ASIC Corporations (Disclosure in Dollars) Instrument 2016/767

The instrument is short and centres on four main legal concepts: the scope of specified disclosure documents, the role of the person responsible for the disclosure, the conditional nature of the exemptions, and the alternative disclosures required when the exemptions are used.

1. Specified disclosure documents. The instrument applies to three statutory products of disclosure: Product Disclosure Statements (PDSs), Statements of Advice (SOAs), and periodic statements. It identifies which statutory paragraphs are affected for each document type. For PDSs the recurring reference is paragraph 1013D(1)(m) of the Act (see s 5 and s 6(3)), while for SOAs the affected provisions are paragraphs 947B(2)(h), 947C(2)(i) and 947D(2)(d) (see s 6(1) and s 7(1)). For periodic statements the instrument specifically refers to subsection 1017D(5A) in s 7(2).

2. Who may rely on the exemptions. Two statutory roles appear. "Responsible person" is used for persons who prepare PDSs (s 4 defines that term by reference to the Act). "Providing entity" is the term used for entities issuing SOAs and periodic disclosures, again by reference to the Act (s 4). The instrument does not redefine these terms; it imports their meanings from the Corporations Act (s 4).

3. Conditions and the "to the extent" limitation. Each exemption is not absolute. The instrument often limits the exemption "to the extent that" the Act requires amounts to be stated in Australian currency (s 7(1)-(2)). Where the instrument removes the dollar-denomination obligation it typically does so in return for other information being included. For example, PDSs that rely on the cost exemption must specify significant cost factors and explain the impact of each (s 5(3)). SOAs and PDSs that omit dollar valuations for non-monetary benefits must include their nature and extent, circumstances in which such benefits may arise, and, where a retail client would reasonably require it, estimated dollar values or ranges expressed in dollars (s 6(2)(a)-(c) and s 6(4)(a)-(c)).

4. Interaction between monetary and non-monetary disclosures. The instrument draws a legal distinction between monetary amounts denominated directly in foreign currencies and non-monetary benefits or interests. For foreign currency amounts the instrument allows the issuer to leave the amount in the foreign currency rather than converting to Australian dollars in the PDS, SOA or periodic statement, but only to the extent the Act would have required conversion (s 7(1)-(2)). For non-monetary benefits the instrument requires qualitative information and only requires dollar estimates where a retail client would reasonably require them (s 6(2)(c), s 6(4)(c)).

These concepts produce a regime where the statutory dollar-denomination rule is disapplied in specified cases but replaced by prescriptive alternative disclosures. The instrument states the conditions for each exemption in concise normative terms; assessing whether those conditions are met will involve factual judgment by the responsible person or providing entity, especially where the standard is whether "a retail client would reasonably require" an estimated dollar value (s 6(2)(c), s 6(4)(c)).

The instrument identifies two classes of persons who may rely on the exemptions and therefore be directly affected.

• Responsible persons for Product Disclosure Statements. The term "responsible person" is the statutory phrase used in the Corporations Act and imported into this instrument by s 4. Responsible persons prepare PDSs and will be affected when they issue PDSs for general insurance products, life risk insurance products, derivatives, foreign exchange contracts, or warrants. For general and life risk insurance PDSs, the instrument relieves the responsible person from the dollar-denomination obligation in relation to certain cost disclosures other than amounts describing excesses or deductibles, which remain subject to the Act (s 5(1)). For derivative, foreign exchange and warrant PDSs the instrument provides the broader exemption in s 5(2). In all PDS cases the exemption applies only where the PDS specifies significant cost factors and explains their impact (s 5(3)). Responsible persons must therefore decide whether to rely on the exemption and, if so, prepare the alternative explanatory content the instrument requires.

• Providing entities that prepare Statements of Advice and periodic statements. The term "providing entity" is defined by reference to section 944A of the Act and is used in s 6 and s 7. Providing entities may omit dollar-conversion or explicit dollar valuations for non-monetary benefits in SOAs, provided the SOA contains the specified descriptive material and, when required for a retail client's decision, an estimated dollar figure or range (s 6(1)-(2)). The instrument also allows providing entities not to convert foreign currency amounts into Australian dollars in SOAs to the extent the Act would otherwise require conversion (s 7(1)).

