If you didn’t know, ASIC – short for the Australian Securities and Investments Commission and you can think of them as Australia’s financial watchdog, keeping an eye on everything from big corporations to your local credit agencies.

So, they’ve just dropped their Reconciliation Action Plan for 2023-2026, which is all very trendy for companies to flaunt their RAPs and CSR initiatives but is it all for real impact or just some PR stunt?

And with most of the “closing the gap” goals aren’t hitting the mark, and some are even backsliding. Makes you wonder, right? Let’s take a closer look at these CSR initiatives that talk a big game but might be dropping the ball when it comes to real results.

ASIC ReconciliACTION Score

ASIC Reconciliation Action Plan
ASIC Reconciliation Action Plan


  • The emphasis on consumer protection for Indigenous Australians addresses a crucial area where ASIC can make a tangible difference.
  • The initiatives, if successfully implemented, have the potential to create a significant positive impact on Indigenous communities, especially in terms of financial protection and well-being.
  • The plan’s focus on embedding reconciliation across ASIC and enhancing the cultural capability of all team members can lead to long-term, systemic change within the organisation.

Tangible Pros

  • Increase the number of thematic projects undertaken that result in regulatory outcomes affecting Aboriginal and Torres Strait Islander consumers from a baseline of 0 to a target of 4.
  • Increase the percentage of regulatory activities that result in regulatory outcomes where Aboriginal and Torres Strait Islander consumers are identifiable as one of the consumer groups affected by the misconduct, from a baseline of 43% to a target of 65%.
  • Increase the percentage of regulatory activities that result in regulatory outcomes where harm or misconduct is primarily or substantially targeted at Aboriginal and Torres Strait Islander consumers, from a baseline of 45% to a target of 65%.
  • ASIC had a 1.82% Aboriginal and Torres Strait Islander employment rate, with 38 team members identifying as Aboriginal and/or Torres Strait Islander peoples.
  • They aim to increase Aboriginal and Torres Strait Islander applicants for ASIC roles from a baseline of 0.7% to a target of 4% of all applicants.
  • Increase the percentage of spend on contracts with Aboriginal and Torres Strait Islander businesses, from a baseline of 2% to a target of 3.75% of ASIC’s eligible spend.


  • Despite intensifying its Indigenous Outreach Program, ASIC’s previous RAPs, especially the 2017-2020 one with over 90 commitments, didn’t effectively measure their real-world impact.
  • Under ASIC’s watch, some companies exploited regulatory gaps to take advantage of Indigenous consumers. This highlights the pressing need for tighter regulations.
  • Major banks, despite their clout, haven’t adequately bridged the financial disparity faced by Indigenous communities. They’ve largely overlooked the introduction of culturally relevant financial products. The alarming rise in First Nations suicides points to the dire consequences of this neglect, with “crushing poverty” and systemic despair at its core.
  • The Financial Royal Commission’s revelations about a fund exploiting regulatory gaps led to the sealing of these gaps in 2020. ASIC subsequently pursued an A$7.5 million fine against the fund for its deceptive practices. However, after rebranding as Youpla, the fund declared bankruptcy in March 2022, leaving many families bereft of resources for Sorry Business expenses.
  • While it’s noteworthy that ASIC boasts a 1.82% employment rate for Aboriginal and Torres Strait Islander individuals, the absence of specifics regarding the nature of this employment—whether full-time, part-time, or casual—raises questions. It’s not uncommon for government and large corporations to inflate their representation statistics by incorporating “Trainees” or other temporary roles, or even asking people to “tick a box”… which can paint a rosier picture in reports than the reality on the ground. Such nuances are crucial for a comprehensive understanding of genuine inclusivity.
  • Similar to jobs, procurement goals lack specificity and clarity without additional information. What criteria does ASIC use to define Aboriginal and Torres Strait Islander businesses? Are joint ventures or instances of “blakwashing” included, where most of the funds benefit non-Indigenous partners or employees, with little to no impact in First Nations communities?

Summary: ASIC Reconciliation Action Plan

While ASIC has made commendable strides in various areas, it falls short in addressing critical issues that could bridge the vast financial divide between Indigenous and non-Indigenous communities.

The lack of culturally appropriate financial products is a glaring oversight, and there seems to be an absence of concrete measures to influence policies or the broader financial industry in a direction that would genuinely help close the disparity gaps between Indigenous and non-Indigenous Australians.

And while ASIC does have its limitations, it can influence the financial sector and big banks when they want to e.g. “ASIC’s early warning to banks: Take care of hardship cases or we’ll do it for you“.

P.S. What’s ReconciliAction? Imagine blending reconciliation with corporate social responsibility but stripping away all the PR gloss and emphasising tangible actions and outcomes…

ReconciliACTION Scores

WhoReconciliation ClaimRAPReconciliACTION ScorePublic Score
Google2023-25 RAP:
Our vision for reconciliation is one where the cultures, knowledge and histories of Indigenous Australians are accessible, understood and appreciated by all Australians.
ASIC2023-26 RAP:
Ensuring that Aboriginal and Torres Strait Islander peoples can access the financial system and experience positive financial outcomes.
Reflections Holiday Park2023-24 RAP:
Reflections will develop opportunities for cultural expression and celebration while delivering social, cultural, and economic outcomes for Aboriginal communities.
KPMG2021–2025 RAP:
Guided by our purpose to ‘Inspire Confidence, Empower Change’, we are committed to placing truth-telling, self-determination and cultural safety at the centre of our approach.

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