The RG 78 Series: Article 2 of 8 – The ‘Grouping Test’
25 May 2023

“ASIC’s ‘grouping test’ brings clarity and efficiency to reporting, fostering accountability and addressing systemic issues for a stronger financial landscape” – Kristijan Vicoroski.

The first of ASIC’S updates to RG 78 is the introduction of a new ‘grouping test’ which clarifies the circumstances in which licensees can group multiple reportable situations into one report.

ASIC provides that, where the conduct of multiple reportable situations:

  • are similar, related or identical, or have very similar reportable situations; and
  • the conduct has the same underlying root cause;

those events may be grouped into a single report.

ASIC also cautions that licensees should take care that the underlying root cause of the breach or likely breach is not caused by a broader failure relating to training, policy, process and/or other systemic issues where multiple reportable situations were caused by human error from staff members.

For more information on the updates to RG 78 or to have a chat to understand your compliance obligations as an AFSL holder, email our friendly team today at

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