Australia’s Substantial Shareholding Reforms

This is an excerpt from our 5 February 2026 webinar on Australia's Substantial Shareholding Reforms. After discussing the need for reform to the current framework, we look at what the reforms will bring. To request the full webinar recording, please complete the form provided.

The Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Act 2025 will substantially shift Australia’s shareholding landscape during 2026.

Among a broader package aimed at improving market transparency and regulatory oversight, this introduces significant reforms to beneficial ownership disclosure with direct implications for equity derivatives and expanded issuer scope. Australia is shifting to a more expansive disclosure framework that captures economic exposure acquired via derivatives in addition to traditional shareholdings, bringing the regime closer to leading international transparency standards.

In this webinar, Rebecca Clayton (aosphere) is joined by Dan Harris (A&O Shearman) to examine how these reforms will reshape shareholding disclosure calculations and what this means for investors.

The discussion explores the major reforms, focusing on:

•  the current rules in Australia -complex and multi-layered disclosure rules

•  the coming reforms:

  • transformative changes to the derivatives disclosure landscape

  • a wider scope of issuer triggers – no longer a domestic capture

•  practicalities

  • timing – what to expect and watch out for

  • detailed disclosure data required to be revealed through filings

  • additional detail on off-setting short positions

  • internal preparations and tips

  • calculation parameters – hotspots and pitfalls

What this means for investors

Disclose ALL economic exposure
Including cash-settled, physically settled, and other derivative interests.

Aggregate physical and derivative holdings
As new combined reporting categories.

Disclose interests in foreign-listed companies
If listed on Australian financial markets.

Update internal compliance systems
Calculations and forms will significantly change.

Critical calculation detail is still currently outstanding and investors will want the complete picture before they set about transforming their rules. Detailed operational settings will need to be finalised through subordinate legislation and regulator guidance. Rulefinder Shareholding Disclosure will continue to track the progression of these reforms and will inform subscribers accordingly, including publication of our detailed memorandum and on-screen report once the full rules set is available.