Target market determinations

Helping you understand the Design and Distribution Obligations


From 5 October 2021, the Design and Distribution Obligations (DDO) will come into effect for issuers and distributors of financial products. These new obligations are designed to help retail investors obtain financial products that are suitable for their objectives, financial situation and needs.

As we work through these new requirements, we will update the information on this page.

What is a Target Market Determination?

All product issuers are required to develop a TMD for each of their financial products that are intended for distribution to Australian retail investors (including via a platform).

Our TMDs will be available on the TMD web page for:

  • Russell Investment Funds and ETFs 
  • Superannuation and retirement products 

Please note: If you require a machine readable TMD, please contact us according to our details listed below.

Frequently asked questions


I am an advice licensee or financial adviser. What are my obligations as distributor under DDO?

ASIC has prepared a useful summary for advice licensees and financial advisers. You can find their factsheet on their website.


If you’re a distributor of Russell Investments products, what’s expected of you? 

You’re expected to understand your own obligations as a distributor under DDO. This includes (but is not limited to):

  • understanding the information set out in the TMDs about our products including how we have defined the target market;
  • taking reasonable steps to ensure the product is distributed in accordance with the TMD;
  • understanding and adhering to any distribution conditions established in the TMD;
  • submitting the required reports, at the required intervals, and in the required format as specified in the DDO, TMD and on this web page;
  • keeping accurate records of both the reasonable steps you have taken in ensuring the product is distributed according to the TMD and any information you may have provided to us; and
  • determining your own thresholds for what you as a distributor considers to be a significant dealing in relation to our products. 


How have we formulated our TMDs? 

The Financial Services Council (FSC) has developed TMD templates for industry use which we have used as the basis for the TMDs for the Russell Investments Funds, ETFs, and Super and Retirement products. We chose to largely follow the FSC templates (with some minor amendments) to assist with maintaining an industry standard and to help distributors comply with DDO.


What DDO reporting do I need to provide to Russell Investments? 

Product distributors are required to provide the following reports: 

  • Complaints  
  • Significant dealings; and 
  • Dealings outside the target market where the distributor is aware 

For more information about our reporting requirements, please refer to the product’s TMD. 

How do I need to provide DDO reporting to Russell Investments? 

We strongly encourage you to use the FSC data standards for the information you provide to us to fulfil your DDO reporting responsibilities. We recommend familiarising yourselves with the FSC data standards templates ahead of the first required reporting period.  

Distributors can provide DDO reports to us in two ways: 

1. Online reporting form 

An online reporting form will be available for distributors to fill in the details of their DDO reports according to the FSC data standards template.  

2. Email reports 

We will accept DDO reports via email. We strongly encourage the use of the FSC data standards templates.  

For Russell Investments Funds and ETFs please send your DDO reports to 
For Super and retirement products please send your DDO reports to  

What is a complaint and how do I report them? 

Complaints in relation to DDO are expressions of dissatisfaction about a product.  

For DDO complaints reporting, we need complaints information for actual product complaints (i.e. expressions of dissatisfaction). 

The complaints reporting required by the TMDs, relates only to DDO. Our existing internal complaints handling processes continue as they normally would under RG271 (and previously RG 165), where we are required to acknowledge complaints as soon as practicable and resolve them within 30 calendar days for standard complaints and 45 calendar days for superannuation complaints. 

To report a complaint that is not part of your DDO reporting obligations for Russell Investments Funds and ETFs contact: and for super and retirement products contact:  

What is a significant dealing? 

Section 994F(6) of the Corporations Act requires distributors to notify the issuer if they become aware of a significant dealing in the product that is not consistent with the TMD. Neither the Corporations Act nor ASIC defines when a dealing is ‘significant’ and distributors have discretion to apply its ordinary meaning. 

A significant dealing for a distributor may be different to the issuer’s determination of a significant dealing and guidance is provided in our TMDs that may be helpful to distributors in determining their own definitions. 

Who should you contact for DDO related questions about our products?  

For questions relating to your DDO obligations and our products, please contact your relationship manager or alternatively you can direct your enquiry to the following mailboxes: 
For Russell Investments Funds and ETFs please contact  
For Super and retirement products please contact  

For additional information regarding your specific DDO obligations, we suggest that you contact your licensee, compliance consultant, legal adviser or other relevant industry body for more information.