ACCC Issues Updated Guidance on Trust Account & Audit Requirements

The ACCC has released new guidance detailing the trust-accounting and audit obligations now applying to water market intermediaries. These requirements form part of broader reforms aimed at improving transparency and strengthening confidence across Australia’s water markets.

December 1, 2025  |  Australian Water Brokers Association

The ACCC’s updated materials outline how intermediaries must establish and manage a compliant water market trust account, including rules for account naming, handling client funds, maintaining client ledgers, and retaining records for six years.
Full guidance is available here:
https://www.accc.gov.au/business/industry-codes/water-markets-intermediaries-code/statutory-trust-accounting-requirements

The Commission has also provided detailed instructions on appointing an independent trust account auditor, who must be engaged within three months of the trust-account obligation arising. This section includes an example trust account statement and an example audit report form to assist intermediaries in preparing their annual audit.
Audit guidance:
https://www.accc.gov.au/business/industry-codes/water-markets-intermediaries-code/statutory-trust-accounting-requirements#toc-appointing-a-trust-account-auditor

These requirements reflect recommendations from recent water market reforms and are designed to safeguard client funds and ensure greater accountability in intermediary operations.

The AWBA has issued a reminder to all Members to review the updated ACCC guidance, confirm their trust-account and audit arrangements meet the Code’s obligations, and seek professional advice where necessary to ensure full compliance.

Media Contact: Andrew Martin, President | 0436 627 083 | president@awba.org.au

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