Australia’s substantial holding disclosure regime is undergoing significant change, with enhanced beneficial ownership and substantial holding disclosure requirements coming into effect on 4 December 2026.
At the centre of the reforms is a new Substantial Holding Notice (SHN), which will consolidate the existing Forms 603, 604 and 605 into a single reporting framework.
For investment managers, hedge funds, banks, brokers and institutional investors, the change is more than a new regulatory form. The reforms expand the information that may need to be considered when assessing ownership and economic exposure, including certain interests arising through equity derivatives.
ASIC finalised the new framework on 30 July 2026, publishing the final SHN, updated regulatory guidance and related legislative instruments.
With the implementation date approaching, firms should now be assessing their data, aggregation, monitoring and disclosure processes.
Key Takeaways
- The new Substantial Holding Notice (SHN) will replace Forms 603, 604 and 605.
- The enhanced regime commences on 4 December 2026.
- A transition period runs from 4 December 2026 to 3 June 2027.
- During the transition period, interest holders can use either the new SHN or one of the replacement forms for Forms 603, 604 and 605.
- The reforms expand disclosure requirements relating to certain equity derivatives and deemed economic interests.
- Firms will need to consider direct holdings, relevant interests and applicable economic exposure when assessing their disclosure obligations.
- ASIC has updated RG 5, RG 9 and RG 222 to support the new framework.
- ASIC is also exploring a web-based portal with market operators for submitting substantial holding information.
What Is the New Australian Substantial Holding Notice?
The Substantial Holding Notice (SHN) is the new ASIC reporting form for substantial holding disclosures under Australia’s enhanced beneficial ownership framework.
It consolidates the existing three-form structure into a single notice.
From 4 December 2026, the new framework will replace the existing:
| Existing Form | Current Purpose | New Framework |
|---|---|---|
| Form 603 | Notice of initial substantial holder | Substantial Holding Notice |
| Form 604 | Notice of change of interests of substantial holder | Substantial Holding Notice |
| Form 605 | Notice of ceasing to be a substantial holder | Substantial Holding Notice |
ASIC has designed the SHN to provide a more consistent reporting structure while accommodating the enhanced disclosure requirements introduced by the legislative reforms.
Why Is Australia Replacing Forms 603, 604 and 605?
The existing substantial holding regime was developed around the disclosure of interests in listed securities.
However, investment structures and financial instruments have evolved significantly, allowing investors to establish substantial economic exposure through arrangements that may not be captured in the same way as direct holdings.
The reforms are intended to improve transparency around:
- Who owns securities
- Who controls voting power
- Who has relevant interests
- Who has significant economic exposure
- How derivative positions contribute to that exposure
- The beneficial ownership of listed entities
The enhanced framework therefore broadens the disclosure regime to better capture interests arising through equity derivatives and introduces the concept of a deemed economic interest.
What Is Changing Under the New SHN Framework?
1. A Single Substantial Holding Notice
The most visible change is the move from three existing forms to one consolidated Substantial Holding Notice.
Instead of determining whether an event requires Form 603, 604 or 605, the new SHN provides a common reporting structure for substantial holding events.
This should simplify the form-selection process while creating a more consistent approach to reporting.
2. Certain Equity Derivatives Come Into Scope
One of the most important changes is the broader treatment of interests arising through equity derivatives.
The reforms are designed to improve visibility of economic exposure to listed securities, including exposure that may arise through derivative arrangements.
This is particularly relevant to investment managers using:
- Cash-settled derivatives
- Other equity derivatives
- Complex investment structures
- Multiple portfolio strategies
- Positions spread across different entities or accounts
The final ASIC framework also includes changes to the calculation of deemed economic interests and offsetting short positions.
For firms that previously monitored physical holdings separately from derivative exposure, this may require a significant review of existing processes.
What Is a Deemed Economic Interest?
The new framework introduces the concept of a Deemed Economic Interest (DEI).
Broadly, the concept is intended to capture certain economic exposure to securities where a person does not necessarily hold the underlying securities directly.
