ASX has released its first Listed Entity Supervision Report, bringing together detailed information about its supervisory and enforcement activities, current priorities and planned reviews for FY27. For listed entities and their advisers, the report provides a useful indication of where ASX is likely to direct its supervisory attention over the coming year.

The report reflects ASX’s stated objective of adopting a more proactive approach to supervision, focused on areas of greatest risk, and being more transparent in its oversight activities, with a particular focus on issues affecting market integrity and investor confidence.

The clearest theme emerging from the report is ASX’s continued transition towards a more proactive approach to supervision. Over the last two years, ASX has progressively reduced its involvement in reviewing announcements before release and has instead sought to place greater responsibility on listed entities and their advisers to ensure compliance with the Listing Rules. At the same time, ASX has indicated that it will devote more resources to identifying patterns of behaviour, monitoring market outcomes and taking enforcement action where it identifies conduct that may undermine market integrity or investor confidence.

The full Listed Entity Supervision Report can be accessed here.

Insights from recent supervisory activity

The report provides a useful snapshot of ASX’s supervisory workload. For the nine-month period from 1 July 2025 to 31 March 2026, ASX provided more than 2,500 advices to listed entities and advisers, investigated more than 2,000 matters involving approximately 2,600 Listing Rule issues and processed more than 300 waivers. During the same period, ASX also considered more than 700 reports of misconduct, with more than 90 resulting in further action being taken.

Most investigations were triggered by ASX’s own monitoring activities, including post-release reviews of announcements. Continuous disclosure issues, including price queries, aware letters and leak letters, accounted for a significant proportion of ASX’s investigative activity.

The report also notes that ASX frequently required entities to provide information, make corrective disclosures, release correspondence to the market, direct entities to make announcements to better inform the market or address disclosure concerns through private advice or warnings. Trading interruptions were imposed in more than 100 matters where ASX considered intervention necessary.

ASX’s evolving approach to disclosure supervision

One of the more significant themes emerging from the report is ASX’s intention to continue reducing its pre-release involvement in listed entity announcements.

ASX notes that, over the past 18 to 24 months, it has actively reduced the number and type of announcements referred to it prior to release. ASX considers that listed entities are responsible for ensuring their announcements comply with the Listing Rules and are accurate, complete and not misleading.

Instead, ASX intends to focus increasingly on ongoing patterns of behaviour and market outcomes after announcements are released. This is likely to result in less routine pre-release engagement with ASX, but greater post-release scrutiny of disclosure practices and market outcomes, particularly where ASX identifies recurring disclosure issues or concerning patterns of behaviour.

ASX has indicated that where significant disclosure concerns arise, it may utilise its recently introduced close review procedure rather than relying on ad hoc pre-release intervention.

Ramping and continuous disclosure remain key priorities

The report confirms that ASX’s focus on ramping will continue in FY27, although its approach is evolving.

Rather than concentrating on the wording of individual announcements, ASX intends to focus on patterns of conduct that may indicate announcements are being used to support capital raisings, maintain trading prices following raisings or induce speculative investor interest.

In practical terms, ASX has signalled that it will scrutinise factors such as the timing and frequency of announcements, disclosures released close to capital raisings, announcements that contain limited new information and recurring conduct that has previously attracted regulatory attention. ASX is also likely to continue focusing on whether entities are appropriately characterising announcements as price sensitive or non-price sensitive.

ASX has made clear that it expects disclosure practices to be supported by robust internal assessment and escalation procedures and that announcements should not be used to influence share price outcomes that are not supported by information concerning the entity that is complete, accurate and not misleading.

Targeted reviews planned for FY27

ASX’s proposed review program for FY27 provides a valuable roadmap for listed entities seeking to understand where supervisory attention is likely to be concentrated over the next 12 months.

Key areas of focus include continuous disclosure, ramping, placement capacity compliance, Chapter 10 transactions, private credit disclosure, foreign exempt entities, biotechnology disclosures and repeated Listing Rule breaches. Entities operating in these areas should expect increased supervisory attention and ensure their compliance frameworks are appropriately tailored to manage these risks.

ASX also intends to continue its focus on disclosure by mining entities, including annual mineral resources and ore reserves statements, and has identified a number of specific mining disclosure areas that it considers capable of causing significant market harm if handled improperly.

Key takeaways for listed entities

The report provides a clear indication that ASX intends to adopt a more proactive supervisory approach, with a stronger focus on enforcement and areas of greatest risk.

While listed entities may experience less pre-release engagement from ASX, they should not mistake this for reduced regulatory oversight. Rather, ASX is seeking to place greater responsibility on boards and management to ensure compliance, while directing its supervisory resources towards areas of heightened regulatory and market integrity risk.

Given ASX’s stated priorities, listed entities should ensure they have robust processes for continuous disclosure, shareholder approval requirements and governance compliance, particularly in areas identified by ASX for targeted review in FY27.

This article was written by David Naoum, Partner and Lachlan Pearce, Associate.