ASIC’s Report 830: reportable situations and substantial holding notices — the key watch items for AFS licensees and fund managers

ASIC’s Regulatory simplification progress report (REP 830) is mainly a progress update on simplification work already underway, but it contains two developments that AFS licensees and fund managers should watch closely: a clear signal of support for broader reportable situations reform, and active consultation on simplifying the substantial holding notice regime.

The report also touches on platforms relief consolidation, financial reporting and audit instruments, an imminent financial advice roadmap, private credit compliance expectations, a faster ASX IPO process, and data collection burden reduction. Those are noted briefly below, but the reportable situations and substantial holding developments are the items most likely to have near-term practical significance for AFS licensees and fund managers.

1. Reportable situations: ASIC signals support for broader reform

This is the most commercially significant development in the report for AFS licensees.

ASIC records that a large proportion of submissions on ASIC’s Report 813 expressed frustration with the current reportable situations regime. Stakeholders told ASIC that the framework is overly burdensome, requiring firms to spend significant time and resources identifying and reporting minor or technical breaches that provide limited, if any, consumer benefit.  This is certainly our experience.

ASIC has already made some incremental changes. In June 2025, it extended the investigation reporting threshold for AFS and credit licensees from 30 days to 60 days, and exempted industry from reporting certain breaches of the misleading and deceptive conduct provisions. To be clear, the exemption is from the reporting obligation only — the underlying provisions still apply.

The more significant point in REP 830 is what ASIC says about law reform. The Council of Financial Regulators’ review of small and medium-sized banks recommended removing small banks from the requirement to automatically report certain breaches, and suggested the Australian Government consider extending that approach to all other licensees. ASIC expressly says it supports this as a simple and uniform approach.

This matters for AFS licensees for two reasons. First, ASIC’s public support for extension of any reform beyond the banking sector is a meaningful signal — it is not a position ASIC was required to take. Second, the framing of reform as a “simple and uniform approach” suggests ASIC would favour a clean, across-the-board change rather than a piecemeal one.

The law has not changed. Any reform will require government action and likely legislation. But the direction of travel is clearer than it has been, and AFS licensees with significant breach reporting obligations should monitor this closely.

What to do now: it is worth reviewing your current reportable situations framework in light of the existing relief already in place — particularly the extended 60-day investigation threshold and the misleading and deceptive conduct exemption — if you have not already done so. These changes are in force now, regardless of what broader reform may follow.

2. Substantial holding notices: a single digital form may be on the way

The second development of direct operational relevance is ASIC’s active consultation on the substantial holding notice regime.

Under the enhanced beneficial ownership regime, ASIC has a new power to approve the manner and form of substantial holding notices. ASIC is now consulting — through Consultation Paper 387 — on proposals to replace the three existing prescribed forms (Form 603, Form 604 and Form 605) with a single simplified notice. ASIC is also consulting on a web-based substantial holding notice and a digital format for submitting substantial holder information.

This is directly relevant to fund managers with listed equities strategies. Substantial holding notices are operationally sensitive and time-critical. The current three-form structure creates duplication and can be administratively cumbersome, particularly for managers running multiple funds or dealing with fast-moving positions. A single digital notice, if well-designed, could meaningfully reduce that burden.

The consultation is active now. If this reform matters to your operations, the time to engage is during the consultation process — the design of the digital notice and any standardisation requirements will be shaped by what stakeholders say at this stage.

What to do now: review CP 387 and consider whether to make a submission. Pay particular attention to whether the proposed single notice and digital format will work operationally for your specific disclosure workflows, including any issues around timing, agent authorisation, or multi-fund aggregation.

Other developments in REP 830

The report also flags the following, which are worth noting but are at an earlier stage or of narrower application:

• Platforms instrument — ASIC will make a new simplified instrument consolidating the two existing IDPS instruments, with updated guidance to follow.
• Financial reporting and audit relief — ASIC will proceed with two separate consolidated instruments (one for financial reporting, one for audit), with further consultation on simplification to come.
• Financial advice roadmap — ASIC expects to publish updated roadmaps for financial advice providers by end of June 2026, now only weeks away.
• Private credit — ASIC issued a catalogue of key legal obligations for private credit funds in December 2025. Fund managers in this sector should treat it as a signal of ASIC’s compliance expectations.
• IPO timetable — A faster ASX IPO listing process is now in a two-year trial, aimed at reducing deal execution risk and providing greater deal certainty for capital markets transactions.
• Data collection — ASIC and APRA are working on reducing duplicated data requests, though this remains at an early, high-level stage.
• ASIC portal changes — The Register of Relevant Providers and the Authorised Representative Register will migrate to the ASIC Regulatory Portal, with pre-filling and reduced duplication across transactions.

Should you be doing anything now?

REP 830 is a progress report — but it contains two live issues that warrant attention now, not when reform eventually lands.

On reportable situations, the incremental relief already in force is being underutilised by many AFS licensees. The extended 60-day investigation threshold and the misleading and deceptive conduct exemption are available now and may already reduce your reporting burden materially. If your breach reporting framework has not been reviewed since these changes took effect, it should be. And if broader reform proceeds along the lines ASIC has signalled, firms that understand their current position will be better placed to adapt quickly.

On substantial holding notices, the consultation window is open. The design decisions made during CP 387 will shape how the new single notice regime works in practice — including timing, agent authorisation and multi-fund aggregation. Fund managers with listed equities strategies have a direct interest in how those details are resolved, and a submission is the only way to influence them.

If you would like to discuss what the existing reportable situations relief means for your compliance framework, whether your breach reporting processes are appropriately calibrated, or how to engage with the CP 387 consultation, please get in touch with our team. These are practical issues with near-term implications, and early attention is likely to be more efficient than reactive review once reform is finalised.