The ASX’s one month extension to lodgement deadlines does not apply to foreign entities listed on the ASX

In June 2020 Accounting News we noted the ASX’s Class Waiver which allows listed entities to lodge reviewed half-year financial statements, or audited annual financial statements, up to one month late if certain criteria were met. The ASX’s Class Waiver was made in response to  the relief provided in ASIC’s Corporation  (Extended Reporting and Lodgement Deadlines – Listed Entities) Instrument 2020/451 to extend reporting deadlines by one month for listed entities lodging financial statements with ASIC (both half-year and annual financial statements). It is important to note that this extension only applies to entities reporting to ASIC under the Corporations Act 2001:

  • Chapter 2M (i.e. Australian registered entities), and
  • Chapter 7 (Australian Financial Services Licensees).
This means that foreign entities whose shares are traded on the ASX, including as Chess Depository Interests (CDIs), do not qualify for the one month extension because they do not report to ASIC under either Chapter 2M or Part 7 of the Corporations Act 2001. These foreign entities are instead required by the ASX Listing Rules to be registered foreign companies and report to ASIC under section 601CK of the Corporations Act 2001.

Key dates for foreign entities

Given that there are no reporting extensions for foreign entities, the following deadlines for reporting to the ASX must be adhered to for 30 June 2020 reporting dates:

Type of entity Half-years ending 30 June 2020 Annual periods ending 30 June 2020
Non-explorers Appendix 4D (together with half-year financial report and auditor’s review report) by 31 August 2020
  • Appendix 4E (can be unaudited) by 31 August 2020
  • Full-year statutory financial statements by 30 September 2020 (together with audit report).
Explorers Half-year financial report and auditor’s review report by 11 September 2020 Full-year statutory financial statements by 30 September 2020 (together with audit report).
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