The Reserve Bank's 2025/26 assessment rated most standards at ASX's clearing and settlement facilities as observed or broadly observed, but four areas remain only partly observed for one or more of them.

Ratings tables rarely make headlines, but the one at the heart of the Reserve Bank of Australia's (RBA) latest assessment of ASX deserves a closer look. Released on 23 September 2026, the assessment covers ASX's four clearing and settlement facilities for 2025/26 and grades them against the RBA's standards.

The grading uses four levels: "observed", "broadly observed", "partly observed" and "not observed". Where a facility lands on that scale tells the market how far it is from fully meeting a given standard.

The overall scorecard

The headline result is a split picture. Most standards were rated "observed" or "broadly observed". That is the part of the assessment that reflects areas where ASX's facilities are meeting, or largely meeting, what the RBA expects.

The weaker part is concentrated in four standards. Under each of these, one or more of the facilities was rated only "partly observed":

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

"Partly observed" sits below "broadly observed" and above "not observed". It indicates that a standard is being met in part, but that there are shortcomings the RBA considers significant enough to keep it from a higher rating.

Standard by standard

Governance. This standard concerns how the facilities are directed and overseen. It is also the area the RBA has emphasised most consistently. The Payments System Board said in its August 2026 update that ASX must ensure "robust and independent governance", and that ASX's governance, culture and risk challenges "require sustained focus". A "partly observed" rating here is consistent with that message.

Framework for Comprehensive Management of Risks. As the name suggests, this standard looks at whether risks are managed as a whole, rather than one at a time. The RBA's broader description of ASX's challenges, "longstanding shortfalls in governance, capability, culture and risk management", indicates why an organisation-wide risk framework remains a focus.

Credit Risk. This standard relates to the management of credit risk within the clearing and settlement facilities. The assessment places it among the four standards where at least one facility was rated "partly observed". For readers, the key point is the rating itself: for at least one facility, credit risk management remains short of "broadly observed", and it sits on the same list as governance and risk management more generally.

Operational Risk. This is where the most movement occurred. ASX Clear and ASX Settlement were upgraded on this standard, from "not observed" to "partly observed". The RBA linked the upgrade to strengthened CHESS resourcing and contingency arrangements, put in place after the December 2024 batch settlement incident.

Why an upgrade is not a turning point

On the face of it, two facilities moving off the bottom rung on operational risk looks like progress, and in a narrow sense it is. The specific weaknesses exposed by the December 2024 incident have been addressed to a degree the RBA was prepared to recognise.

But the RBA explicitly cautioned against reading too much into it. It said the upgrades do not indicate broader progress. "Partly observed" is still not "broadly observed", and the upgrade reflects targeted fixes rather than a wider transformation.

Brad Jones, Assistant Governor (Financial System), put the overall position bluntly: "ASX is still not meeting the RBA's expectations in several important areas."

He framed the task ahead as delivering change "without compromising the safe and reliable operation of its critical infrastructure." That is the balancing act for ASX: fixing the underlying problems while keeping clearing and settlement running safely in the meantime.

The RBA's assessment points to ASX's Transformation Portfolio as the programme that addresses "longstanding shortfalls in governance, capability, culture and risk management".

Mapped against the ratings table, that list overlaps closely with the four "partly observed" standards. Governance appears in both. Risk management runs through the framework, credit and operational standards. Capability and culture are not standards in their own right, but they underpin an organisation's ability to meet all of them.

This is why the RBA's view of ASX is likely to depend on the Transformation Portfolio as a whole rather than on individual upgrades. A single standard can improve because of a targeted fix, as operational risk did for two facilities this year. Moving several standards up the scale at once requires the broader change the RBA describes.

The wider frame, and what would count as progress

The ASX assessment arrived about a week before the RBA's October 2026 Financial Stability Review, released on 1 October. That review found the financial system resilient overall, but said "global and operational vulnerabilities continue to mount".

Its list of elevated threats included disruptions to critical service providers, alongside geopolitical tensions, global financial market vulnerabilities and advances in AI. It urged institutions to keep building resilience and to strengthen crisis preparedness. The review also referred to APRA's operational risk standard CPS 230, introduced in July 2025.

The connection to ASX is one of theme rather than direct finding. Clearing and settlement facilities are critical infrastructure, and operational risk is the standard on which two ASX facilities had been rated "not observed" until this assessment. The FSR's emphasis on operational resilience shows why the RBA treats that rating so seriously.

Based on the RBA's own language, a few markers stand out. The first is movement in the four "partly observed" standards towards "broadly observed" or "observed" in future assessments. The second is evidence that the Transformation Portfolio is addressing governance, capability, culture and risk management together, not piece by piece. The third is a change in the Payments System Board's tone on whether ASX's challenges still "require sustained focus".

Until then, the 2025/26 scorecard stands as a record of partial improvement: better than the year before on operational risk for two facilities, but still short in four important areas.

The bottom line

ASX's clearing and settlement facilities meet or broadly meet most of the RBA's standards, but one or more facilities remain "partly observed" on Governance, the Framework for Comprehensive Management of Risks, Credit Risk and Operational Risk. The upgrade of ASX Clear and ASX Settlement on operational risk followed specific work on CHESS after the December 2024 incident, and the RBA has said it does not signal broader progress. The Transformation Portfolio is the programme the RBA expects to close the remaining gaps, and the next assessment will show whether it has.