How do I keep track of all my compliance obligations?
The best way to keep track of your compliance obligations is to maintain a central obligations register that clearly identifies each requirement, assigns ownership, sets review dates and links each obligation to the controls and evidence that demonstrate compliance. Regular monitoring helps ensure obligations remain current and nothing is overlooked.
The detail
Keeping track of compliance obligations can quickly become challenging for AFSLs and ACLs. Regulatory requirements come from multiple sources, including legislation, ASIC regulatory guides, licence conditions, internal policies and business commitments. As your business grows, so does the number of obligations that need to be monitored.
Many firms start with spreadsheets or shared documents. While these may work initially, they often become difficult to maintain. Different versions circulate, responsibilities change, and it becomes unclear whether an obligation has been reviewed or completed.
The result is that important activities can be missed. Annual policy reviews, breach reporting assessments, compliance monitoring, training, risk reviews and board reporting may all rely on individuals remembering what needs to happen.
Good compliance practice starts with understanding what your obligations are and ensuring each one has a documented process for managing it. An effective obligations register should identify:
- The source of the obligation.
- What the obligation requires.
- Who is responsible for meeting it.
- How compliance is monitored.
- What evidence demonstrates the obligation has been met.
- How often the obligation is reviewed.
For example, an obligation to maintain staff competence should not simply appear as a line in a register. It should be linked to training requirements, competency assessments, supervision activities and records demonstrating those activities have been completed.
This approach provides a clearer picture of your compliance framework and makes it much easier to demonstrate effective governance during an ASIC surveillance, audit or board review.
A better way to manage this
Rather than maintaining multiple spreadsheets and calendars, centralise your obligations in a single system that connects obligations with the activities required to manage them.
Where configured, [complyᵉ] can help maintain an obligations register, assign responsibility, schedule recurring compliance activities and capture evidence as work is completed. Linking obligations to monitoring, actions, incidents and reporting improves visibility and helps demonstrate that compliance is being actively managed rather than simply documented.
This creates greater accountability, reduces duplication and provides management with clearer oversight of outstanding obligations and emerging risks.
Practical guidance
- Identify every regulatory, licence and internal obligation that applies to your business.
- Assign a responsible owner for each obligation and define their accountability.
- Link each obligation to the policies, controls, monitoring activities and evidence that support it.
- Review your obligations register regularly to reflect regulatory changes and business developments.
- Report on the status of key obligations so management and directors have ongoing visibility.
Common mistakes
- Maintaining multiple obligation lists. Different versions create confusion and increase the risk of missed activities.
- Recording obligations without assigning ownership. An obligation without accountability is unlikely to be managed consistently.
- Failing to connect obligations to evidence. Knowing an obligation exists is not enough if you cannot demonstrate how it is being met.
- Only reviewing obligations when an audit occurs. Compliance should be monitored continuously, not just when external scrutiny is expected.
See how [complyᵉ] helps centralise your compliance obligations, improve accountability and maintain clear evidence that each obligation is being actively managed.
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