ASIC’s updated RG 5 – Relevant interests and deemed economic interests provides guidance on relevant interests, deemed economic interests and the legislative modifications introduced by the reforms.
For investment managers, the practical implication is important:
Disclosure monitoring increasingly needs to look beyond physical shareholdings.
Firms may need to consider how different instruments and structures contribute to their overall exposure when determining whether disclosure obligations have been triggered.
What Does the New SHN Need to Capture?
The final SHN provides for reporting of holdings and relevant exposure in a structured format.
The final form includes fields addressing:
- Previous and present holding percentages
- Non-derivative-based holdings
- Derivative-based holding percentages
- Derivative-based interest
- Deemed physically settleable holdings
- Deemed non-physically settleable holdings
- Offsetting short positions
- Disclosable movements
- Transactions giving rise to those movements
This makes the underlying data and calculation process increasingly important to the disclosure workflow.
The final SHN published by ASIC specifically separates derivative-based holdings, deemed economic interests and offsetting short positions within the reporting structure.
When Does the New Substantial Holding Notice Take Effect?
The enhanced substantial holding and beneficial ownership disclosure regime commences on:
4 December 2026
From this date, entities listed on Australian financial markets become subject to the enhanced disclosure requirements.
However, ASIC has provided a transition period to allow market participants to move to the new reporting framework. This transition window runs from 4 December 2026 to 3 June 2027, during which transitional versions of Forms 603, 604, and 605 can be used in place of the new master form.
The SHN Transition Period Explained
The transition period runs from:
4 December 2026 to 3 June 2027
During this period, interest holders can meet their substantial holding obligations using either:
- The new Substantial Holding Notice, or
- One of the three replacement forms corresponding to Forms 603, 604 and 605.
This gives firms additional time to update their internal processes, technology and reporting workflows.
Importantly, however, firms should not treat the transition period as an opportunity to delay preparation.
The underlying enhanced disclosure requirements commence on 4 December 2026.
Australia SHN Implementation Timeline
| Date | Milestone |
|---|---|
| 10 March 2026 | ASIC publishes Consultation Paper 387 and draft SHN |
| 21 April 2026 | Consultation closes |
| 30 July 2026 | ASIC finalises the SHN, legislative instruments and updated guidance |
| 4 December 2026 | Enhanced substantial holding and beneficial ownership disclosure regime commences |
| 4 December 2026 – 3 June 2027 | Transitional period |
| From 4 June 2027 | Transitional forms are no longer available |
ASIC’s final framework and updated regulatory guidance were published on 30 July 2026.
Current Regime vs New SHN Framework
| Area | Current Regime | From 4 December 2026 |
|---|---|---|
| Reporting forms | Forms 603, 604 and 605 | Single Substantial Holding Notice |
| Substantial holding framework | Existing Chapter 6C requirements | Enhanced Chapter 6C framework |
| Equity derivatives | More limited disclosure treatment | Expanded disclosure treatment |
| Economic exposure | Less comprehensive visibility | Deemed economic interest framework |
| Ownership transparency | Existing requirements | Enhanced beneficial ownership disclosure |
| Transition | Not applicable | SHN or replacement forms available until 3 June 2027 |
| Regulatory guidance | Existing guidance | Updated RG 5, RG 9 and RG 222 |
The reforms are intended to improve transparency around ownership, control and significant economic exposure while simplifying aspects of the reporting framework.
Who Needs to Prepare for the New Australian SHN?
The changes are particularly relevant to organisations and investment professionals with exposure to entities listed on Australian financial markets.
This includes:
- Asset managers
- Investment managers
- Hedge funds
- Institutional investors
- Banks
- Brokers
- Fund managers
- Other entities responsible for monitoring substantial holdings
The impact can be particularly significant for global investment managers.
Australian substantial holding requirements are rarely managed in isolation. A single portfolio may also be subject to shareholder disclosure requirements in the US, Europe, Canada, Hong Kong and other markets.