Indirectly affected parties include retail clients and investors who receive PDSs, SOAs or periodic statements. The instrument changes the form of information those recipients will receive where the issuer elects the exemption. For example, instead of a direct dollar figure for a non-monetary benefit, a retail client may receive a description of the nature and circumstances of the benefit and, where necessary, an estimated dollar range (s 6(2)(a)-(c)). Similarly, a PDS for a derivative or warrant might list significant cost factors and their impacts rather than provide a single dollar cost (s 5(3)).

Other intermediaries and advisers who rely on or distribute PDSs and SOAs are also affected. They must interpret the alternative disclosures and, in some cases, exercise client-facing judgment about whether "a retail client would reasonably require" an estimated value. Because the instrument imports statutory definitions (s 4) and cross-references numerous Act provisions, counsel, compliance teams and product designers will need to consult the Corporations Act and Regulations to determine the boundaries of who is a "responsible person" or "providing entity" for a particular product or document.

Finally, ASIC as regulator is implicated given the instrument was made by ASIC and is intended to operate alongside the Act (s 3). The instrument changes what regulators will inspect in a PDS, SOA or periodic statement where the exemptions are claimed, by substituting the statutorily prescribed alternative content for the dollar-denomination requirement.

The instrument creates a set of conditional duties on responsible persons and providing entities to include specified alternative information when they elect not to comply with certain dollar-denomination requirements of the Corporations Act. It does not create new civil or criminal offences within its text. Instead it affects duties established in the Act by making the specified Act obligations inapplicable "to the extent" stated when the instrument's conditions are met.

Duties created or modified by the instrument include the following, stated in the instrument's normative terms.

• Duty to include explanatory cost factors for certain PDSs. A responsible person for a PDS for a general insurance product or life risk insurance product is exempt from paragraph 1013D(1)(m) in relation to the information required by paragraph 1013D(1)(d) except for excesses or deductibles, but only where the PDS specifies any significant factors that will affect the cost of acquiring the product and includes an explanation of the impact of each factor (s 5(1), s 5(3)). For derivatives, foreign exchange contracts and warrants, the responsible person is exempt from paragraph 1013D(1)(m) for the same paragraph 1013D(1)(d) material, again subject to the requirement that the PDS specify significant cost factors and explain their impacts (s 5(2), s 5(3)). The responsible person therefore has a duty to supply qualitative explanations where the exemption is relied on.

• Duty to describe non-monetary benefits in SOAs. A providing entity need not comply with the dollar-denomination requirements in paragraphs 947B(2)(h), 947C(2)(i) and 947D(2)(d) when those paragraphs require amounts to be stated in Australian currency in a Statement of Advice, provided the SOA includes the nature and extent of the non-monetary benefit or interest, the circumstances in which it may be provided or arise, and, where a retail client would reasonably require it, an estimated value in dollars or a dollar range (s 6(1)-(2)). Those are the operative prescriptive duties for SOAs.

• Duty to describe non-monetary benefits in PDSs. A responsible person for a PDS likewise does not have to comply with paragraph 1013D(1)(m) when that paragraph would require dollar-denominated disclosure of non-monetary benefits under paragraph 1013D(1)(b), provided the PDS contains the same sorts of descriptive and estimated-value information that the instrument prescribes (s 6(3)-(4)).

• Duty to leave foreign currency amounts in foreign currency in certain documents. The instrument permits a providing entity and responsible person not to convert foreign currency amounts into Australian dollars in SOAs, PDSs and periodic statements "to the extent" the Act would otherwise require conversion (s 7(1)-(2)). The practical duty here is to ensure that, where a foreign currency amount is presented without conversion, it is done within the boundaries set by the instrument and the Act.

Rights and choices created by the instrument.

• Right to choose exemption. The phrasing "does not have to comply" indicates a right for the responsible person or providing entity to elect the exemption. It is not an obligation to use the exemption. The choice carries with it the duty to comply with the alternative disclosure requirements when the exemption is relied on (s 5-7).

• Right to present foreign currency amounts without conversion. Where an issuer presents amounts denominated in a foreign currency and relies on the s 7 exemptions, it may do so rather than converting to Australian dollars, subject to the import of "to the extent" limitations in s 7(1)-(2).

• Right to use estimated ranges. For non-monetary benefits the instrument allows estimated values to be expressed as a single amount in dollars or as a range when that is what a retail client would reasonably require for the decision (s 6(2)(c), s 6(4)(c)). That gives issuers some latitude in how they quantify non-monetary benefits.

