CCM software in Australia: disclosure rules and the platforms that fit

Looking at CCM software in Australia? Start with the rules, because they decide your document estate. A product disclosure statement (PDS), a Financial Services Guide (FSG), a periodic statement and a failed performance test notice each come with their own trigger, format and deadline.

This guide maps the ASIC and APRA rules that shape bank, insurer, super fund and lender communications, shows what a customer communications management (CCM) platform has to do for each, and covers which platforms have documented Australian work. It isn’t legal advice, so confirm every obligation with your compliance team. For the full vendor list, see our CCM software guide.

Pick by your situation

Short on time? Start here.

• Insurer or health fund rebuilding correspondence? Look at Quadient Inspire.
• Super fund or fund manager stuck on PDS updates? Look at Objective for authoring, paired with a composition platform for statements.
• Very large statement runs or thousands of overlapping templates? See the leaders without public Australian proof and ask for local references.
• Running SmartCOMM today? Jump to renewal and exit terms.

Five sets of rules drive most Australian disclosure work

Most of the load comes from the Corporations Act and ASIC’s regulatory guides, with APRA rules for super and industry codes on top. Here’s what each asks of your documents.

PDSs: right version, right time, kept seven years

RG 168, reissued on 3 December 2025, says a PDS generally goes to the client at or before the time you recommend or offer the product. In time-critical cases it can follow, but within five business days of the sale.

Everything in it must be “clear, concise and effective.” When something changes, you issue a Supplementary PDS or a new one, and you tell ASIC on forms FS88 (in use), FS89 (fee change) or FS90 (product closed). You keep a copy of each PDS for seven years.

Super and simple managed investment schemes use the shorter PDS regime: eight A4 pages at most, nine-point minimum font, and prescribed warnings. That’s a hard layout constraint your templates must enforce, not a style preference.

FSGs and Statements of Advice

Under RG 175, you give an FSG for both general and personal advice, or publish the same information on your website as website disclosure information. A Statement of Advice goes out with or soon after personal advice, and within five days in time-critical cases. Keep each SOA, and what it refers to, for seven years.

Digital delivery: publish, notify and honour the opt-out

RG 221 was also reissued on 3 December 2025, alongside ASIC’s Electronic Disclosure Instrument 2025/447. You can now publish a PDS, FSG, SOA, ongoing disclosure or periodic statement and notify the client, without first getting their agreement.

The conditions matter for your platform. Clients must be able to opt out of digital delivery by a reasonable means, and ASIC’s guidance says the notice should make clear they can do so at any time and at no cost. Disclosures should stay accessible for a reasonable period, such as at least two years, and you should keep every version with the dates it was available. RG 221 also points to WCAG for accessibility; our accessible communications guide explains the standard.

Design and distribution obligations

Since 5 October 2021, issuers must publish a target market determination (TMD) free of charge before distributing a product. A review trigger means reviewing the TMD within 10 business days, and significant dealings outside the target market go to ASIC within 10 business days.

DDO doesn’t write your letters for you. But it does mean every PDS, marketing piece and welcome pack should trace back to the product version and TMD in force when it went out.

Statements, super notices, complaints and codes

Periodic statements cover super, managed investments, investment life insurance, deposit products and margin lending. Each reporting period is a year or less, and the statement is due within six months of the period ending, with balances, transactions, termination value and return.

Super funds whose product fails APRA’s annual performance test must notify affected members in the prescribed form within 28 days of APRA’s determination. There’s no exemption, although a trustee can apply to defer in exceptional cases such as a merger.

Under RG 271, complaint responses are written, give reasons for any rejection and tell the customer about AFCA. They’re due within 30 calendar days, or 45 for super trustee complaints.

Codes add more. The 2025 Banking Code of Practice requires at least 30 days’ notice of unfavourable changes to terms, with exceptions such as interest rate and repayment changes. By October 2026 the Insurance Council had submitted a redrafted General Insurance Code to ASIC for approval. It would make key obligations enforceable in contracts after a transition period. Until then, the current Code stays in place.

