The Reserve Bank's latest assessment of ASX's clearing and settlement facilities recorded some upgrades, but its Assistant Governor (Financial System) made clear that they should not be mistaken for a clean bill of health.

Regulators do not often speak this plainly about the operator of a country's main securities exchange. When the Reserve Bank of Australia (RBA) released its 2025/26 assessment of ASX's four clearing and settlement facilities on 23 September 2026, Brad Jones, Assistant Governor (Financial System), summed up the findings in a single sentence:

"ASX is still not meeting the RBA's expectations in several important areas."

The word "still" carries much of the weight. It signals that the concerns are not new, and that the RBA's patience is being tested by the pace of change rather than by a single fresh failure.

What the assessment found

The RBA's assessment covers ASX's four clearing and settlement facilities, the infrastructure that sits behind trades on the market. The RBA rates each facility against a set of standards using a scale that runs from "observed" through "broadly observed" and "partly observed" to "not observed".

The overall picture was mixed. Most standards were rated "observed" or "broadly observed". But one or more facilities were rated only "partly observed" under four standards:

  • Governance
  • Framework for Comprehensive Management of Risks
  • Credit Risk
  • Operational Risk

Those four are not peripheral. Governance and the framework for managing risks go to how the organisation is run and overseen. Credit risk and operational risk go to whether the facilities can withstand losses and keep functioning.

The upgrades, and why the RBA downplayed them

There was some movement in ASX's favour. ASX Clear and ASX Settlement were upgraded on the Operational Risk standard, from "not observed" to "partly observed".

The RBA linked the upgrade to strengthened resourcing and contingency arrangements for CHESS, following the batch settlement incident in December 2024. In other words, ASX had done work that addressed specific weaknesses exposed by that event, and the ratings reflected it.

But the RBA was careful to limit what the upgrades meant. It said the upgrades do not indicate broader progress. A move from "not observed" to "partly observed" lifts the rating off the bottom of the scale, but "partly observed" still signals that a standard is not being fully met.

That framing explains why Jones' summary was so direct. Taken alone, an upgrade can read as good news. The RBA's message was that the specific improvements on operational risk should not be read as evidence that the deeper problems have been resolved.

The deeper problem: governance, capability, culture and risk

The RBA's assessment points to ASX's Transformation Portfolio as the vehicle for fixing what it calls "longstanding shortfalls in governance, capability, culture and risk management".

That phrase sets out the scale of the task. These are not narrow technical issues that can be solved with a single system upgrade. They concern how the organisation makes decisions, the skills it has available, how its people work and how it manages risk across its operations.

Jones identified the central tension. The challenge for ASX, he said, is to deliver its programme "without compromising the safe and reliable operation of its critical infrastructure."

Put simply, ASX has to rebuild while the system keeps running. Clearing and settlement cannot be paused while improvements are made, so every change has to be delivered without disrupting the services the market relies on every day.

The assessment did not come out of the blue. The Payments System Board's update from its August 2026 meeting, released on 27 August, addressed ASX in similar terms.

The Board said ASX must ensure "robust and independent governance". It also said the governance, culture and risk challenges at ASX "require sustained focus".

Read together, the August update and the September assessment present a consistent position. The RBA recognises that work is under way, but it wants that work to be sustained, independently governed and broad enough to address the underlying shortfalls rather than only the most visible incidents.

Why it matters beyond ASX, and what to watch

The RBA's interest in ASX sits within a wider concern about the resilience of critical infrastructure. The October 2026 Financial Stability Review, released on 1 October, found that the Australian financial system is resilient, but warned that "global and operational vulnerabilities continue to mount".

Among the elevated threats the review identified were geopolitical tensions, vulnerabilities in global financial markets, advances in artificial intelligence and disruptions to critical service providers. It urged institutions to keep building resilience and to strengthen their crisis preparedness.

The review also noted that outages at common third-party providers could disrupt much of the superannuation sector, and referred to APRA's operational risk standard CPS 230, introduced in July 2025, and an APRA letter on AI-driven cyber threats dated 30 April 2026.

Those findings are not specific to ASX. But they explain why the RBA places such weight on the reliability of clearing and settlement facilities. When infrastructure that many participants depend on falters, the effects can spread well beyond a single organisation.

The assessment leaves ASX with a clear agenda. Several things will indicate whether the RBA's view is shifting:

Progress on the Transformation Portfolio will be central, given the RBA has tied the resolution of longstanding shortfalls to it. Future assessments will show whether any of the four "partly observed" standards move up the scale. And the Payments System Board's future updates will indicate whether the RBA still regards ASX's governance, culture and risk challenges as requiring "sustained focus".

For investors and market participants, the significance is in the tone as much as the ratings. A regulator that pairs upgrades with an explicit statement that they do not indicate broader progress is signalling that it intends to keep the pressure on.

The bottom line

Brad Jones' verdict that "ASX is still not meeting the RBA's expectations in several important areas" was the defining line of the RBA's 2025/26 assessment. Two facilities were upgraded on operational risk after CHESS resourcing and contingency arrangements were strengthened following the December 2024 incident, but the RBA said those gains do not signal broader progress. With four standards still rated "partly observed" for one or more facilities, and longstanding shortfalls in governance, capability, culture and risk management to address, the RBA's message is that ASX has more to do, and must do it without compromising the safe and reliable operation of its critical infrastructure.