The Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Act 2025 introduces changes to beneficial ownership disclosure for entities listed on Australian financial markets. The reforms commence on 4 December 2026.
Key changes
- Foreign-incorporated listed entities: These entities will be expressly included in the disclosure framework.
- Equity derivatives: Disclosures will capture physically and non-physically settled derivatives providing economic exposure, even without voting rights.
- Deemed economic interests: ASIC has introduced revised calculations, including treatment of offsetting short positions.
- Substantial Holding Notices: A consolidated SHN form will replace Forms 603, 604 and 605.
- Registers of relevant interests: ASIC has implemented an index-based RORI format to improve transparency and accessibility.
A transition period for the new SHN forms will run from 4 December 2026 to 4 June 2027.
Practical implications
Foreign-owned groups with Australian-listed vehicles or significant derivative positions should review their arrangements before 4 December 2026. The reforms may affect takeover strategies, stapled structures, cross-border financing, hedging programs and internal ownership reporting.
How we can assist
We can review ownership and derivative arrangements, assess relevant interests, assist with substantial holding calculations and help update reporting and governance procedures.