Every Australian disclosure has a trigger and a clock

This view lists documents by when they fire and how long you have, which is how your production calendar actually runs.

1. 1

   Before and at sale

   Product launch and advice

   • Target market determination

     When Before the product is distributed

     Clock Public and free of charge

     RG 274, s994B(9)

   • Financial Services Guide

     When General or personal advice

     Clock Given, or published as website disclosure

     RG 175

   • Product disclosure statement

     When Recommendation or offer

     Clock At or before; time-critical within 5 business days

     RG 168.16, 168.19

   • Statement of Advice

     When Personal advice

     Clock With or soon after; within 5 days if time-critical

     RG 175.86 to 175.88

2. 2

   Product changes

   New terms, fees or versions

   • Supplementary or new PDS

     When Information changes or a statement is misleading

     Clock PDS must be up to date when given

     RG 168.67, 168.94

   • ASIC notice FS88, FS89 or FS90

     When PDS first used, fees change, product closes

     Clock As soon as practicable

     RG 168.133

   • Unfavourable change notice (banks)

     When Terms change against the customer

     Clock At least 30 days before

     Banking Code para 36

3. 3

   Holding the product

   Every year, often for decades

   • Periodic statement

     When End of each reporting period (1 year or less)

     Clock Within 6 months

     s1017D

   • Failed performance test notice (super)

     When APRA determination

     Clock Within 28 days, prescribed form

     APRA YFYS

   • Digital disclosure notice

     When Each disclosure published

     Clock Opt-out honoured at any time

     RG 221, Instrument 2025/447

4. 4

   Complaints and records

   Proof after the fact

   • IDR response letter

     When Complaint received

     Clock 30 calendar days; 45 for super trustees

     RG 271.56, Table 2

   • Significant dealing notice

     When Dealing outside the target market

     Clock 10 business days

     RG 274

   • PDS copy and digital versions

     When Every version issued

     Clock PDS kept 7 years; digital copies reachable 2 years or more

     RG 168.137, RG 221 Table 1

Sources: ASIC RG 168 and RG 221 (December 2025), RG 274, RG 175, RG 271; Corporations Act s1017D; APRA YFYS FAQ; ABA Banking Code of Practice. Checked November 3, 2026.

See which capabilities matter most to you

Tick the documents you produce. The list underneath ranks the capabilities by how many of them depend on each one, so you know what to prove first in a demo.

Scroll the table sideways to see every capability.

Document and rule	Approved wording, versioned	Page, font and layout limits	Account or member data feed	Cycle batch at peak volume	On-demand generation	Publish and notify, with opt-out	Accessible digital output	Link to product version and TMD	Archive of every version sent
Full PDS and Supplementary PDS RG 168	●				●	●	●	●	●
Shorter PDS (super, simple MIS) RG 168 Table 5	●	●				●	●	●	●
Financial Services Guide RG 175	●				●	●	●		●
Statement of Advice RG 175	●		●		●				●
Periodic statement s1017D			●	●		●	●		●
Failed performance test notice APRA YFYS	●	●	●	●					●
Change of terms notice Banking Code para 36	●		●	●		●		●	●
IDR response letter RG 271	●		●		●				●
Welcome pack and marketing pieces RG 274			●		●	●		●

Rules: ASIC RG 168, 175, 221, 271 and 274; Corporations Act s1017D; APRA; ABA Banking Code. Checked November 3, 2026. Capability mapping is our model of typical Australian financial services production.

Two columns stand out for Australia: publish and notify with a working opt-out, and traceability to the product version and TMD. Test both with real member data.

SmartCOMM alternatives for Australian firms

These two picks have Australian work reported in trade press. The table after them lists strong platforms to shortlist only with local references. Ratings are global, not Australian; every number is in our CCM benchmark.

1

Quadient Inspire

Best for insurers and health funds rebuilding correspondence across print, email and mobile

• 4.8 ★130 Gartner reviews
• 2016HBF selected Inspire, per B&T

B&T reported, quoting only GMC Software, that HBF, which it described as Australia’s fourth-largest private health insurer, picked Inspire after a tender against three other vendors. The goals were fewer disparate systems, more digital contact, brand control and less reliance on IT. The vendor was GMC Software, which became part of Quadient in 2017.