Decisions to rely on the exemptions therefore migrate the substantive duty of compliance from a strict numeric dollar-disclosure rule to a judgemental obligation to supply meaningful explanations, descriptions and, in some cases, estimated dollar ranges. The standard "a retail client would reasonably require" introduces an objective-reasonableness test; how that test is applied in practice will be material to assessing compliance with the instrument’s requirements.

The instrument itself does not list penalties. It operates by specifying that certain persons "do not have to comply" with particular paragraphs or subsections of the Corporations Act 2001 in certain circumstances (see s 5-7). Because the instrument is made under the Act (s 3), its practical enforcement context is the Corporations Act framework and ASIC's regulatory functions, but the instrument text does not describe enforcement mechanisms, sanctions or penalty scales.

From the instrument text the relevant enforcement implications that can be stated are:

• Effect on statutory obligations. Where the conditions for an exemption in this instrument are met, the specified Act provision is not applicable "in relation to" the identified information in the disclosure document. That means a person who satisfies the instrument’s conditions will not be judged against the particular dollar-denomination requirement being disapplied. The instrument therefore alters which statutory provisions an issuer can be found to have breached in relation to the specific disclosure content covered by the exemption.

• Residual Act obligations. The instrument does not state that other statutory duties or prohibitions are affected. Persons relying on the exemptions remain subject to all other obligations in the Act that are not expressly disapplied by the instrument. For instance the instrument does not purport to alter obligations not mentioned in Part 2, or other duties such as general disclosure obligations, misleading or deceptive conduct prohibitions, or licensing conditions that remain in the Act. The instrument’s text should be read together with the Act because it expressly references and limits particular paragraphs of the Act (s 3, s 4).

• ASIC oversight. The instrument was made by ASIC (the compilation notes record that it was prepared by ASIC), and it is an ASIC instrument intended to operate under the statutory powers granted in the Act (s 3). While the instrument does not itself describe ASIC’s enforcement activities, ASIC’s role as regulator under the Act would be the forum in which compliance with both the Act and this instrument is assessed. The instrument’s conditions create factual predicates (for example the need to specify "significant factors" and include "an explanation of the impact") that ASIC could examine when assessing whether a responsible person or providing entity legitimately relied on the exemption.

• Scope for regulatory challenge. Because the instrument turns on fact-specific standards such as whether the PDS specifies "any significant factors" and whether a retail client "would reasonably require" an estimated value, compliance assessments will involve discretionary judgment. Those judgements could be the subject of regulatory attention or administrative review under processes available in the Act, though the instrument itself does not set out those review or penalty mechanisms.

In short, the instrument changes what is prescribed as the baseline statutory disclosure for select items. Enforcement will therefore focus on whether the issuer complied with the alternative information requirements of the instrument and with other residual obligations in the Act. The instrument does not itself create a schedule of penalties or enforcement steps; it modifies the content against which the statutory compliance of a PDS, SOA or periodic statement is measured.

This instrument is expressly tied to and operates by reference to provisions of the Corporations Act 2001. It does not purport to amend the Act. Its interaction with the broader legislative and regulatory framework follows from its explicit cross-references and from the imported definitions in s 4.

Key interactions recorded in the text are as follows.

• Direct cross-references to the Corporations Act. The instrument disapplies specified paragraphs and subsections of the Act in limited respects: paragraphs 1013D(1)(m) and 1013D(1)(d) for PDSs (s 5 and s 6(3)); paragraphs 947B(2)(h), 947C(2)(i), 947D(2)(d) for SOAs (s 6(1)); and subsection 1017D(5A) for periodic statements (s 7(2)). Because it operates by reference to specific Act paragraphs, the instrument must be read alongside those sections in the Act to understand the full legal consequences. The instrument’s exemptions are expressly tied to the text and scope of those Act provisions.

• Imported statutory definitions. The instrument imports the definitions of "providing entity" and "responsible person" from the Act (s 4). It also imports the definition of "warrant" by reference to the Corporations Regulations 2001 (s 4). The instrument therefore interacts horizontally with the Act and vertically with the Regulations by relying on those definitions to identify who can rely on the exemptions.

• No standalone repeal or amendment of Act provisions. The instrument does not amend or repeal the Act. It changes compliance obligations by providing that certain persons "do not have to comply" with particular required forms of disclosure in specific circumstances. This is a standard form of subordinate instrument power: an exemption instrument that modifies how the primary legislation is applied. The instrument’s practical legal operation therefore depends on the interplay between the Act’s baseline obligation and this instrument’s carve-outs.

