Compliance, ASIC cyber resilience
ASIC cyber resilience training, phishing simulation and PI-insurer evidence.
Vigil covers the staff awareness, attack simulation and evidence ASIC's cyber resilience expectations require. Built for AFSL holders, financial advisers and dealer groups. Post-FIIG, every regulated entity needs to prove the programme is operating.
What ASIC expects, and where Vigil fits
| ASIC expectation | Source | How Vigil covers it |
|---|---|---|
| Staff awareness training | REP 716, REP 776, Corporate Plan | Role-based training for advisers, admin and executives. |
| Attack simulation | REP 716 §6.4, FIIG judgment | AI-personalised phishing, vishing and BEC simulation. |
| Incident response capability | REP 776, FIIG judgment | Reporting training plus incident-timeline evidence log. |
| Evidence of operating effectiveness | FIIG judgment, Corporate Plan | Continuous-control timeline and auditor portal. |
| Cyber risk management framework | REP 716, s 912A general obligations | Out of scope for Vigil (ISMS / GRC domain). Vigil supplies the awareness signal that feeds it. |
| Director / responsible-manager accountability | ASIC Corporate Plan | Board-level dashboard and responsible-manager attestation. |
Post-FIIG, what changed
In February 2026 the Federal Court ordered FIIG Securities to pay a A$2.5M penalty for cyber-security failings. This was ASIC's first cyber-security penalty against an AFSL holder. The Court found FIIG had inadequate awareness training, insufficient testing of controls, and weak incident response. The judgment compels the firm to engage an independent expert and implement a remediation programme covering each gap.
The signal to the industry is clear. Documented, operating, evidenced cyber-resilience controls are now an enforceable AFSL condition. Vigil exists to close the awareness, simulation and evidence gaps before they become enforcement triggers.
ASIC cyber and Vigil, common questions
Which ASIC documents set the cyber resilience expectations?
ASIC's cyber resilience expectations span multiple instruments rather than one Regulatory Guide. The primary references are REP 429 (Cyber resilience, 2015), REP 716 (Cyber resilience of firms in Australia's financial markets, 2021), REP 776 (Spotlight on cyber, 2023), the annual ASIC Corporate Plan, and enforcement positions such as the Federal Court judgment in ASIC v FIIG Securities (Feb 2026). The consistent themes are documented cyber-risk management, staff awareness training, attack simulation, incident response capability, and evidence the controls are operating.
Is RG 271 about cyber resilience?
No. RG 271 is ASIC's Internal Dispute Resolution guide for AFSL and Australian credit licensees. ASIC's cyber resilience expectations are spread across the REP series, the Corporate Plan and enforcement actions named above. Vigil's content uses the accurate references because audit and broker conversations rely on them.
What evidence does my PI insurer want at renewal?
Most professional-indemnity insurers covering AFSL holders now ask for quarterly phishing simulation results, role-based training completion across advisers and admin, BEC and payment-fraud control evidence, and an incident response plan. Vigil's evidence pack covers each in one PDF mapped to ASIC's published expectations.
How does this connect to the FIIG Securities enforcement action?
In February 2026 the Federal Court ordered FIIG Securities to pay a A$2.5M penalty for cyber-security failings. This was ASIC's first cyber-security penalty against an AFSL holder. The judgment identified inadequate awareness training, insufficient control testing, and weak incident response. The Court ordered FIIG to engage an independent expert and implement a remediation programme. Vigil is built to close those exact gaps before they become enforcement triggers.
Do I need both Vigil and a cyber-insurance broker?
They are complementary. Brokers place the cover and negotiate terms. Vigil produces the evidence that earns favourable terms and supports a claim payout. Several Australian brokers now refer their AFSL clients to Vigil ahead of renewal to strengthen the submission.
Does this scale from solo advisers to large dealer groups?
Yes. Vigil's per-seat pricing and self-serve onboarding suit a solo adviser (5 employees, set up in 30 minutes). The multi-tenant console and role-based dashboards scale to dealer groups managing 500 or more authorised representatives.
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