Managed accounts governance: what the ASIC review means for platforms

ASIC's managed accounts compliance review is currently underway, with findings expected in the second half of 2026. The review is examining governance, suitability, and controls at the licensee level, which means it lands squarely on investment platforms. For most, the legal question is manageable. The harder question is operational: can you evidence how product decisions were made?

What is ASIC examining in its managed accounts compliance review?

ASIC senior executive Leah Sciacca has indicated publicly that the review focuses on how licensees and advisers are recommending managed accounts to retail clients, the governance behind those recommendations, whether suitability assessments are robust, and what controls are in place. The FSC confirmed the scope in its March 2026 Policy Update and has convened an expert group on good and poor practice, with findings expected later this year. 

This isn't primarily a product design review. It's a process review. ASIC wants to understand whether the decisions being made, about what to recommend, to whom, on what basis, are documented, defensible and consistent with the platform's stated obligations.

What governance gaps do most investment platforms have in managed accounts?

The gap we see most consistently is this: platforms have built strong front-end product capability and comparatively light back-end governance infrastructure. The product is well-designed. The governance documentation exists. But it was built to satisfy a requirement, not to reflect how decisions are made.

Specifically:

- TMDs that were written for initial product approval and haven't been meaningfully reviewed since launch, even as the product evolved and the distribution profile changed

- Review cycles that exist in theory but run inconsistently in practice, usually triggered by a specific event rather than a regular cadence

- Documentation of suitability considerations that sits at the adviser level, with the platform's view being that suitability is the adviser's responsibility - which is technically true, but not the whole answer under ASIC's current framing

What does ASIC expect platforms to do about managed accounts suitability?

ASIC's question to platforms isn't just "did advisers make appropriate recommendations?" It's "what did the platform do to ensure the conditions for good suitability decisions existed?" That's a different question, and it requires a platform-level answer. 

That means documented decision rights for managed accounts product decisions. It means TMDs reviewed on a schedule and updated when distribution or product characteristics change. And it means a clear, documented boundary between what the platform governs and what sits with the licensee or adviser - explicit, not assumed.

What does good managed accounts governance look like for a platform?

The platforms that are well-positioned for this review aren't necessarily the ones with the most sophisticated products. They're the ones where governance infrastructure was built with the same care as the product itself.

In practice that means: a governance framework that documents how managed accounts product decisions are made and by whom; TMDs reviewed at least annually with a record of that review; and a clear line between platform-level governance and licensee/adviser obligations that could be produced and explained on request.

The ambiguity in that boundary is where most of the ASIC risk lives. Resolving it before the findings come out is considerably easier than resolving it after.

When should platforms act on this?

Now, not after the report. ASIC will publish findings in the second half of 2026. The platforms in the best position will be the ones that have already done the work. The question "can we evidence how we made these decisions?" is one worth being able to answer at any point, not just when a regulator is asking.

What's your read on where the review will focus? I'm hearing different things from different parts of the market.

 *Mayflower Consulting works with investment platforms on product governance and operating model design. Matt Jose, our Senior Consultant, brings direct experience from HUB24. Get in touch if you'd like to talk through where you stand.