Submissions - 2025

Date Title & Summary Topic Area Sent to
25-Jul-2025

Economic Reform Roundtable Consultation

AFMA made nine recommendations to proposals to boost national productivity, dynamism, and growth in the financial services sector. 

Regulation Treasury
17-Jul-2025

Tranche 2 Exposure Drafts: Guarantee of Origin scheme

AFMA's submission recommended that the registration process and maintenance be as efficient as possible and that a coherent timetable for implementing the scheme would be beneficial to the market. AFMA expressed the view that a high functioning certificate register is key to the success of the scheme.

Regulation DCCEEW
14-Jul-2025

Firm Energy Reliability Mechanism – Stage 2

AFMA's submission proposed that FERM should be designed to work with the recommendations of the NEM Market Settings Review, noting that it was unclear why FERM needs to support long-duration firm capacity after the commencement of the NEM Market Settings Review’s recommendations.  In addition,  AFMA believes the proposed Reliability Obligation is unnecessary. AFMA recommended that units that do not receive payments under FERM should only be required to advise if they intend to close during the commitment period and should not be required to give a capacity commitment.

Regulation South Australian Government
11-Jul-2025

Issuer Reporting Standardisation

AFMA's submission welcomed  the recent development by the state and federal issuers of common bond turnover reporting standards, while seeking clarity on technical matters. 

Regulation AOFM
10-Jul-2025

IRSR arrangements – Directions Paper

AFMA's submission did not support the rule change and views that the proposed option will increase prices for consumers.  Further, AFMA noted that the rule change process has left inadequate time to properly consider the issues identified during consultation.  

Regulation AEMC
30-Jun-2025

Anomalous Order Thresholds (AOT) on ASX 24 products

AFMA's submission provided feedback to the consultation questions and also suggested consideration of extension of Price Limits (AOT/ETR) to IR Futures.

Regulation ASX
27-Jun-2025

Consultation on the Second AML/CTF Rules Exposure Draft

AFMA's submission supports a set of Rules that gives effect to the FATF recommendations, respects the primacy of comparable FATF-compliant jurisdictions and facilitates compliance in a risk-based manner. The submission sets out a number of potential enhancements to the current draft Rules. 

Regulation AUSTRAC
27-Jun-2025

Proposed amendments to IFRS S2

AFMA's submission broadly supported the ISSB's amendments and encouraged permitting early adoption. AFMA sought clarity regarding treatment of REPOs, Reverse REPOs and Options.

Regulation International Sustainability Standards Board
13-Jun-2025

2025 Rules Consultation

AFMA's submission proposed that to the extent that AFCA amends its Rules to allow jurisdiction to investigate scam-related complaints against banks where the complainant is not a customer, the scope of “bank” for this purpose should only be those banks authorised by APRA to provide services to retail customers.

Regulation AFCA
11-Jun-2025

Cboe Australia Listings

AFMA's submission welcomed Cboe proceeding with its plans for listings and the increased competition it will bring. AFMA encouraged Cboe to ensure regulatory consistency between its different listing entities and measures to support the  success of the listings.

Regulation Cboe
11-Jun-2025

Extraterritorial application of NFA rules to non-US Swap Dealers

AFMA's submission highlighted that we were not aware of any similar comparability assessment nor cross-border relief from NFA compliance rules to non-US swap dealers for activities that are outside the scope US swap dealing with US Persons and that the absence of any relief impacts Australian non-US Swap dealers who (for prudential reasons) include swap dealer activity within the same legal entity as the retail, business, institutional, broker-dealer and treasury activities.  

Regulation National Futures Assocation
11-Jun-2025

2025 Energy Savings Scheme and Peak Demand Reduction Scheme statutory reviews

AFMA agreed that the ESS and PDRS have functioned efficiently and that we view the ESS surplus and decreasing price signals a successful market. 

