---
title: "Build an AI-use gap table against s 912A, ASIC REP 798 and the APRA AI letter"
url: "https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations/commonwealth"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-T1-R2-CTH"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["CTH"]
last_reviewed: "2026-09-23"
---

# Build an AI-use gap table against s 912A, ASIC REP 798 and the APRA AI letter

> Map AI uses to the six REP 798 domains (accountability, risk, harm, transparency, oversight, vendors) and draft a gap register covering the ASIC and APRA letters named.

Canonical page: https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations/commonwealth  
Last reviewed: 2026-09-23

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Map AI uses to the six REP 798 domains (accountability, risk, harm, transparency, oversight, vendors) and draft a gap register covering the ASIC and APRA letters named. |
| What the lawyer must review | Include ASIC's May 2026 open letter (26-092MR) For APRA entities, include APRA's April 2026 AI letter Check each use case's risk rating and s 912A(1)(a) and (1)(h) Check CPS 230 (from 1 July 2025) Look for gaps beyond the tool's list |
| Written for | Commonwealth |
| Applies to | [Build an AI-use gap table against the licence's general obligations](https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations.md) |

## Checking plan

**Lawyer review required**

The responsible lawyer reviews the work against the instructions, sources and intended use.

- What the AI does: Potential support includes organising research leads and preparing preliminary structure or wording. Confirm the tool’s capability and permitted scope.
- What the lawyer does: Set the scope, verify the evidence, resolve exceptions and approve the final output for its intended use.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Suggested checking approach based on the task guidance. Complete the assessment for the actual tool, information and jurisdiction.
- Why: The plan reflects the described work and review requirements. Policy colours are not used to determine permission or checking.

## Checks the lawyer makes

1. Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions.
2. Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
3. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
4. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

## Notes

- Confirm the required checking with the responsible lawyer before work starts. The checking approach does not establish permission to use AI.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*