This creates a broader operational challenge:
How do you monitor multiple jurisdictions, multiple thresholds, multiple instruments and multiple entities consistently?
What Should Investment Managers Do Now?
With the new regime less than three months away, firms should be reviewing their existing shareholder disclosure processes.
1. Identify Australian exposure
Determine which funds, portfolios, accounts and legal entities have exposure to securities listed on Australian financial markets.
2. Review your data sources
Assess whether the data required to calculate substantial holdings and relevant economic exposure is available accurately and on a sufficiently timely basis.
3. Review aggregation methodology
Understand how positions are aggregated across:
- Funds
- Accounts
- Legal entities
- Investment strategies
- Associated entities
4. Assess derivative exposure
Review how equity derivatives are captured and incorporated into your disclosure calculations.
This is particularly important under the enhanced framework because certain derivative-based economic exposure can now form part of the disclosure assessment.
5. Review regulatory rules
Ensure your regulatory rule sets reflect the new Australian requirements and are maintained as the framework evolves.
6. Review disclosure workflows
Map the process from:
Position Change > Calculation > Threshold Assessment > Alert > Review > Approval > Disclosure > Audit Trail
Every stage should have clear ownership and appropriate controls.
7. Test your audit trail
Your firm should be able to evidence:
- What position was identified
- What data was used
- Which regulatory rule was applied
- How the exposure was calculated
- When a reportable event occurred
- Who reviewed the position
- What decision was made
- What disclosure was submitted
Digital Reporting and the Future of Australian Disclosure
The move towards a more structured disclosure framework also creates opportunities for greater digitalisation.
ASIC has stated that it is exploring with market operators a web-based portal through which users could submit substantial holding information.
While the portal is still being explored, the direction is clear: regulatory disclosure processes are increasingly moving towards structured data, automation and more integrated reporting workflows.
For investment managers, this makes the quality of the underlying data and monitoring process increasingly important.
A regulatory form is only the final output.
The real challenge is ensuring that the right position data, regulatory rules and calculations are available before the form needs to be completed.
Why Spreadsheet-Based Disclosure Monitoring Is Becoming Harder
Spreadsheets can work effectively for relatively straightforward processes.
The challenge increases when a firm needs to manage:
Multiple jurisdictions + multiple portfolios + multiple entities + multiple instruments + changing regulatory requirements.
Manual processes can create risks including:
- Incorrect calculations
- Outdated thresholds
- Missed position changes
- Inconsistent aggregation
- Manual data-entry errors
- Missed deadlines
- Fragmented approval processes
- Limited auditability
The Australian reforms demonstrate why shareholder disclosure monitoring is increasingly becoming a data and operational control challenge, rather than simply a regulatory filing task.
Automating Australian Shareholder Disclosure Monitoring
The Australian SHN reforms form part of a wider trend towards greater transparency around ownership, economic exposure and regulatory reporting.
For global investment managers, this means disclosure obligations need to be monitored consistently across jurisdictions, portfolios, entities and instruments.
Funds-Axis Galaxy Shareholder Disclosure Software automates shareholder disclosure monitoring across 80+ jurisdictions, helping investment firms monitor thresholds, aggregate holdings and manage disclosure workflows from a single platform.
Galaxy supports major shareholding disclosures across markets including Australia, the US, Canada, Hong Kong and Europe, with pre-configured rules, aggregation capabilities, early-warning thresholds and disclosure workflows.
Key capabilities include:
Jurisdiction-Specific Rule Packs
Pre-configured and regularly updated regulatory rules help firms manage complex disclosure requirements without relying on manual regulatory research.
Smart Position Aggregation
Aggregate holdings across entities, portfolios and levels to provide a more complete view of exposure.
Galaxy also supports the decomposition of baskets, ETFs and indices to help identify underlying exposures.
Automated Threshold Monitoring
Monitor disclosure thresholds continuously and receive early-warning alerts as positions approach reportable levels.
End-to-End Disclosure Workflows
Manage calculations, investigation, review, approval and reporting through a structured workflow.
