ASIC gives the CPD year a different notification clock

ASIC's separate clock

ASIC guidance dated 24 August 2026 says AFS licensees can use the Regulatory Portal to advise or modify the licensee's CPD year. ASIC says an AFS licensee must notify ASIC of changes within 10 business days of the change occurring. The only exception to this timeframe is advising or changing the CPD year, which must be advised within 30 business days from the day the licence is granted or the day the CPD year is to begin if it is a change. Read ASIC's guidance on changing licence details.

That breaks a plausible assumption for practices: the CPD year can be treated solely as an internal calendar setting. A practice may manage its CPD calendar internally, but that does not remove the separate step of notifying ASIC about the CPD year through the licence-details process.

The reasonable prediction that fails

The intuitive prediction is that once a practice chooses a CPD year and records it internally, the regulatory work is finished. That prediction fails because ASIC identifies the CPD year among the licence details that can be advised or modified through the Regulatory Portal, and gives it a separate notification timeframe.

The internal calendar and the information notified to ASIC are therefore related, but ASIC's guidance does not say that they must be reconciled. It also does not say that the information notified to ASIC is an externally validated record of the cycle being operated, or that a mismatch is itself a governance failure.

Reconciliation is a governance recommendation, not an additional requirement stated on ASIC's page. A practice may choose to compare its internal calendar with the CPD year it has notified to ASIC so that responsibility for the notification is clear.

Consider a hypothetical. A practice changes its internal CPD calendar during a restructure. If it treats that as internal administration only, it may overlook whether the CPD year has changed for ASIC notification purposes. That is a possible process scenario, not a finding about how practices usually operate.

The practical control

ASIC's page sets the notification obligation and the relevant timeframe. The following are recommended practice controls, not additional ASIC requirements:

• Record internally the CPD year the practice is using and identify who owns the ASIC notification.
• When the licence is granted, or when the CPD year is to begin if it is a change, identify the relevant starting point for the 30 business days timeframe.
• Use the Regulatory Portal to advise or modify the licensee's CPD year.
• Compare the information notified to ASIC with the practice's internal calendar and retain evidence of the check.
• For other changes, apply ASIC's stated timeframe of 10 business days of the change occurring, rather than assuming the CPD year is treated in the same way.

The boundary matters

The accurate reading of ASIC's guidance is narrow. The CPD year can be advised or modified through the Regulatory Portal, and ASIC has specified a separate timeframe for advising it. The guidance does not prescribe a firm's internal CPD calendar or make reconciliation between internal information and information notified to ASIC mandatory.

For licensees, the practical takeaway is clear: CPD year notification has its own ASIC timeframe. The internal calendar remains a practice‑management matter, while notifying ASIC through the stated process is a licence obligation.¹