Audit of firm-level performance data requires annual audit, standard ToR, inclusion of all clients, and regulator submission. Portfolio Managers must perform an annual firm-level performance audit including all clients' portfolios across discretionary and non-discretionary services; advisory clients may be excluded only if their performance is not reported or published. APMI will prescribe standardised Terms of Reference, which are mandatory from October 01, 2023. Portfolio Managers must submit a certified confirmation of compliance and the audit report to the regulator within sixty days of the financial year end, with certification by directors, partners or authorised persons.