Private credit has expanded to an estimated $224 billion in Australia, with private real estate credit representing ~40% of that market. The sector’s growth has outpaced the frameworks that traditionally keep capital aligned, risk measured, and investors informed.

The review acknowledged the important role private credit plays in Australia’s capital markets — particularly in a rising-rate, bank-tightening environment — but also highlighted material gaps in how some managers operate.

This is not surprising. The industry’s rapid influx of new entrants, varying levels of sophistication and inconsistent valuation or conflict-management practices have created a fragmented landscape.

ASIC’s findings were unambiguous: the industry must raise the bar on transparency, conflict management, disclosure and valuation discipline.

These are not minor adjustments. They reflect structural issues that impact investor trust, portfolio integrity and the long-term credibility of the asset class.

For Ark, the review aligns with where we’ve always positioned ourselves: disciplined, conservative, and built around investor-first principles.

But it also reinforces that now is the time to continue lifting our standards — not because we are required to, but because we have the opportunity to lead.

ASIC has made it clear that in 2026 they will sharpen their focus on:

• Fees and margin structures
• Conflict-of-interest management
• Valuation practices
• Real estate credit fund governance

This will include increased surveillance and updated regulatory guidance. In short: the spotlight is now squarely on wholesale real estate private credit managers.

While we believe Ark operates at and often above industry best practice, we’re not standing still.

1. Independent Valuations: More Frequent and More Transparent

We are reviewing our valuations framework to incorporate:

• More regular independent valuations of all projects, and
• The introduction of quarterly portfolio valuations for greater transparency and clarity for investors.

Valuation discipline is the backbone of responsible private credit. We see this as an opportunity to set a higher industry benchmark.

2. A Strengthened Conflicts Management Framework

Ark has recently established an Investment Conflicts Committee, including an independent member, to:

• Provide external oversight
• Strengthen conflict identification
• Ensure all decisions reflect investor-first principles
• Remove ambiguity in complex multi-party transactions

This is not a compliance exercise – it is cultural. It reinforces that our duty is to manage investors’ capital with discipline, independence and integrity.

The ASIC review should not be viewed as regulatory burden. It is a reset point — a moment for serious managers to distinguish themselves from those who rely on opaque valuation methods, loose governance or aggressive structuring.

For investors, this is positive. For the industry, it is necessary. For Ark, it is a moment to lead.

Private credit can only continue to deliver stable, risk-adjusted returns if the sector embraces better governance and transparency — not because ASIC demands it, but because investors deserve it.

Since Ark’s inception, “Investor First” has been more than a value; it has been the lens through which every decision is made.

This review reinforces that staying disciplined, conservative and transparent isn’t just best practice — it’s the future of private credit in Australia.

We Invite You to Explore the Full ASIC Report here 

We encourage investors to review ASIC’s findings and reach out to our team to discuss how these insights relate specifically to Ark’s approach, governance framework and investment discipline.

If you’re an investor, borrower or strategic partner who values forward-thinking leadership, now is the right time to connect.

Let’s talk about where you want to go and how we can help you get there.