Product Design and Review Policy Template (DDO | Australia)

For financial product issuers and distributors

$499.00 +GST

Use this policy to:
  • Document your DDO perimeter assessment before any retail product distribution;
  • Approve target market determinations against a structured quality and appropriateness checklist;
  • Evidence reasonable steps across distributor selection, marketing, monitoring and escalation;
  • Record proposals, reviews and significant dealings using the eight included schedules.

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Product Design and Review Policy Template: Terms and Definitions

About this Document

The Product Design and Review Policy Template is an internal product governance policy for Australian businesses that design, issue, review or distribute financial and credit products. It sets out a design and distribution obligations framework under Part 7.8A of the Corporations Act 2001 (Cth) for retail products and a separate good-practice governance overlay for wholesale-only products.

Use this policy if you:

  • issue financial or credit products to retail clients and must make target market determinations
  • distribute products issued by another person and need documented reasonable-steps controls
  • operate wholesale-only products and want a governance overlay without assuming statutory DDO applies
  • need to evidence product governance to your Board, ASIC or an assurance reviewer

It is suited to:

  • financial product issuers, responsible entities and trustees
  • fund managers and AFS licensees
  • credit licensees and product distributors
  • compliance, risk and legal teams accountable for product governance

What this policy covers:

  • DDO perimeter assessment and the rule that no product proceeds to retail distribution without classification
  • governance roles for the Board, Product Governance Committee, Product Owner, Compliance, Risk, Legal and Internal Audit
  • a five-stage product lifecycle covering concept, design, approval, distribution and monitoring
  • minimum TMD content, the appropriateness requirements and target market granularity
  • issuer and distributor reasonable steps, marketing controls and distributor due diligence
  • monitoring data, periodic and trigger reviews, and the 10 business day review and notification timeframes
  • significant dealing assessment, material product change, suspension and closure
  • wholesale-only products, conflicts, remuneration, vulnerable consumers, training and record retention of up to seven years

You receive an editable Word document with eighteen numbered sections, eight schedules and a regulatory update table current to 8 August 2026. Highlighted fields such as [INSERT LEGAL ENTITY NAME], [INSERT ACN], [INSERT APPROVING BODY] and [INSERT ROLE] configure the policy for your entity, and Schedule 1 sets your committee composition, reporting frequencies and review month. Obtain legal review before adoption so the policy reflects your products, authorisations and distribution model.

How To Use This Template

This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.

Before you use it, you should:

  • Complete all placeholders, bracketed items and optional fields;
  • Remove any drafting notes or clauses that aren’t relevant to your situation; and
  • Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.

Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.

If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.

This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.

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