Submissions - 2025

Date Title & Summary Topic Area Sent to
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