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Regulatory Update

ASIC CP 377 and the Future of Managed Accounts

Turing Dynamics

Regulatory Intelligence

March 20263 min readASIC

Jurisdiction

Australia

Effective Date

1 March 2026

Regulator

ASIC

Managed account operators will need stronger demonstrability around portfolio governance, client suitability, and evidence retention.

ASIC's consultation work on managed accounts signals a more explicit expectation that operators be able to demonstrate not only what they did, but why the decision path was appropriate for the client and evidenceable after the fact.

That shifts the burden onto infrastructure. A platform that simply records trades and reconstructs rationale later will struggle to produce the level of traceability regulators are increasingly expecting. Suitability, portfolio intent, approval state, and execution context need to be bound together.

For firms building or buying MDA technology, the practical question is whether the system can produce a coherent evidence chain at any moment in time. Turing Dynamics treats CP 377 as further confirmation that governed execution and evidence-led operations are becoming baseline infrastructure requirements.

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