Regulation NSW Government
11-Jun-2025

Pillar 5: Investing in cheaper, cleaner energy and the net zero transformation

AFMA expressed that the NEM Wholesale Market Settings Review, combined with the Safeguard Mechanism, should provide policy certainty to manage the energy market transition and that clearer , more consistent policy to support the role of gas through the transition is required.

Regulation Productivity Commission
11-Jun-2025

Pillar 1: Creating a more dynamic and resilient economy

AFMA's submission to the Productivity Commission highlights tax frictions that hamper investment and generate compliance costs. AFMA's submission suggested that  financial sector participants are facing increasing regulatory burden and included areas for reform. 

Regulation Productivity Commission
06-Jun-2025

Consultation on reform areas

AFMA re-stated its support for Government to adopt a more pro-innovation approach as is the case in the UK and US rather than one more aligned with the restrictive EU and Canadian regulatory regimes. While supportive of the proposed CDR scheme reset, AFMA's submission stated   it does not go sufficiently far to address these  issue.  

Regulation Productivity Commission
06-Jun-2025

Governance Review Discussion Paper

While supportive of APRA's initiatives to strengthen the prudential governance framework, AFMA made eight recommendations that to safeguard Boards' capacity to support and drive growth and innovation within their organisations.

Regulation APRA
19-May-2025

Consultation Paper 383 Reportable situations and internal dispute resolution data publication (CP 383)

 AFMA's submission highlighted that we do not support the reporting of firm-level data for Reportable Situations reporting, particularly for wholesale clients. 

Regulation ASIC
16-May-2025

Mergers reform – notification thresholds instrument – exposure draft

 AFMA's submission seeks additional clear exclusions in the Determination for transactions used in wholesale financial markets. 

Regulation Treasury
15-May-2025

Cash Credit Support – Draft Determination

AFMA was supportive of making this rule change and believes that the cash cap should be increased to more than $50 million. AFMA's submission recommended that prudential supervision requirements for credit support providers should remain aligned with broader financial service law.

Regulation AEMC
09-May-2025

International Alignment of Required Stable Funding Factors

AFMA writes to APRA seeking consideration of aligning two Required Stable Funding (RSF) factors to increase efficiencies in financial markets and reduce a competitive disadvantage faced by Australian banks.

Regulation APRA (Ms Santosaputri)
08-May-2025

PASA rule change request

AFMA's submission was supportive of the the introduction of a gas PASA and AFMA submitted that the PASA should be published frequently enough to meet the needs of the market.

Regulation AEMC
07-May-2025

ETD TradeAccept System Replacement

AFMA submitted that given the specific nature of the questions asked  were best answered by individual firms, and this is appropriate to give ASX a view of the technical preferences of its participants.

Regulation ASX
07-May-2025

Australia’s evolving capital markets: A discussion paper on the dynamics between public and private markets

AFMA's submission highlighted the consensus view of our membership is that there is a mix of cyclical and structural drivers in the growth in private capital markets. AFMA sees substantial scope for increasing the attractiveness of public markets through adjustments to laws, regulations and regulatory stances by ASIC, many of which could be readily implemented. AFMA explained that private markets fulfil a different function to public markets, and we do not believe that the two necessarily need to align and that caution needs to be exercised in imposing additional law and regulation on private markets.

Regulation ASIC
02-May-2025

Energy Savings Scheme Rule and Regulation Change 2025

AFMA's submission expressed that the current high-volume methodologies should not be retired until appropriate replacement methodologies are in place and that proposals that risk supply, market liquidity and consumer prices should be reconsidered.

Regulation NSW DCCEEW
17-Apr-2025

Gas Reliability Standard- Initiation

AFMA supports the proposed introduction of a gas reliability standard and formalised reviews of gas market settings; however, AFMA's submission expressed that the standard should be set by an independent panel rather than the AEMC.

