ASIC Lifts Minimum NTA Requirements for Fund Operators from 1 July 2027

Published 22 October 2026

Introduction

Responsible entities of registered managed investment schemes, operators of investor directed portfolio services (IDPS), and corporate directors of retail corporate collective investment vehicles (CCIVs) face higher net tangible assets (NTA) thresholds from 1 July 2027, after ASIC confirmed its final position on 30 July 2026.

What Is Changing

ASIC’s financial requirements for these operators set minimum NTA and liquidity levels designed to ensure they can meet their obligations and absorb losses without putting investor money at risk. Those thresholds were last set in June 2013 and had not moved since, despite thirteen years of inflation.

Following Consultation Paper 388 (March 2026) and eighteen submissions from industry, ASIC adopted the least disruptive of the options on the table: a straight CPI-linked uplift of the existing dollar thresholds, rather than a new per-scheme minimum or a higher concessional base. Industry reporting on the reforms puts the practical effect at:

• the $150,000 base NTA minimum rising to $200,000;
• the $150,000 minimum cash or cash equivalents holding rising to $200,000;
• the $500,000 NTA minimum (for operators holding scheme property) rising to $700,000;
• the $5 million cap under the average value of scheme assets limb rising to $7 million; and
• the $10 million non-concessional NTA minimum rising to $14 million.

ASIC will confirm the final figures when it amends ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647, and when it updates Regulatory Guide 166 to match, both expected in the months ahead.

Indexation Going Forward

The thresholds will no longer sit still for another thirteen years. From 1 July 2027, ASIC will index the NTA requirements annually, with the 1 July 2027 figures already carrying the first year’s adjustment built in.

Affected operators should expect the minimums to move each year from then on, and should build that into ongoing capital planning rather than treating 1 July 2027 as a one-off step change.

What Operators Should Do Now

The commencement date is nine months out, but balance sheet and liquidity positions take time to adjust. Responsible entities, IDPS operators and retail CCIV corporate directors should, ahead of 1 July 2027:

• recalculate their NTA position against the higher thresholds, using both the existing and the indicative uplifted figures;
• review surplus liquid funds and cash or cash equivalent holdings against the new minimums;
• check whether capital raising, a change of structure, or a change of custody or outsourcing arrangements will be needed to meet the higher bar; and
• watch for the amended Instrument 2023/647 and the updated RG 166, which will fix the final figures and any transitional detail.

How GRM LAW Can Help

GRM LAW advises responsible entities, fund operators and corporate directors on financial requirements, licensing conditions and managed investment scheme compliance. Operators wanting to understand how this change affects their own capital position should speak with our funds and financial services regulation team.

Disclaimer: This article is general information only and is not legal advice. It does not consider any particular operator’s circumstances.