APRA has accepted 37 enforceable undertakings since its register began in 2005, fewer than two a year on average, and none in seven of the 21 years. Twenty-seven of them came in the first nine years. The three accepted in 2025 are the most in a year since 2013, a difference of a few cases that is too small to call a trend. What has changed is who gives them: every undertaking since 2014 has come from an institution, where most before it came from individuals.
Node reading for Banking & Lending Regulation (21350): NIL RETURN. This article rests on the source data alone.
What an enforceable undertaking is
An enforceable undertaking is a written promise to a regulator, which the regulator can take to court to enforce. APRA, which supervises banks, insurers and most superannuation funds, can accept one from an institution or from an individual on a matter within its powers. In APRA’s own description, undertakings can be used in place of formal legal action, particularly where the institution or person has made admissions about their conduct.
APRA keeps a public register of every undertaking it has accepted since 1 January 2005, with the acceptance date and the law each was given under. Counting the register by year gives a complete annual series, including the years with none. It is one of several APRA tools. Infringement notices, which APRA has published since 1 August 2019, and disqualifications of individuals sit on separate registers and are not counted here.
| Measure | Regulator | What it counts | What it does not count | Window |
|---|---|---|---|---|
| Enforceable undertakings accepted | APRA | Written undertakings APRA has accepted from an institution or an individual, which can be used in place of formal legal action | Infringement notices, disqualifications and other supervisory or enforcement action | Every year since 2005, from the register |
| Investigations commenced | ASIC | Investigations opened in the six months, across all the sectors ASIC regulates | Whether an investigation leads to any outcome, or how serious the matter is | Five six-month periods, July 2023 to December 2025 |
| Investigations ongoing | ASIC | Investigations open at the end of the period | When each was opened | Same five periods |
| Court enforceable undertakings accepted | ASIC | Undertakings ASIC accepted in the period | The conduct or sector each concerns | Same five periods |
Sources: APRA Enforceable Undertakings Register and enforcement page; ASIC Summary of Enforcement Outcomes, five six-monthly editions.
Twenty-one years of undertakings
The register holds 37 undertakings over 21 years. There were none in seven of those years: 2008, 2010, 2014, 2015, 2016, 2019 and 2022. The busiest year was 2013, with seven. Twenty-seven were accepted between 2005 and 2013 and ten between 2014 and 2025.
APRA enforceable undertakings accepted, by year
Undertakings accepted in each calendar year, 2005 to 2025, split by whether the giver was a person or an institution. The bar for each year sums to the total marked. Source: APRA Enforceable Undertakings Register, re-tabulated by acceptance date.
These are small numbers, and small numbers move a lot for reasons that have little to do with any wider pattern. Three undertakings in 2025 against one in 2024 is a difference of two cases, not a tripling of anything meaningful. A single matter can fill a year. The 13 undertakings accepted from 2011 to 2013 all came from individuals and, according to APRA’s own media releases, all related to one superannuation group. Those 13 are why 2013 stands out on the chart, and why 2011 is among the higher years.
From people to institutions
Of the 37 undertakings, 22 came from individuals, such as former directors or executives, and 15 from institutions. All 22 from individuals were accepted by 2013. Every one of the ten accepted since 2014 was given by an institution: four under superannuation law, four under the Banking Act and two under general insurance law.
| Law the undertaking was given under | Undertakings, 2005–2025 | From individuals | From institutions |
|---|---|---|---|
| Superannuation Industry (Supervision) Act 1993 | 23 | 17 | 6 |
| General insurance law | 9 | 5 | 4 |
| Banking Act 1959 | 5 | 0 | 5 |
| Total | 37 | 22 | 15 |
The register records the general insurance undertakings as given under section 126. Source: APRA Enforceable Undertakings Register, re-tabulated by acceptance date.
The banking undertakings are few: five in 21 years, all from institutions, and four of them since 2018. Eight of the ten accepted since 2014 carry no expiry date on the register; the other two are recorded as completed.
ASIC over a shorter window
ASIC, which regulates conduct across financial services, credit and markets, publishes a summary of its enforcement outcomes every six months. Its enforcement outcomes page lists summaries for five periods, from July–December 2023 to July–December 2025. In those periods it commenced between 63 and 132 investigations each half-year, 510 in total.
ASIC investigations commenced, by six-month period
Investigations commenced in each six-month period, all sectors. Source: ASIC Summary of Enforcement Outcomes, July–December 2023 to July–December 2025.
Five observations are context, not a trend. Each half of 2025 had more commencements than either half of 2024, and the number of investigations open at the end of each period rose from 126 to 205. ASIC accepted 18 court enforceable undertakings over the five periods, between 1 and 7 a half-year. Over the same two and a half years APRA accepted four. The two counts are not comparable as measures of intensity: ASIC regulates a far larger and more varied population of firms and individuals, under different powers. For the full 2025–26 financial year ASIC reported more than 250 investigations launched; its six-monthly summary for January to June 2026 had not been published by late September 2026.
| Six months | Investigations commenced | Investigations ongoing at period end | Court enforceable undertakings accepted |
|---|---|---|---|
| July–December 2023 | 83 | 126 | 3 |
| January–June 2024 | 63 | 140 | 7 |
| July–December 2024 | 109 | 195 | 2 |
| January–June 2025 | 132 | 202 | 1 |
| July–December 2025 | 123 | 205 | 5 |
Source: ASIC Summary of Enforcement Outcomes, Figure 1 of each six-monthly edition.
What these counts do not show
Enforcement counts measure what regulators did, not how firms behaved. A year with no undertakings is not a year without problems, and a busier year may reflect one large matter, a change in approach, or a regulator choosing a different tool: an infringement notice, a licence condition, court proceedings or supervisory work that is never announced. Undertakings differ greatly in scope, so a count gives each the same weight. The ASIC figures cover every sector ASIC regulates, not only lenders or property, and an investigation commenced is not a finding that anything was wrong.
Findings are presented on the basis of data and evidence alone.
