In brief

On 30 July 2026, following the consultation commenced through Consultation Paper 388 in March 2026, ASIC announced changes to net tangible assets requirement for responsible entities and confirmed that it will uplift the net tangible assets requirements for responsible entities, IDPS operators and corporate directors of retail CCIVs. ASIC has adopted the consumer price index (CPI)-linked option, increasing key thresholds and introducing annual indexation from 1 July 2027. More substantive proposals, including a higher concessional minimum or a per-scheme minimum, will not proceed at this stage. The changes preserve the existing net tangible assets (NTA) framework but require affected operators to assess capital, liquidity and compliance arrangements before commencement.

Key takeaways

• ASIC has chosen the least disruptive option. ASIC will increase the NTA thresholds in line with CPI, rather than adopting more significant structural changes canvassed in CP 388. The changes will be made to ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647 (Instrument 2023/647), while preserving the current concessional and non-concessional architecture.
• Key thresholds will increase. ASIC will raise:
  • The AUD 150,000 NTA minimum to AUD 200,000
  • The AUD 150,000 minimum cash or cash equivalents requirement to AUD 200,000
  • The AUD 500,000 NTA minimum to AUD 700,000
  • The AUD 5 million cap under the average value of fund assets limb to AUD 7 million
  • The AUD 10 million non-concessional minimum to AUD 14 million.

  These amounts will be subject to a further increase per the first annual indexation adjustment before they commence on 1 July 2027.
  
  

• Annual indexation will become part of the regime. ASIC will introduce an ongoing mechanism to index financial thresholds annually from 1 July each year, based on CPI growth over the year to March. This provides a more predictable mechanism for maintaining the real value of thresholds, but it will also require licensees to monitor future annual increases and build them into capital planning.
• More substantial reforms are deferred. ASIC will not proceed with a higher fixed concessional minimum, a per-scheme minimum, or broader concessional NTA reforms at this stage.
• Start preparations now. The changes will apply from 1 July 2027 to responsible entities, IDPS operators and corporate directors of retail CCIVs. Affected entities should assess whether additional capital, liquidity support, board approvals, financial forecasts, compliance monitoring or updates to internal policies will be needed before the new thresholds commence.

In more detail

Background

In March 2026, ASIC released CP 388 to consult on whether NTA requirements for responsible entities and related fund operators should be increased. As discussed in our previous client alert, Tightening the Belt: ASIC Consults on NTA, ASIC canvassed CPI-based threshold increases and more substantive reforms to the concessional NTA framework. ASIC has now published its final response, confirming a narrower CPI-linked uplift.

ASIC’s final position

ASIC has adopted Option 1 from CP 388, increasing the relevant NTA thresholds in line with CPI. CP 388 consulted on three options for increasing NTA requirements under ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647. ASIC received 18 submissions, including three confidential submissions. Responses were mixed, but Option 1 received the strongest support as a proportionate way to restore the real value of thresholds that have not been updated since 2013. ASIC will implement the uplift by amending Instrument 2023/647, which sets the financial resource requirements for responsible entities, IDPS operators and corporate directors of retail CCIVs.

What will change

The following financial thresholds will increase from 1 July 2027, subject to the first annual indexation adjustment:

• The AUD 150,000 concessional NTA minimum will increase to AUD 200,000
• The AUD 150,000 minimum cash or cash equivalents requirement will increase to AUD 200,000
• The AUD 500,000 NTA minimum will increase to AUD 700,000
• The AUD 5 million cap under the average value of fund assets limb will increase to AUD 7 million
• The AUD 10 million non-concessional NTA minimum will increase to AUD 14 million

ASIC will also introduce annual indexation from 1 July each year, based on CPI growth over the year to March. This implements the ongoing adjustment mechanism foreshadowed in CP 388 and avoids the need for infrequent larger threshold resets.

What will not change

ASIC has decided not to proceed with the more substantial alternatives raised in CP 388. It will not impose a higher concessional minimum of up to AUD 1 million, will not apply the minimum on a per-scheme basis, and will not otherwise restructure the concessional NTA requirement at this stage. ASIC acknowledged stakeholder concerns that those changes could increase barriers to entry, compliance costs and impacts on smaller operators.

There will be no change to how the applicability of the various NTA thresholds are determined. For example, if the concessional NTA minimum is currently applicable to you, it will continue to apply after the change (all else being equal and subject to the increase of the minimum amount).

ASIC also confirmed that the current review does not extend to other AFS licensees, although feedback on custodial and depository service providers and wholesale structures may inform future work. ASIC will update RG 166 to clarify that the average value of fund assets test does not capture schemes no longer operated by the responsible entity. Affected entities should now review capital forecasts, liquidity arrangements, financial covenants, board reporting and compliance monitoring processes.