Australia’s substantial holdings disclosure reforms are set to reshape how fund managers report shareholdings. With new rules proposed by ASIC, understanding your fund manager compliance obligations is more critical than ever.
On 7 October 2025, the Australian Government introduced the Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill 2025, marking a significant step toward enhancing transparency and resilience in financial markets.
This bill proposes targeted amendments to the Corporations Act 2001, focusing on the substantial holdings disclosure regime in Australia. These reforms aim to close regulatory gaps and align Australia’s financial system with international best practices, as guided by ASIC shareholder disclosure reform initiatives.
Key Changes in Australia’s Substantial Holdings Disclosure Reforms
Cash-Settled Derivatives in Substantial Holdings Disclosure
Currently, only physically settled derivatives are considered when calculating substantial shareholdings. The proposed changes will expand this scope to include cash-settled equity derivatives, ensuring all relevant financial instruments are captured in disclosure obligations. This move is expected to improve market transparency and reduce the risk of hidden ownership structures, key goals of Australia’s evolving financial transparency legislation.
Expanded Issuer Coverage Under Australian Disclosure Reforms
The bill also extends the substantial shareholding tracing regime to foreign-incorporated entities listed on Australian financial markets. This ensures overseas companies operating in Australia are subject to the same disclosure standards as domestic issuers, promoting fairness and consistency across the board.
Why Australian Substantial Holdings Disclosure Reforms Matter
These reforms are part of a broader effort to strengthen Australia’s financial system by:
- Enhancing market integrity and investor confidence
- Reducing opportunities for regulatory arbitrage
- Aligning Australia’s disclosure standards with global best practices
For fund manager compliance obligations, these changes represent a shift in how holdings must be tracked and reported, especially for firms with exposure to Australian markets.
Fund Manager Compliance Obligations – What to Do Next
The bill is currently under parliamentary review. Stakeholders, including listed entities, institutional investors, and legal advisors, should:
- Monitor its progress closely
- Assess potential impacts on disclosure obligations
- Prepare for compliance updates and system changes
Automating Substantial Holdings Disclosure Across Jurisdictions
At Funds-Axis, we help firms automate shareholder disclosure obligations across 80+ jurisdictions, including Australia. Our platform ensures compliance with evolving rules through:
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Learn more about our Shareholding Disclosure Solutions for managing fund manager compliance obligations across jurisdictions and download the brochure here: Explore Solutions.
Ready to Stay Ahead of Disclosure Reform?
Don’t wait for regulatory change to catch you off guard. Contact our shareholder disclosure experts today to learn how Funds-Axis can help your firm navigate the complexities of substantial holdings disclosure in Australia and short-selling regulations.
Frequently Asked Questions
Q: What are Australia’s substantial holdings disclosure reforms?
A: These are proposed changes to the Corporations Act 2001 aimed at improving transparency in financial markets by expanding disclosure obligations, including cash-settled derivatives and foreign issuers.
Q: How do these reforms affect fund manager compliance obligations?
A: Fund managers may need to update systems and processes to ensure compliance with expanded reporting requirements, particularly for derivatives and cross-border holdings.
Q: What is ASIC’s role in shareholder disclosure reform?
A: ASIC is driving regulatory updates to align Australia’s financial system with global best practices and close existing gaps in the substantial holdings disclosure regime.
Source: Australian Parliament Bill Digest – Treasury Laws Amendment Bill 2025