Watch out: the public Australian example is from 2016, so ask for current Australian references.

SmartCOMM vs Quadient Inspire →

2

Objective (PDS authoring)

Best for super funds, fund managers and insurers whose bottleneck is PDS updates

• 2013PDS system at a major insurer, per Insurance News

Insurance News reported in 2013 that one major Australian insurer was using Objective’s online system for producing and updating PDSs. Investor Daily later reported a PDS service for super and funds management that combined Objective’s Keystone platform with Mayflower’s due diligence, version control and typesetting.

Watch out: the reported work covers PDS production, so plan a composition platform for statements and letters.

Compare CCM platforms →

Strong CCM leaders without public Australian proof

These platforms have strong global records in financial services but little public Australian detail. If their strengths fit, make Australian references a shortlist condition.

Platform	Gartner rating	Why it might fit	Ask the vendor
OpenText Exstream	4.4 from 76 reviews	Reviewers praise high-volume batch, which suits periodic statement runs	An Australian bank, insurer or fund you can call, and where your data is hosted
Messagepoint	4.4 from 69 reviews	Manages communications as reusable content, useful when PDS and TMD changes ripple through letters	Two Australian references and how it handles publish and notify
ISIS Papyrus	4.5 from 92 reviews	Combines communications with case management for complaints and claims letters	An Australian reference on your volumes
Precisely EngageOne	4.1 from 12 reviews	Cloud composition; Precisely says its archive can run in your own AWS account	Which Australian firms run it today

Gartner Peer Insights ratings, October 2026. Serving clients in other markets too? See CCM software for banks, insurers and wealth managers.

Running SmartCOMM today? Start with renewal and exit terms

Smart Communications has Australian customers. In a 2023 press release, it named Commonwealth Superannuation Corporation, AMP and Bendigo Bank among award winners at its Sydney conference. It also bought Canberra forms company Intelledox in 2019; the full story is in what happened to Intelledox.

If you’re on SmartCOMM or SmartIQ, your contract dates decide how much room you have.

1. Find the notice date in your order form and work back about a year. Our SmartCOMM contract renewal plan has the timeline.
2. Get archive export terms in writing. You keep each PDS for seven years and digital disclosures for a reasonable period, so the archive outlives any contract. Ask for a full export with product, version and send date.
3. Get template export terms, with version history, so you can show which approved wording produced which document.
4. Ask for a short extension sized to a migration, with per-unit prices and an increase cap, instead of a long renewal.
5. Price a competitor on the same volumes. Start with SmartCOMM alternatives, then plan the move with our guide to migrating off SmartCOMM.

What to put in your RFP

These lines follow from the rules above. Copy them from our CCM RFP template.

1. Shorter PDS layout rules enforced in the template: page count, nine-point minimum and prescribed warnings.
2. Publish and notify for PDSs, FSGs and periodic statements, with each client’s opt-out stored and honoured on the next send.
3. Versioned approved wording, with every document traceable to the product version and TMD in force on the send date.
4. Periodic statement batches at peak volume, plus on-demand SOAs, complaint responses and notices from the same templates.
5. Prescribed-form notices such as failed performance test letters, produced and sent inside 28 days.
6. Accessible digital output that a client can save, print or forward.
7. An archive of every version sent, searchable by client, product and date, for at least seven years.
8. Australian hosting options and references, stated in writing. Our CCM security and compliance guide lists the questions to ask.

How to test the shortlist

Use your own products and member data, because that’s where platforms fail.

1. Build a shorter PDS for a super product and try to push it past eight A4 pages. The platform should stop you.
2. Publish a periodic statement digitally for a client who opted out last week, and check it goes by post instead.
3. Change a fee and show the Supplementary PDS, the change notice and the approval trail, each tied to the right version.
4. Generate a failed performance test notice for a sample member file and time it.
5. Score each vendor with our CCM vendor scorecard.

Running communications in the UK too? See CCM and the FCA Consumer Duty.