On 16 May 2025, the Australian Securities Exchange (ASX) announced an update to ASX Guidance Note 1 Applying for Admission – ASX Listings (GN1), which took effect from 30 May 2025.
GN1 provides detailed guidance to entities seeking admission to the official list of the ASX by outlining the eligibility criteria, application process and ongoing obligations for listed entities. The ASX’s amendments represent the first revision of GN1 since 2019 and introduce changes aimed to provide greater transparency to early-stage technology, biotechnology and medical technology listing applicants, as well as incorporating existing market practice into the guidance and streamlining the admission process.
This insight provides an overview of the key amendments, with clearer guidance on when ASX will let you use its 'fast track' procedure, new guidance regarding the factors the ASX will consider when making listing decisions and a summary of other noteworthy changes.
In general, the updates reflect ASX’s current practices but having them publicly stated is helpful. Please contact a member of the G+T team should you have any questions.
Changes to the fast track process
Under the standard listing process, ASX generally commences its review of a listing application once the final prospectus or product disclosure statement (PDS) has been lodged with the Australian Securities and Investments Commission (ASIC). This process typically takes up to six weeks before a listing decision is made, and an applicant’s securities are quoted and begin trading on ASX.
The fast track process aims to reduce the period between an entity lodging its listing application and final prospectus with the ASX and ASIC, and the commencement of trading on ASX – aiming for a turnaround of approximately two weeks. ASX facilitates this by undertaking an expedited review of an applicant’s listing application based on the pathfinder (or draft) prospectus or PDS. An accelerated listing process is important as it limits the entity’s exposure to potential adverse market movements and reduces the period in which institutional investors who pre-commit to securities are 'on risk' between the completion of the bookbuild and the commencement of trading.
The revised GN1 clarifies the criteria that entities must meet to be eligible for the fast track process. Crucially, use of the fast track remains solely at ASX’s discretion – so early engagement is essential. There’s no point applying unless your market capitalisation on listing is at least $100 million or if ASX mandatory escrow will apply to your listing (i.e. assets test entity without an acceptable track record of revenue or profitability). These criteria are designed to ensure that only larger, more established entities can access the fast-track process.
Additionally, the pathfinder prospectus or PDS, together with any other draft documents (eg the ASX information form and checklist and accompanying materials, such as the corporate governance statement and securities trading policy), must be provided as "near final drafts". The ASX allows for the omission of offer metrics and the resulting capital structure from these drafts. If the ASX determine that the drafts are not sufficiently final, it may reject the submission and require the applicant to follow the standard, non-fast track admission process. This ensures that the fast track remains a streamlined pathway, not burdened by premature or incomplete applications.
‘Appropriate structure and operations’
ASX may refuse an applicant’s admission to the official list where it does not have a structure and operations that are appropriate for a listed entity, as set out in Condition 1 of Listing Rule 1.1. In the updates to GN1, ASX has urged entities which are incorporated overseas or which have significant businesses that are based overseas to engage at an early stage with ASX. This is not to suggest that this is a barrier – only that earlier engagement is sound.
ASX states that an applicant’s structure and operations will not likely be appropriate where:
The business is in its early stages and, in ASX’s view, has not developed to a point where listing is appropriate; or
The applicant is not an investment entity and has a non-operating or minority interest in assets or businesses that form a significant part of its listing proposition.
The updated GN1 provides targeted guidance on the suitability of early-stage technology applicants for admission. ASX will weigh both positive and negative factors when assessing whether the business is sufficiently developed for admission. These factors are outlined below.
Issue | Positive factors | Negative factors | |
Background of the entity | The business has been developed and grown by its promoters over a period of time. | The business was recently acquired by its promoters and there is no continuity of key personnel. | |
Level of development | Material cash has been spent over several years developing the business. | There has been little, or no cash spent on development. | |
Revenue and commercialisation | There is a market for the product and commercialisation opportunities, as evidenced by:
| No revenue or binding agreements to generate revenue. | |
Ownership of intellectual property | Intellectual property rights granted or applied for in each relevant jurisdiction and target market. | No intellectual property rights granted or applied for in each relevant jurisdiction and target market. | |
Investment history |
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For early-stage biotechnology and medical technology applicants, ASX will consider similar factors, with added focus on whether business holds key licences or government approvals it needs to operate. If the applicant is not generating revenue, ASX will be particularly focused on the status of any planned or required clinical trials. If clinical trials are not required, ASX will need clear evidence the relevant statutory authorities do not require clinical trials.
For all early-stage companies, ASX expects a clear path to commercialisation and a defined plan to use the funds raised through the listing to advance the business. ASX has confirmed that decisions on whether an applicant’s business is at too early-stage of development, will be made on a case-by-case basis and, notwithstanding the factors identified above, listing remains at ASX’s absolute discretion.
Guidance on listing eligibility
ASX has provided further guidance on the factors it considers when assessing listing eligibility, including examples of when it may refuse admission. These include where:
The applicant is established or has its main business operations in, or its controlling shareholders or a majority of its directors are resident in:
An emerging or developing market where ASX has concerns about the maturity and effectiveness of the legal, regulatory and judicial systems or standards of corporate governance in that market;
A jurisdiction associated with a heightened risk of corruption, organised crime, international fraud or money laundering; or
A jurisdiction experiencing war or major civil unrest.
An officer, employee or adviser of the entity has given, or has authorised or permitted the giving of false or misleading information to ASX in connection with the listing application;
An adviser involved in the application (or its representatives and its or their associates) are receiving fees and benefits from their involvement in the application and related transactions that are disproportionately high in comparison to the funds being raised;
The applicant has not engaged an experienced broker or financial adviser in connection with the offer and has not provided ASX with a credible plan for raising funds from investors sufficient to meet the minimum subscription, minimum free float and minimum spread requirements imposed by ASX; and
Another exchange has rejected or refused to accept an application by the entity for admission to the official list of that exchange.
Additional changes
The updated GN1 also includes general amendments and tidy-ups to align with ASX’s current practices and policy. These changes are intended to clarify, strengthen and modernise the admission process.
Timing for commencement of trading
ASX Listing Compliance will coordinate with the ASX Operations team to determine the commencement date for trading of an applicant’s securities. This will generally be three business days after it has completed its review and confirmed that the listing conditions have been satisfied. Whilst previous GN1 did not specify a review period, the new approach may imply a slightly longer timeline – particularly for IPOs not proceeding under the fast track process.
Updated financial information
If a reporting deadline passes after an entity lodges its application for admission but before it is admitted, ASX may require an updated, reviewed pro-forma statement of financial position for the relevant reporting period as a condition of admission. This must be released as a pre-quotation disclosure to ensure that investors have access to the most current financial information.
Waiver of working capital requirements under the assets test
ASX has clarified that it will generally not grant a waiver of the $1.5 million minimum working capital requirement for entities seeking admission under the assets test.
Disclosure of bookbuild information
ASX has confirmed that the requirement to disclose bookbuild information does not apply where an applicant has completed a front-end bookbuild before lodging its prospectus or PDS and listing application.