What this means
Start with the exact decision in front of you.
Personal licensees must comply with applicable conditions and cooperate with the Commission. A case may examine notification, integrity, due care or management failures, but the precise condition and factual responsibility must be identified.
Immediate priorities
Organise the position before responding.
Check the current personal licence and general conditions
Record disclosures and communications with the Commission
Map decisions against the holder's actual authority
Detailed guidance
The procedure, evidence and possible route from here.
01
Identify personal conditions and key events
A PML holder must comply with the conditions attached to personal licences, including reporting specified personal key events. The Commission's current material uses a ten-working-day period for relevant personal events. Obtain the licence, current LCCP wording and event details. Do not confuse this personal duty with the operator's separate key-event reporting obligations, which can have a different, often shorter, deadline.
Create a notification table showing the event, date it occurred or became known, rule, due date, actual report and supporting evidence. Examples may involve criminal matters, bankruptcy or other specified changes, but the current condition must be checked. If a report was late or incomplete, explain the reason and provide the missing information promptly without altering the original record of what was sent.
- Check the current personal licence conditions
- Calculate the ten-working-day personal deadline
- Preserve the original report and submission receipt
02
Apply openness and cooperation accurately
The Commission expects personal licensees to work openly and cooperatively and disclose matters it would reasonably expect to know. That expectation does not justify guessing at facts. State what is known, identify sources and correct material errors promptly. If legal or employment proceedings are unresolved, describe their status accurately rather than labelling an allegation as a conviction or a disputed finding as established.
A personal disclosure may overlap with an operator report, but one does not automatically satisfy the other. Compare both duties and ensure the correct account or service received the information. Where confidentiality or privilege is relevant, identify the specific issue and seek a lawful way to provide what is required. Silence based on an assumed restriction can itself deepen the regulatory concern.
- Report facts with precise procedural status
- Make personal and operator notifications separately
- Raise confidentiality issues rather than assuming non-disclosure
03
Respond to an alleged reporting breach
If the Commission alleges late or missing disclosure, confirm the trigger date and version of the condition in force. Review what the holder knew, any advice received and whether information was provided through another channel. Evidence of misunderstanding may explain events but does not automatically remove the obligation. Address impact on regulatory oversight, candour and any steps taken to prevent recurrence.
A reporting breach can form part of a section 116 review and may affect suitability, particularly where information was material or deliberately withheld. Prepare a focused chronology and copies of portal receipts, emails or call notes. Remediation may include diary controls, delegated checking and periodic licence review. Keep those improvements specific; a generic promise to communicate better will not demonstrate a reliable compliance system.
- Fix the trigger and rule version
- Document what was known and reported
- Implement verifiable reporting controls
Key questions
Keep the analysis tied to this stage.
Which condition or expectation applied
Whether information was complete and timely
Whether any failure was personal, systemic or both
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
How quickly must a PML holder report a personal key event?
The Commission's current PML material uses ten working days for specified personal key events. Check the current condition and event.
Does the operator's report satisfy my personal duty?
Not necessarily. The operator and PML holder have separate licences and notification requirements, so each duty should be checked and completed.
Connected guidance
Continue through the topic map.
Use the hub for the full sequence or choose the connected route that matches the notice.
Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.