. This is something we are seeing consistently across firms we work with in the region.
What this means for firms
The key question from regulators now is can your data be trusted?
Firms that continue to treat data quality as a technical or operational issue will struggle to keep pace with this shift. Across our work with firms in APAC, those that are ahead are treating data quality as a control framework, supported by independent testing, and clear ownership.
As supervision increases, so does the cost of getting it wrong. As we all know, remediation programmes are expensive, time-consuming, and highly visible.
Ensuring data quality upfront is no longer just about compliance. It’s about reducing risk, controlling costs, and maintaining confidence in reported data.
Kaizen supports firms globally with independent regulatory reporting quality assurance, helping them identify gaps in controls, strengthen governance and evidence reporting quality before issues surface with regulators. Contact us for a conversation about how we can help you.