• Tension points with other law areas. The instrument does not expressly address how its exemptions interact with other areas of law such as consumer protection statutes, contract law, financial services licensing obligations or general prohibitions against misleading or deceptive conduct. Those laws remain on the statute book and could be relevant to conduct that occurs when the instrument is relied upon. The instrument does not state that those other provisions are displaced. Any analysis of interaction with non-Act statutes must begin from the Act and the present instrument, because the instrument itself does not alter other statutory areas.

• Interaction with disclosure auditing and record-keeping. The instrument’s conditional exemptions require issuers to include alternative narrative and estimated-value information. This creates a practical intersection with record-keeping, internal compliance and audit processes, which typically operate under the Act and under licensing or regulatory requirements. The instrument does not prescribe evidence standards or retention periods, but because the exemptions turn on reasonable-client necessity and factual descriptions, issuers will need to document the factual basis for their reliance on the exemptions for regulatory scrutiny.

• Temporal interaction arising from amendment history. The endnotes show amendment instruments and commencement dates (Endnote 1). Anyone assessing the effect of the instrument for a particular PDS, SOA or periodic statement should check the applicable historical version because the instrument has been amended over time (see Endnote 1 and Endnote 2). The instrument itself does not alter the operation of unrelated statutes, but its amendments affect which version applies at a given point in time.

In sum, the instrument is a subordinate law tool that modifies how certain disclosure obligations in the Corporations Act are to be satisfied for specific document types. Its operation must be understood by reference to the Act and the Corporations Regulations for definitions, and it sits alongside other statutory obligations that remain in force.

The compilation provided includes an endnote charting the instrument’s registration and commencement dates as well as later amending instruments. The instrument’s recorded history in the endnotes is as follows.

• Original instrument. ASIC Corporations (Disclosure in Dollars) Instrument 2016/767 was registered on the Federal Register of Legislation on 18 August 2016 and commenced on 19 August 2016 (Endnote 1, table).

• Amendments. The instrument has been the subject of at least three subsequent instruments recorded in the compilation’s history. These are:

  • Instrument 2021/292, registered 27 April 2021, with commencement entries showing Schedule 1 commencing 28 April 2021, and Schedule 2 commencing 27 April 2022 (Endnote 1). The amendment history table in Endnote 2 notes that Section 4 was amended by 2021/292 and that Section 8 was revised by 2021/292 and later repealed and substituted (Endnote 2 shows entries "Section 4 am. 2021/292 rs. 2022/1032" and "Section 8 rs. 2021/292 rep. 2022/1032").

  • Instrument 2022/264, registered 13 April 2022 and commencing 14 April 2022 (Endnote 1). Endnote 2 records that Section 8 (note 2) was replaced in 2022/264 ("Section 8 (note 2) rep. 2022/264").

  • Instrument 2022/1032, registered 15 December 2022 and commencing 16 December 2022 (Endnote 1). Endnote 2 records that Section 4 was amended again by 2022/1032 ("Section 4 am. 2021/292 rs. 2022/1032") and that Section 8 was repealed and substituted by 2022/1032 ("Section 8 rs. 2021/292 rep. 2022/1032").

• Compilation note. The front matter of the compilation states that this is Compilation No. 3 and that the compilation is of the instrument "as in force on 16 December 2022", including any commenced amendment affecting the legislative instrument to that date.

The endnotes use standard annotation shorthand. They show that the instrument has been amended multiple times and that specific sections have been amended, substituted and that notes have been replaced. Section numbers referenced in the amendment table include Section 2, Section 4 and Section 8. The instrument as provided in this compilation includes the current text of the provisions cited in the body (Parts 1 and 2) as in force on the compilation date.

For practical compliance work, those dates and amending instrument numbers are the authority to locate earlier versions or to determine which version applied at a particular time. The compilation does not contain the text of the repealed or previous versions; practitioners will need to retrieve prior instrument versions from the Federal Register of Legislation if retrospective analysis is required.

The instrument text and the compilation endnotes do not record any case law or litigation that interprets this specific instrument. The compilation contains no judicial citations and the endnotes do not list litigation outcomes. The instrument itself cross-references provisions of the Corporations Act 2001, but the compilation does not name or summarise any judicial decisions applying or construing the instrument.

