Why fund managers with 50+ products are still updating PDSs in spreadsheets

Most Australian fund managers with large product ranges are still managing PDS updates through spreadsheets, shared drives, and email chains, not because they haven't thought about it, but because the process was built for 10 products and scaled to 60 without ever being redesigned.

That's the core problem. Not the tools. The structure.

Why does PDS management break down as product ranges grow?

When a fund manager has 10 products, a shared drive and a tracking spreadsheet are fine. Version control is manageable, everyone knows where things live and one person can hold it in their head.

At 50 or 60 products, the same approach creates a different set of problems. Versions multiply. Review sequences get murky, legal is reviewing the same section compliance is reviewing and they're not talking to each other. Annual review dates slip because they live in someone's calendar, not a system. And critical process knowledge lives in two or three people’s heads. When they leave, reconstruction takes weeks.

None of this is negligence, it's what happens when you patch a process that needs redesigning.

Does adding more PDS staff fix the problem?

No - and this is the most common mistake. Hiring more people to manage a broken process adds coordination overhead without fixing the underlying structure. You end up with more email chains, more risk of things falling between two people who both assumed the other had it covered and a team that's always busy but never quite ahead.

The fund managers with the smoothest PDS operations aren't the ones with the biggest teams. They're the ones with the clearest process: a single source of truth, defined ownership at each review stage and a review calendar that runs automatically.

What does a well-run PDS operating model look like?

The fundamentals aren't complicated:

- one system of record for all documents, not a shared drive with subfolders
- clear ownership at each stage: who drafts, who reviews, who approves, in what sequence
- a scheduled review calendar that doesn't depend on anyone remembering
- standardised templates across the range, so you're not rebuilding the wheel for each new product

This isn't about technology. It's about deciding how the work will be structured and restructuring it, rather than adding another layer on top of what already exists.

What does ASIC's updated disclosure guidance mean for PDS process?


ASIC updated its regulatory guides on product disclosure in late 2025. The content requirements haven't changed dramatically, but the expectation that issuers can demonstrate a consistent, controlled production process has increased. If your PDS operation runs on spreadsheets and shared drives, the question isn't just whether the content is right, it's whether you can evidence the process that produced it. That's a harder question to answer without a proper operating model behind it.

How long does it take to fix a broken PDS process?

In our experience, fund managers who commit to rebuilding their PDS operating model see the time investment pay back within six months: fewer reviews that run long, fewer version errors, faster turnaround on regulatory updates. The rebuild itself, depending on the size of the range and the current state, typically takes eight to sixteen weeks of focused effort. It doesn't require a lengthy transformation program.

Is your PDS process built for the product range you have now, or the one you had five years ago?


*Mayflower Consulting helps Australian fund managers build PDS operating models that scale. If this resonates, get in touch.