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DDO / TMD checklist

The Design and Distribution Obligations (Corporations Act Part 7.8A, in force since 5 October 2021, regulated by ASIC under RG 274) require issuers and distributors of retail financial products to design, distribute and monitor those products against a Target Market Determination. This tool checks whether DDO applies to you, then scores your issuer and distributor obligations and lists the artefacts ASIC expects.

Last verified: 1 July 2026
Scope
Obligation checklist

Issuer obligations (Div 2)

Target Market Determination made for each product

s994B — a TMD is made and in force before the product is offered to retail clients.

TMD describes the target market

s994B(5)(b) — the class of retail clients for whom the product is appropriate.

TMD sets distribution conditions

s994B(5)(c) — conditions and restrictions on retail product distribution conduct.

TMD review triggers and review periods

s994B(5)(d)-(g) — review triggers, maximum review periods and reporting periods.

Reasonable steps so distribution is consistent with the TMD

s994E — controls reasonably likely to result in distribution consistent with the TMD.

Record-keeping of TMD decisions and reviews

s994F — complete, accurate records of TMD decisions and reviews.

Report significant dealings to ASIC

s994G — notify ASIC in writing within 10 business days of significant dealings inconsistent with the TMD.

Review the TMD when a trigger occurs

s994C — review as soon as practicable after a trigger; cease retail distribution if the TMD is no longer appropriate.

Reference tool — not legal or financial-services advice. DDO scope depends on the specific product, exclusions and your role for each product. Always confirm with ASIC's RG 274 or an AFS-licensing specialist for material decisions.

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Frequently asked questions

Who do the Design and Distribution Obligations apply to?
Issuers and distributors of financial products that are made available to retail clients, where the product requires a Product Disclosure Statement or is otherwise caught by the regime (including securities offered under a prospectus under Chapter 6D, and credit products under the equivalent NCCP regime). Some products are excluded — for example MySuper products and, in many cases, fully-paid ordinary shares. Margin lending is included.
What is a Target Market Determination (TMD)?
A TMD is a document an issuer must make for each product before it is offered to retail clients (s994B). It describes the class of retail clients for whom the product is appropriate (the target market), the conditions on distribution, and the review triggers and review periods that require the issuer to reconsider the TMD.
What must a distributor do under DDO?
A distributor must not distribute the product to retail clients without a current TMD, take reasonable steps so distribution is consistent with the TMD, collect and keep the distribution information the TMD specifies, and report significant dealings and complaints to the issuer (and ASIC where required) within the required timeframes.
When did Part 7.8A commence?
The Design and Distribution Obligations in Part 7.8A of the Corporations Act 2001 commenced on 5 October 2021. ASIC regulates the regime and its expectations are set out in Regulatory Guide RG 274. Breaches can attract civil penalties and stop orders.

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