Consequently the compilation provides no on‑record litigation history for this instrument as of the compilation date (16 December 2022). Any reliance on the instrument in regulatory enforcement contexts or court proceedings would therefore require independent research beyond the instrument to identify whether ASIC enforcement, administrative determinations or judicial decisions have addressed its application since the compilation date. The instrument’s conditional standards , such as whether a PDS "specifies any significant factors" or whether a retail client "would reasonably require" an estimate , are fact‑sensitive and therefore potential subjects for regulatory challenge or judicial interpretation, but no such decisions are referenced in the source text.

Practitioners seeking litigation precedents or administrative rulings that engage this instrument should therefore consult court databases, ASIC enforcement releases and the Federal Register of Legislation for subsequent annotations. The compilation itself records only legislative amendment history and not case law.

The instrument is concise, but several practical pitfalls and points of ambiguity arise from its drafting and from the factual judgements it imposes. These are concrete implementation risks and compliance traps that follow directly from the instrument’s text.

1. Conditional exemptions depend on factual judgments. The exemptions in s 5 and s 6 hinge on standards that require judgement calls. A PDS must "specify any significant factors that will affect the cost" and "include an explanation of the impact of each of those factors" for the s 5 exemptions to apply (s 5(3)). For non-monetary benefits the SOA or PDS must include an estimated value "where a retail client would reasonably require such an estimated value" (s 6(2)(c), s 6(4)(c)). These standards are not numerically defined in the instrument, so issuers must make and document reasoned judgments. That documentation will be material if ASIC reviews reliance on the exemption.

2. Partial application and "to the extent" language. The foreign-currency exemptions in s 7 apply "to the extent" the Act requires conversion. That phrasing can lead to partial application in documents that contain both domestic and foreign currency exposures. Issuers must map precisely which Act provisions are being disapplied and ensure they do not inadvertently omit disclosure that remains required. The instrument’s language does not state conversion methodology, timing or exchange rates. Practitioners will need to be careful in mixed-currency disclosures.

3. Particulars for general insurance and life risk insurance. The s 5(1) exemption expressly preserves disclosure obligations about any excess or deductible "however described". Responsible persons for general and life risk insurance PDSs therefore must continue to disclose excess or deductible amounts in accordance with the Act. A drafting error that fails to disclose an excess because the issuer relied on the exemption elsewhere could produce non‑compliance.

4. Coverage differences by product type. The s 5 exemptions are product-specific. Derivatives, foreign exchange and warrants receive a different framing than general or life risk insurance products (s 5(1)-(2)). Issuers dealing with hybrid or complex products should correctly classify the product to determine whether s 5 applies and under which subparagraph. Misclassification risks are practical and predictable.

5. Reliance on imported definitions. The instrument imports "providing entity", "responsible person" and "warrant" from the Act and Regulations (s 4). Determining whether a person falls within those categories therefore requires consulting the Act and the Corporations Regulations. Failure to do that work can create the risk of incorrectly claiming the exemption.

6. Absence of conversion mechanics. For foreign currency amounts s 7 allows amounts to be stated in the foreign currency rather than in Australian dollars. The instrument does not prescribe how foreign currency amounts are to be displayed, whether exchange rates or conversion dates must be disclosed, or whether an AUD equivalent must be provided elsewhere. This silence leaves open formatting and consumer‑information risks.

7. Interaction with other statutory obligations. The instrument does not say it displaces other duties in the Act or other statutes. For instance it does not alter prohibitions on misleading and deceptive conduct. An issuer that complies with this instrument but produces disclosures that a regulator considers misleading or insufficient may still face regulatory action under the Act or other laws. The instrument’s silence on such interaction can be a minefield.

8. Documentation burden not stated but implied. Because the exemptions hinge on factual predicates and reasonable-client standards, issuers will likely need contemporaneous records explaining why the alternative disclosures meet the instrument’s conditions. The instrument does not set recordkeeping rules, but the need for evidentiary support is a practical gotcha.

9. Amendment timing. The endnotes show the instrument has been amended several times (Endnote 1 and Endnote 2). Ensuring the correct version applies to a particular PDS, SOA or periodic statement requires checking which amendments had commenced at the relevant time. Mistakes here can lead to reliance on inapplicable text.

These are not abstract risks. They follow directly from the instrument’s conditional language, its reliance on imported statutory definitions, its partial carve‑outs for particular products, and its silence about conversion mechanics and interaction with other legal duties.