One-Click Reporting
Generate disclosure reports efficiently once a reportable event has been identified.
Complete Audit Trail
Maintain evidence of calculations, rule application, decisions and disclosure activity to support internal governance and regulatory review.
Flexible Deployment
Galaxy can be deployed as a standalone technology solution or through a managed service model, depending on the firm’s operating model and internal resources.
Australia Is Changing. Is Your Disclosure Process Ready?
The introduction of the Substantial Holding Notice represents an important change to Australia’s shareholder disclosure framework.
But for investment managers, the biggest challenge isn’t simply learning how to complete a new form.
It is making sure the underlying data, aggregation, regulatory logic, threshold monitoring and workflow can identify a reportable event accurately and in time.
The transition period provides firms with an opportunity to assess and strengthen their processes before the new framework becomes fully embedded.
And for firms managing portfolios across multiple markets, the Australian changes provide another reminder of the importance of having a scalable approach to global shareholder disclosure monitoring.
Automate Australian Shareholder Disclosure Monitoring
Australia’s new Substantial Holding Notice framework introduces broader disclosure obligations and increased reporting complexity. Galaxy helps firms monitor physical holdings, derivatives, associates and economic exposure across jurisdictions, supporting timely identification of disclosure obligations and audit-ready compliance processes.
Related Reading
- Australia Shareholder Disclosure Changes 2026: Substantial Holding & Derivative Disclosure Explained
Explore the wider Australian shareholder disclosure reforms, including the treatment of derivative exposure and deemed economic interests.
View Australia Analysis
- Shareholder Disclosure Monitoring Software
Discover how Galaxy helps investment firms automate major shareholding, short selling, takeover and other shareholder disclosure obligations across 80+ jurisdictions.
Explore Galaxy Shareholder Disclosure Software
Frequently Asked Questions
What replaces Forms 603, 604 and 605?
The new Substantial Holding Notice (SHN) consolidates the three existing forms into a single reporting framework. During the transition period, however, interest holders can use either the new SHN or the replacement forms corresponding to Forms 603, 604 and 605.
When does the new Australian SHN take effect?
The enhanced substantial holding and beneficial ownership disclosure regime commences on 4 December 2026.
How long is the SHN transition period?
The transition period runs from 4 December 2026 to 3 June 2027. During this period, firms can use either the new SHN or the applicable replacement form.
Are equity derivatives included in the new regime?
The reforms expand disclosure requirements to better capture interests arising through equity derivatives. ASIC’s updated guidance also addresses deemed economic interests and offsetting short positions.
What is a Deemed Economic Interest?
A Deemed Economic Interest (DEI) is a concept within the enhanced framework intended to capture certain economic exposure to securities. ASIC’s updated RG 5 provides guidance on deemed economic interests and related calculations.
Has ASIC finalised the new Substantial Holding Notice?
Yes. ASIC finalised the new SHN, related legislative instruments and updated regulatory guidance on 30 July 2026.
Which ASIC guidance has been updated?
ASIC has updated several regulatory guides in connection with the reforms, including:
- RG 5 – Relevant interests and deemed economic interests
- RG 9 – Takeover bids
- RG 222 – Substantial holding disclosure and tracing requirements
RG 222 specifically provides guidance on substantial holding disclosure and beneficial ownership tracing requirements, including requirements commencing on 4 December 2026.
Is ASIC introducing a digital submission portal?
ASIC has stated that it is exploring with market operators a web-based portal for users to submit substantial holding information. This is an ongoing development rather than a confirmed replacement for the current submission process.
What is the difference between Form 603 and the new SHN?
Form 603 is currently used when a person becomes a substantial holder. Under the enhanced framework, the new Substantial Holding Notice (SHN) consolidates the functions of Forms 603, 604 and 605 into a single reporting structure.
Regulatory Disclaimer
This article is provided for general informational purposes only and does not constitute legal, regulatory or investment advice. The Australian regulatory framework is subject to change and firms should consult the applicable legislation, ASIC guidance and professional advisers when assessing their specific obligations.
