Introduction
On 30 July 2026, ASIC confirmed the first increase to the minimum financial thresholds for responsible entities since 2013. The new requirements will take effect on 1 July 2027 and introduce a significant structural change: from that date onward, the thresholds will be adjusted annually in line with inflation.
The increases apply to:
- Responsible entities of registered managed investment schemes
- Operators of investor directed portfolio services (IDPS)
- Corporate directors of retail corporate collective investment vehicles (CCIVs)
These changes do not apply to managers that operate only wholesale funds.
What ASIC Announced
The decision follows Consultation Paper 388, released in March 2026, which presented three possible approaches to updating the financial requirements.
ASIC adopted the option that received the strongest industry support—raising each threshold to reflect cumulative Consumer Price Index (CPI) growth between June 2013 (when the thresholds were last updated) and March 2026. The resulting figures were rounded to the nearest $100,000 or $1 million, depending on the requirement.
The amendments will be implemented through updates to the ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647, with corresponding changes to Regulatory Guide 166.
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The New Financial Thresholds
| Requirement | Current | From 1 July 2027 |
|---|
| Minimum NTA | $150,000 | $200,000 |
| Minimum cash or cash equivalents | $150,000 | $200,000 |
| Minimum NTA where Tier $500,000 class assets are held | $500,000 | $700,000 |
| Cap on the average value of fund assets limb | $5 million | $7 million |
| Minimum NTA under the non-concessional requirement | $10 million | $14 million |
The figures that commence on 1 July 2027 will already include the first annual CPI indexation adjustment, meaning the final commencement amounts may be slightly higher than those currently published.
Understanding the NTA Requirement
Under the concessional calculation, a responsible entity must maintain Net Tangible Assets (NTA) equal to the greatest of:
- The fixed minimum dollar amount;
- 0.5% of the average value of fund assets (up to the applicable cap); or
- 10% of average revenue.
A portion of the required NTA must be held as cash or cash equivalents.
Entities that do not qualify for the concessional calculation—typically because of the way scheme property is held—must instead satisfy the higher non-concessional minimum.
ASIC has stated that these requirements are intended to:
- Provide sufficient funds to transition a scheme to a replacement operator if the business fails.
- Align the interests of fund operators with investors;
- Ensure operators can meet ongoing operating costs; and
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Annual Indexation Is the Major Structural Change
While the higher dollar thresholds are relatively straightforward to model, the more significant change is the introduction of annual CPI indexation.
Beginning in 2027, the thresholds will automatically increase every year based on CPI growth over the year ending in March, with the revised figures taking effect on 1 July each year.
As a result, an NTA buffer that comfortably exceeds today’s requirements may gradually diminish over time if capital levels remain unchanged.
Boards and fund operators should therefore shift from reviewing their capital position only occasionally to incorporating annual threshold increases into their ongoing capital planning process.
What Fund Operators Should Do Now
Fund operators should begin preparing well before the 1 July 2027 commencement date by:
- Recalculating their NTA position using the new thresholds to determine which requirement becomes binding.
- Modelling capital requirements beyond July 2027, including future annual indexation.
- Identifying funding strategies early, whether through retained earnings or capital injections.
- Reviewing custody and scheme property arrangements, as these may affect whether the concessional or non-concessional calculation applies.
- Monitoring the release of the amending instrument and the updated Regulatory Guide 166 to confirm the final commencement figures.
Conclusion
Boards and operators who leave this to the last minute risk breaching their licence conditions or running with a capital buffer that quietly evaporates under annual indexation. Now is the time to model the impact, plan funding options and tighten governance around how you monitor NTA against rising thresholds each year.
If you operate registered schemes, IDPS platforms or retail CCIVs and want to understand how these changes apply to your structure, our senior Corporate & Commercial lawyers can help you assess your current position and design a compliant capital and governance framework ahead of 1 July 2027. Reach out if you’d like a tailored review of your arrangements and a clear action plan.
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Disclaimer: This article provides general information only and does not constitute legal advice. You should obtain professional legal advice that is specific to your circumstances.