Compliance under this instrument requires a procedural approach that aligns document drafting with the instrument’s conditional requirements and with the Corporations Act definitions it imports. The following practical checklist is grounded in the instrument’s text and the specific conditions set out in Parts 1 and 2. It is phrased as operational steps that responsible persons and providing entities should follow when preparing PDSs, SOAs or periodic statements.

1. Identify the relevant document and statutory role. Confirm whether the disclosure is a Product Disclosure Statement, Statement of Advice or periodic statement. Confirm whether you are the "responsible person" for the PDS or the "providing entity" for the SOA or periodic statement as those terms are defined in the Corporations Act (s 4). Check the Corporations Regulations for the definition of "warrant" if the product relates to warrants (s 4).

2. Determine whether the instrument’s exemptions are available for the product. For PDSs, establish whether the product is a general insurance product, a life risk insurance product, a derivative, a foreign exchange contract or a warrant, and then map to s 5(1) or s 5(2). For non-monetary benefits in PDSs and SOAs, consult s 6(1)-(4). For foreign currency presentation, consult s 7(1)-(2).

3. If relying on the cost exemption for a PDS (s 5), create and include the required content. The PDS must specify "any significant factors that will affect the cost of acquiring the product" and "include an explanation of the impact of each of those factors" (s 5(3)). Draft discrete, readable descriptions of those significant factors, and state how each factor affects acquisition cost. For general insurance and life risk insurance, ensure you still disclose any excess or deductible as required by the Act; do not omit excess/deductible information because of the exemption (s 5(1)).

4. If relying on the non-monetary benefits exemption for an SOA (s 6(1)-(2)) or PDS (s 6(3)-(4)), include the three prescribed items for each relevant non-monetary benefit or interest: (a) the nature and extent of the non-monetary benefit or interest; (b) for benefits that may be provided in the future, the circumstances in which they may be provided or arise; and (c) where "a retail client would reasonably require" it for decision-making, an estimated value in Australian dollars or a range of amounts in Australian dollars (s 6(2)(a)-(c), s 6(4)(a)-(c)). For (c) document the factual basis for concluding that a retail client would (or would not) reasonably require an estimated value.

5. If relying on the foreign currency exemption (s 7), determine scope and presentation. The instrument permits amounts denominated in a foreign currency to be stated in that currency rather than being converted to Australian dollars "to the extent" the Act would otherwise require conversion (s 7(1)-(2)). Decide whether any conversion is required elsewhere in the document and ensure that the presentation avoids inconsistency. Consider disclosing the currency and, where appropriate for investor understanding, the date of the foreign currency denomination and a reference statement that the amounts are in the stated foreign currency.

6. Keep contemporaneous compliance records. Because the instrument’s exemptions track fact-based standards, retain records that explain why the required alternative disclosures were included and why any dollar conversion or estimated-value decision was or was not necessary. Records should identify the specific clauses of the instrument relied upon (for example s 5(3), s 6(2)(c)), the factual analysis undertaken, and sign-off by an authorised compliance officer.

7. Coordinate with legal and compliance teams for cross-checks. Since the instrument imports statutory definitions and cross-references the Act, confirm with legal counsel that the person claiming the exemption falls within the imported statutory category and that no other Act provisions or regulatory duties are inadvertently breached by the alternative disclosure format.

8. Monitor amendments. The instrument has been amended multiple times (Endnote 1). Ensure that the version of the instrument used for compliance corresponds to the instrument that was in force at the time the PDS, SOA or periodic statement is issued. Maintain a log of which instrument version was in force on key issue dates.

9. Draft with consumer clarity in mind. Even though the instrument permits alternatives to strict dollar denomination, the replacement information must be meaningful. Draft the "significant factors" explanations and the non-monetary benefit descriptions to be intelligible to a reasonable retail client who is making acquisition or advice decisions. Where an estimated value in dollars is included, indicate whether it is an estimate and the method or assumptions used to derive it.

10. Consider disclosure consistency across related documents. If the same product is the subject of multiple documents (for example a PDS and a periodic statement), ensure consistency in how costs, non-monetary benefits and foreign currency amounts are presented across those documents, noting the particular instrument provisions that apply to each document type (s 5-7).

Following these steps aligns document preparation with the instrument’s conditional requirements. The core compliance principle in the instrument is that substitutes for dollar-denominated figures must be informative: significant factor explanations for cost, descriptive and circumscribed estimated-value information for non-monetary benefits, and clear presentation when foreign currency amounts are used. Documentation of the factual judgments underlying those substitutions is the practical keystone of defensible compliance.