ASIC Regulatory Guide 271 — Internal Dispute Resolution¶


Regulator	ASIC
Jurisdiction	AU
Status	live
Applicability	Platform

ASIC Regulatory Guide 271 (Internal Dispute Resolution, effective 5 October 2021) sets the IDR standard for all Australian Financial Services Licensees and Australian Credit Licensees. It replaced RG 165 as the definitive IDR standard and introduced binding timeframe obligations, specific content requirements for IDR responses, and a systemic issue identification obligation.

RG 271 is given legal force by ASIC's Complaints (Internal Dispute Resolution) Instrument 2020/98, which is a legislative instrument binding on all licensees. Non-compliance with the Instrument can result in licence conditions, enforceable undertakings, or civil penalty proceedings. IDR data is also reportable to ASIC under the IDR Reporting Instrument.

Compliance register¶

This register maps every material obligation under RG 271 to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Acknowledgement and recording¶

Ref	Obligation	Scope	Policy	Platform controls	Build
RG 271.46	Acknowledge receipt of a complaint promptly; for credit complaints, acknowledge within 24 hours	🤖 Automated	CON-002	MOD-053 (AUTO) — complaint intake triggers automatic acknowledgement dispatch within 24 hours; SLA timer starts at complaint creation; no manual step required for acknowledgement	🔨
RG 271.47	Record all complaints in a register with required fields (date, nature, outcome)	📊 Evidenced	CON-002	MOD-053 (LOG) — all complaints recorded with date, channel, nature, assigned handler, and resolution outcome; register is always current	🔨

Timeframes¶

Ref	Obligation	Scope	Policy	Platform controls	Build
RG 271.54	Respond to credit complaints within 30 calendar days	🤖 Automated	CON-002	MOD-053 (ALERT) — 30-day SLA timer enforced automatically; escalation alert triggered at Day 20 (warning) and Day 28 (breach imminent); complaint cannot be closed without a final response on file	🔨
RG 271.55	Respond to general banking complaints (non-credit) within 30 calendar days (with limited exceptions up to 45 days for complex matters)	🤖 Automated	CON-002	MOD-053 (ALERT) — SLA timer calibrated per complaint category; extension to 45 days requires documented justification and customer notification, both enforced by workflow	🔨
RG 271.63	If timeframe cannot be met, notify the complainant and provide updated timeline; inform them of AFCA referral right	🤖 Automated	CON-002	MOD-053 (AUTO) — SLA breach notification dispatched automatically; AFCA right-to-refer is a mandatory element of the breach notice template; MOD-083 (AUTO) — agent is coached on required disclosures in real time	🔨

IDR response content¶

Ref	Obligation	Scope	Policy	Platform controls	Build
RG 271.73	IDR response must include: outcome decision and reasons; information about the complainant's AFCA right; AFCA contact details; statement that AFCA is free for consumers	🤖 Automated	CON-002	MOD-053 (AUTO) — final IDR response template enforces all required content elements; system prevents closure without confirming each mandatory element is present; MOD-083 (AUTO) — IDR response obligations surfaced to agent during complaint handling	🔨
RG 271.76	Where complaint is not upheld, reasons must be adequate and not generic	📊 Evidenced	CON-002	MOD-053 (LOG) — response reasons are recorded as structured text; quality is a human obligation; platform ensures reasons are present and logged but does not validate adequacy	🔨
RG 271.47	Maintain complaint records for 7 years	📊 Evidenced	CON-002	MOD-047 (LOG) — all complaint records, actions, and outcomes are retained in the immutable audit log; records cannot be deleted	🔨

Systemic issue identification¶

Ref	Obligation	Scope	Policy	Platform controls	Build
RG 271.85	Identify systemic issues from complaint patterns; escalate to management for root cause analysis	📊 Evidenced	CON-002	MOD-053 (LOG) — complaint categorisation data enables pattern analysis; systemic issue identification requires human review of complaint trends; platform provides the data; analysis and escalation is institutional	🔨
RG 271.86	Where systemic issue identified, proactively remediate affected customers	🏛 Institutional	CON-002	Remediation programme design and execution is institutional. Platform evidence inputs: MOD-053 identifies affected case cohort; MOD-047 provides audit trail for remediation activity.	—

IDR data reporting to ASIC¶

Ref	Obligation	Scope	Policy	Platform controls	Build
IDR Reporting Instrument 2022	Report IDR data to ASIC twice yearly (March and September reporting periods) including complaint volumes, types, timeframes, and outcomes	📊 Evidenced	CON-002	MOD-053 (LOG) — complaint register provides all data fields required by the ASIC IDR Reporting Instrument; data extraction for ASIC report submission is available but not yet automated; human finance/compliance team prepares submission	🔨

Institutional obligations (not platform scope)¶

The following obligations under RG 271 are the responsibility of the institution, not the platform.

Obligation	Owner	Platform evidence input
Staff training on IDR obligations and complaint handling procedures	Head of Customer Experience	MOD-083 provides real-time coaching; formal training is institutional
Root cause analysis programme for systemic issues	Chief Compliance Officer	MOD-053 provides complaint data for analysis
Senior management oversight of IDR performance	CEO / Chief Compliance Officer	MOD-053 complaint register provides management reporting data
IDR policy documentation and annual review	Chief Compliance Officer	—

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊	Institutional 🏛
Acknowledgement and recording	2	1	1	0
Timeframes	3	3	0	0
IDR response content	3	1	2	0
Systemic issues	2	0	1	1
ASIC reporting	1	0	1	0
Total	11	5 (45%)	5 (45%)	1 (9%)

All attributed modules are currently build_status: Not started — the compliance position will update as modules are built and deployed.

Policy	Title
CON-002	Complaints & Internal Dispute Resolution Policy

Official documentation¶

Policies referencing this standard¶

CON-002 — Complaints & Internal Dispute Resolution Policy

Compiled 2026-05-22 from source/entities/regulations/au-asic-rg-271.yaml