Overview
Under CDR Rule 9.4, data holders must prepare a report for each reporting period (in the ACCC-approved form) that includes, among other things:- A summary of CDR complaint data for the period.
- The number of:
- Product data requests, and
- Consumer data requests (separately for requests made by eligible consumers, and requests made by accredited persons on behalf of eligible consumers), received during the period.
- For each request type above, details of refusals to disclose CDR data, including the rule or data standard relied upon.
Reporting periods and due dates
The reporting periods are:- 1 January to 30 June
- 1 July to 31 December
- Period ending 30 June → due 30 July
- Period ending 31 December → due 30 January
What Fiskil provides vs what you provide
When completing the data holder report, you will generally pull information from two places:Data holder-owned inputs (you provide)
You are responsible for preparing and validating inputs that are internal to your organisation, including:- Your CDR complaint data summary for the reporting period (counts, categories, internal dispute resolution timeframes, external dispute resolution referrals/outcomes, etc.).
Fiskil-supported inputs (Fiskil provides in the Console)
Fiskil’s Analytics tab is designed to provide the request and refusal metrics you need for the “data requests received” section of the report, based on traffic handled by your Fiskil Data Provider implementation:- Product data requests received
- Consumer data requests received (from accredited persons on behalf of eligible CDR consumers)
- Refusal counts (including totals and error-code breakdowns, where applicable)
Note on “received”: the ACCC reporting form guidance typically treats “received” as requests that reached the data holder system (including both successful and unsuccessful outcomes, and including requests rejected due to traffic thresholds). Make sure you apply the reporting form’s definition when completing your submission.
Using the Analytics tab
1) Open the Analytics tab
In the Fiskil Console:- Select your Data Provider workspace (top left).
- Navigate to Analytics.
- Product Data Requests
- Consumer Data Requests
2) Select the correct environment
Use the environment selector (top right) to choose the environment you want to report on.- For regulatory reporting, this should almost always be Production.
- Staging is for testing and generally should not be used for regulatory submissions.
3) Select your reporting period
In the Period section, choose the date range that matches the reporting period you are submitting for:- 1 January → 30 June, or
- 1 July → 31 December
The date range picker excludes the end date. For example, selecting 01/07/2025 → 01/01/2026 returns data from 1 July 2025 up to (but not including) 1 January 2026.
4) Copy values into the reporting form
Use the tile values to populate the matching fields in the ACCC-approved reporting form.Mapping: Analytics tiles → reporting form fields
| Fiskil Console (Analytics) | Use this value for… |
|---|---|
| Product Data Requests | “Number of product data requests received” |
| Consumer Data Requests | “Number of consumer data requests made by accredited persons on behalf of eligible CDR consumers received” |
Direct consumer data requests (eligible consumers)
CDR Rule 9.4 also calls out consumer data requests made by eligible CDR consumers as a separate number. Depending on your operating model:- If you do not support direct consumer requests outside the accredited-person flow, this will often be 0 (confirm with your implementation and legal/compliance advice).
- If you do support direct consumer requests, you’ll need to source that number from the system handling those requests (it may be outside Fiskil’s Data Provider request flow).
Refusals to disclose CDR data
The reporting form also requires refusal reporting for each request type, including:- how many times you refused to disclose, and
- which rule or data standard you relied on.
Good practice: keep your supporting evidence
Reporting is closely linked to record keeping. Data holders must retain relevant records for 7 years. We recommend saving (internally) for each reporting submission:- The date range used in Analytics
- The values copied into the report
- Any supporting exports/log evidence used for refusal metrics
- Your complaint summary workings and dispute resolution stats
Quick checklist
Before submitting your biannual report:- Selected the correct reporting period (1 Jan–30 Jun or 1 Jul–31 Dec).
- Confirmed you are viewing Production metrics (not Staging).
- Copied Product Data Requests into the “product data requests received” field.
- Copied Consumer Data Requests into the “accredited person requests received” field.
- Completed your CDR complaint data summary (internal).
- Completed refusal reporting (counts + grounds).
- Submitted within 30 days after the end of the reporting period.