Regulation AEMC
27-Mar-2025

Future Made in Australia (Guarantee of Origin) Rules 2025

AFMA urged DCCEEW to provide implementation timeframes for all products. The submission also expressed that development of the register should be prioritised and that consultation on storage, hybrid systems and below baseline should begin. 

Regulation DCCEEW
10-Mar-2025

Strategic Review of the Energy Efficiency Upgrades Program

AFMA's submission welcomed  the review but stated that certifying new, durable and scaleable methodologies should be of highest priority. Likewise, additional measurers should be taken to ensure that market participants are fit and proper.

Regulation Victorian Government
28-Feb-2025

NEM Settings Review Initial Consultation

AFMA's submission highlighted that the review should look to restore the decisive role of the market in NEM investment and that sucessfully managing the retirement of coal units is critical to allowing the energy market to navigate the energy transition. 

Regulation NEM Settings Review Panel
21-Feb-2025

Positioning Australia’s financial reporting system for the future

AFMA's submssion did not support the proposalson the basis that they have not been adequately developed with the aid of industry consultation and are not acceptable in their current form.

Regulation Treasury
20-Feb-2025

Pre-hedging Consultation Questions Responses

AFMA provided responses to IOSCO's consultation questions. While AFMA was in agreement on some elements, AFMA made a series of drafting recommendations, fundamentally not agreeing with the definition of pre-hedging.

Regulation IOSCO
07-Feb-2025

Review into Small and Medium-sized Banks

AFMA’s submission highlighted challenges and opportunities regarding the evolution of Australia as a financial services centre and both the role and importance of foreign banks in Australia. 

Regulation CFR and ACCC
07-Feb-2025

Victorian Industrial Renewable Gas Guarantee

AFMA's submission supported the proposed market-based certificate scheme and that the costs of the scheme should be borne by all users. 

Regulation DEECA
31-Jan-2025

PEMM Act Review

AFMA's submission set out that the concerns the PEMM Act was intended to address are better dealt with by other regulation and that the provisions have been ineffective and should be repealed. AFMA recommended that theACCC’s Electricity Pricing Inquiry should conclude as scheduled in 2025.

Regulation Department of Climate Change, Energy, the Environment and Water
31-Jan-2025

AFMA 2025/26 Pre-Budget Submission

AFMA's submission highlighted that foreign banks are a crucial element of the Australian economy that need to be more appropriately considered in policy formation. In addition, the submission noted that Australia’s financial centre competitiveness has been in continuous decline since the Royal Commission/pandemic and AFMA belives Australia should prioritise initiatives to boost Australia’s attractiveness as a place to do business. 

Regulation Treasury
30-Jan-2025

PEC – Draft Determination

AFMA’s submission supported the AEMC’s decision to adopt AEMO’s approach to allocating positive residues.  However, AFMA remains unconvinced that there is a need for a broader review of SRA at this time.

Regulation AEMC
16-Jan-2025

Setting new targets for the Victorian Energy Upgrades program

AFMA's submission stated that there is currently inadequate VEEC supply to meet demand and that targets should be aligned with realistic expectations of the volume of VEECs expected to be created. 

Regulation Victorian Department of Energy, Environment, and Climate Action
16-Jan-2025

Enhanced beneficial ownership disclosure for listed entities

AFMA's submission stated that the changes that are proposed are too complex in their implications and that the proposed amendments to the current regime extend beyond FATF recommendations relating to beneficial ownership and beyond listed company disclosure requirements in other jurisdictions.

Regulation Treasury
09-Jan-2025

Scam Prevention Framework Bill 2024

AFMA submitted that the ADIs that should be subject to the Mandatory Code are only those that are authorised by APRA to provide services to retail customers, as opposed to all ADIs. The Impact Statement that accompanies the Explanatory Memorandum should not undermine the Minister’s authority to designate regulated sectors/services by assuming that foreign bank branches are within regulatory scope.  

Regulation Senate Standing Committees on Economics