Consultation Paper 387: Enhanced beneficial ownership disclosure: proposed legislative instrument, form and guidance: March 2026
Submission Date: 21 April 2026
These are the submissions of the Corporations Committee of the Business Law Section of the Law Council of Australia in response to ASIC’s release of Consultation Paper 387 (CP 387), draft ASIC Corporations (Listed Entities Enhanced Beneficial Ownership) Instrument and draft Substantial Shareholding Notice.
Introductory comments
The Committee is supportive of the initiatives outlined in CP 387 and commend the work undertaken by ASIC to advance the efficient introduction and operation of the Treasury Laws Amendment (Strengthening Financial System and other Measures) Act 2025 and ease transitioning to the new disclosure regime.
It is imperative that, in view of the changed practices concerning listed entity beneficial ownership disclosure that have existed for decades, market participants and their advisers have sufficient time to adapt to the new procedures. The Committee makes some further timing submissions below.
Instead of adopting a submission format that follows the list of proposals and questions in CP 387, our submission is grouped by the key issues that we believe should be addressed further in order of our assessment of their policy significance. The Schedule to our submission then addresses our response to each of the questions raised in CP 387 by reference to our primary submissions.
Last Updated on 22/04/2026
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