ASX to strictly enforce lodgement deadline rules

Since 31 January 2023, the Australian Securities Exchange (ASX) has been strictly enforcing lodgement rules.

To avoid reputational damage associated with having trading in securities suspended, we recommend that all listed entities be mindful of the ASX’s approach to late lodgements and suspensions. Listed entities should plan ahead as they cannot rely on weekends for more time to complete lodgements.

Under Listing Rule 17.5, the ASX suspends the trading of securities of entities that fail to lodge the following documents on time:

  • Appendix 4D and half-year report (Listing Rule 4.2A)
  • Appendix 4E preliminary final report (Listing Rule 4.3A)
  • Change of balance date 12-month period (Listing Rule 4.4A)
  • Annual financial reports lodged with ASIC (Listing Rule 4.5)
  • A copy of the annual financial report sent to shareholders (Listing Rule 4.7)
  • Quarterly cash flow reports (Listing Rule 4.7B)
  • Quarterly activity reports (Listing Rule 4.7C)
  • Investment entity’s net tangible asset backing (Listing Rule 4.12)
  • Quarterly reporting for mining producing entities, oil and gas producing entities, mining exploration entities, and oil and gas exploration entities (Listing Rule 5.1, 5.2, 5.3, 5.4 or 5.5).

If a Listing Rule requires something to be done by a day that is not a business day, Listing Rule 19.5 requires the thing to be done by the preceding business day. The ASX considers it important to keep the market informed in a timely manner and provide sufficient time for the market to consider reports lodged late. Therefore, the ASX is  strictly enforcing the late lodgement rules.

Any periodic reports must be lodged before the ASX market announcements office closes on the business day the report is due. If they fail to do so, trading in its securities will be suspended on the next trading day.

If an entity lodges after the market announcements office closes on the business day when the report is due, but before the market announcements office opens the next day (i.e. before the suspension is announced), the entity’s securities will be reinstated to quotation on the next trading day after the suspension is imposed. That is, the shares will be suspended from trading for at least one day.

The normal business hours for the ASX market announcements office is 8:30am to 7:30pm Sydney time (8:30pm during daylight saving time) on ASX trading days.

Example

Listed Manufacturing Entity has a 31 December year-end and is required to lodge its Appendix 4E preliminary final report with the ASX within two months after the end of the reporting period (so, by Saturday, 28 February 2026). Because Saturday, 28 February 2026 is not a business day, Listing Rule 19.5 requires the Appendix 4E to be lodged by the preceding business day (by Friday, 27 February 2026).

Listed Manufacturing Entity is still finalising its Appendix 4E on Friday, 27 February 2026. It lodges the report with the ASX after the market closes, at 9pm on Friday evening, 27 February 2026.

Applying the ASX’s enforcement rules:

  • Listed Manufacturing Entity’s securities will be suspended from trading on Monday, 2 March 2026
  • Listed Manufacturing Entity’s securities will be reinstated to quotation on Tuesday, 3 March 2026.

Need help?

Please contact our IFRS & Corporate Reporting experts if you need assistance with your listed entity reporting obligations.