Key Highlights

  • The RBA’s 23 September 2026 assessment found ASX’s four clearing and settlement facilities met many Financial Stability Standards.
  • At least one facility was only “partly observed” on Governance, the Framework for Comprehensive Management of Risks, Credit Risk and Operational Risk.
  • The RBA described the Transformation Portfolio as a pathway to the standard expected of critical market infrastructure, if delivered effectively.

In its latest assessment of ASX's clearing and settlement facilities, the Reserve Bank said the exchange operator's Transformation Portfolio offers a route to the standard expected of critical market infrastructure, but only if it is delivered effectively.

The choice of word matters. When the Reserve Bank of Australia (RBA) released its assessment of ASX's clearing and settlement facilities on 23 September 2026, it described the Transformation Portfolio as something that, if delivered effectively, "provides ASX with a pathway to meet the standard expected of an operator of critical market infrastructure."

A pathway is a route, not an arrival point. The RBA's framing makes the Transformation Portfolio central to ASX's prospects of meeting regulatory expectations, while making equally clear that those expectations are not yet being met.

What the RBA assessed

The assessment covered four ASX facilities against the RBA's Financial Stability Standards:

  • ASX Clear;
  • ASX Clear (Futures);
  • ASX Settlement; and
  • Austraclear.

The results were mixed. Many standards were rated "observed" or "broadly observed". But one or more of the facilities was rated only "partly observed" against four standards: Governance, Framework for Comprehensive Management of Risks, Credit Risk, and Operational Risk.

Those four areas go to the core of how a clearing and settlement operator is run. Governance concerns how the organisation is directed and overseen. The comprehensive risk management framework concerns how risks across the business are identified and managed together. Credit risk and operational risk are two of the main categories of risk such facilities face. A "partly observed" rating in these areas signals that the RBA sees meaningful gaps.

The assessment, in other words, was neither a clean bill of health nor a uniform failing grade. It found facilities that meet many of the standards expected of them, alongside a cluster of important areas where at least one falls short. It is against that cluster that the RBA's pathway language is best read.

The weight placed on transformation

The RBA's statement ties ASX's route to meeting the standard to the Transformation Portfolio. The conditional phrasing, "if delivered effectively", is doing important work. The pathway exists, in the RBA's assessment, but its value depends on execution.

Brad Jones, Assistant Governor (Financial System), set out the RBA's view plainly: "ASX is still not meeting the RBA's expectations in several important areas."

He also identified the central difficulty. The challenge, he said, is delivering the transformation "without compromising the safe and reliable operation of its critical infrastructure." In other words, ASX must change significant parts of its systems and organisation while continuing to run the facilities that the market relies on every day.

That is the tension at the heart of the RBA's framing. The Transformation Portfolio is the route forward, but undertaking it introduces its own demands. The critical infrastructure cannot be paused while it is rebuilt.

It is also worth noting what the assessment, as summarised here, does not do. It does not put a date on when the Transformation Portfolio should be complete, and it does not say which ratings might change if delivery goes well. The pathway language describes a direction and a condition rather than a timetable. Future assessments will be the place to see whether ratings in the four "partly observed" areas move, and in which direction.

One upgrade, carefully qualified

The assessment did include an improvement. ASX Clear and ASX Settlement were upgraded from "not observed" to "partly observed" on Operational Risk. The RBA linked this to strengthened CHESS resourcing and contingency arrangements following the December 2024 batch settlement incident.

But the RBA was explicit that the upgrades should not be over-read. It said they "do not indicate an assessment of broader improvement in ASX's management of operational risk."

The two statements sit together logically. A specific rating improved because of specific steps taken after a specific incident. That is distinct from a judgement that ASX's operational risk management has improved across the board. The RBA's description of the Transformation Portfolio as a pathway, rather than a completed journey, is consistent with that caution.

The September assessment was also not the only recent RBA statement on ASX, and the earlier one carried a similar balance. When the Payments System Board met on 27 August 2026, it said "significant challenges related to ASX governance, culture and risk management require sustained focus."

The Board's update also noted progress on CHESS resilience and the safe delivery of CHESS Replacement Release 1. That pairing of challenges and progress mirrors the September assessment: real steps forward in specific areas, alongside broader concerns about governance, culture and risk management that require sustained attention.

The phrase "sustained focus" is consistent with the idea of a pathway. Problems related to governance, culture and risk management are not described as something to be fixed in a single step. They require attention over time.

Why this matters beyond ASX

ASX's clearing and settlement facilities sit within the broader financial system the RBA oversees. In its October 2026 Financial Stability Review, released on 1 October, the RBA said the system has "a good degree of resilience" but that global and operational vulnerabilities are growing. Among the threats it identified was disruption at critical service providers, and it urged institutions to keep building resilience and strengthen crisis preparedness.

The minutes of the Monetary Policy Board's 28–29 September meeting similarly noted that operational risks, including outages at common service providers, were growing.

That wider concern about operational resilience gives context to the RBA's attention to ASX. Clearing and settlement are functions on which other market participants depend, which is why the RBA frames ASX as an operator of critical market infrastructure and holds it to the corresponding standard.

The bottom line

The RBA's 23 September 2026 assessment found that ASX's four clearing and settlement facilities met many Financial Stability Standards, but that one or more were only "partly observed" on Governance, the Framework for Comprehensive Management of Risks, Credit Risk and Operational Risk. The RBA described the Transformation Portfolio as providing a pathway to the standard expected of critical market infrastructure, if delivered effectively. With Brad Jones stating that ASX "is still not meeting the RBA's expectations in several important areas", the pathway has been identified, but the destination has not yet been reached.

Assessment findings and the transformation program do not amount to certification that all operational or financial-stability risks have been eliminated.