ASIC lifts minimum NTA requirements for fund operators from 1 July 2027
The Australian Securities and Investments Commission (ASIC) has confirmed its previously announced changes to the minimum net tangible assets (NTA) requirements will take effect from 1 July 2027 for:
responsible entities of registered managed investment schemes (MISs);
operators of investor directed portfolio services (IDPS); and
corporate directors of retail corporate collective investment vehicles (CCIVs)
(collectively, fund operators).
With less than nine months until the new requirements take effect, fund operators should act now to ensure they can meet the higher minimum NTA requirements by 1 July 2027.
Need to know
One-off increase: from 1 July 2027, the baseline minimum NTA requirements will increase in a one-off adjustment to reflect inflation since the current financial requirements were formulated in 2013.
Annual indexation: the minimum NTA requirements will be indexed to inflation each year, with the first indexation to occur on 1 July 2027.
What it means in practice: fund operators may need to change their capital structure or asset holding arrangements before 1 July 2027 to ensure they can continue to meet the minimum NTA requirement.
Why ASIC is changing the NTA requirements
ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647 (Legislative Instrument) modifies the Corporations Act 2001 (Cth) by introducing specific financial requirements, including minimum NTA requirements, which must be met by a financial services licensee who is authorised under their Australian financial services licence to be a fund operator.
The purpose of these financial requirements is to ensure:
the licensee has sufficient financial resources to conduct their financial services businesses in compliance with the Corporations Act (including carrying out supervisory arrangements);
there is a financial buffer that decreases the risk of a disorderly or noncompliant wind-up if the licensee’s business fails; and
there are incentives for the licensee owners to comply through risk of financial loss.
Earlier this year, ASIC ran a consultation process seeking feedback on increasing the NTA requirements. In July 2026, ASIC announced that it intended to increase the minimum NTA thresholds to account for inflation since 2013 (when the current thresholds were set), and to index them annually.
ASIC has now amended the Legislative Instrument (to take effect from 1 July 2027), with corresponding updates to Regulatory Guide 166 AFS licensing: Financial requirements to be made.
This change comes at a time of closer regulatory scrutiny of the managed investment scheme sector after the highly publicised Shield and First Guardian MIS collapses and the ensuing fallout. Treasury's recent consultation on a proposal to expand data collection across registered and unregistered managed investment schemes is another facet of the enhanced scrutiny the sector is currently facing.
The new minimum NTA thresholds
* Annual indexation will apply from 1 July 2027. In its announcement on 30 July 2026 , ASIC stated that ‘the thresholds applying from this date will include the first annual indexation adjustment’.
The annual indexation will be formulated by comparing each March quarter CPI figure against the previous March quarter CPI figure.
In its announcement on 21 October 2026, ASIC stated that the updated thresholds would be published on its website each year ‘after the relevant inflation data becomes available’.
To calculate the minimum NTA threshold that applies from 1 July 2027, the 2025 March quarter CPI and 2026 March quarter figures will be used. As this information is publicly available, it is curious that ASIC has not sought to publish these thresholds now. The annual increase in CPI as at March 2026 was 4.6 per cent.
The following requirements relating to NTA will not change:
at least 50 per cent of the required minimum NTA amount must be held in cash or cash equivalents; and
100 per cent of the required minimum NTA amount must be held in liquid assets.
What fund operators should do before 1 July 2027
If you are a fund operator, we recommend taking the following steps to prepare for the upcoming changes:
Assess your current NTA position against the increased and indexed thresholds and work out whether you will have a shortfall by 1 July 2027.
Determine how you will address any shortfall (e.g. by raising more equity or alternatively modifying your asset holding arrangements).
Update your compliance monitoring arrangements so that the updated indexed minimum NTA requirement is ascertained each year and arrangements are made to ensure any required top-up of your NTA occurs in a timely fashion (before 1 July of the relevant year).
Make sure directors and (if applicable) the compliance committee understand the changes and have given all necessary approvals.
Authored by Pip Bell & Langton Clarke of Hall & Wilcox
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Pip has more than two decades’ experience in funds management and financial services regulation, advising providers of asset management, trustee and responsible entity, custodial, broking, non-cash payment, research, platform, managed discretionary account, model portfolio, registry, technology and other intermediary services.
Pip has established professional relationships with businesses ranging from start-ups through to ASX-listed and global players and has experience across a variety of asset classes, including direct and indirect real property, domestic and international equities, infrastructure, agriculture and digital assets.
Langton has extensive experience across all aspects of the funds management industry.
He has particular expertise in investment vehicles seeking to raise capital from the retail and wholesale sectors.
Langton advises both start up enterprises and long-established businesses about raising new capital or debt, establishing investment opportunities and restructuring existing businesses and investment projects.
Langton is a member of the Property Funds Association.