On 26 June 2026, ASX Supervision released its first Listed Entity Supervision Report, consolidating the exchange's supervisory activities, enforcement outcomes and forward-looking focus areas. For listed companies and their advisers, ASX is moving to a more proactive, risk-based and transparent supervisory model.
The report is not a new rulebook, but it provides materially more detail on where ASX’s attention is directed and what it intends to focus on in the year ahead. Mining companies are particularly on notice: ASX has identified specific disclosure focus areas for the resources sector and signalled that companies engaging in problematic patterns of behaviour will face escalating enforcement action.
The supervisory shift: proactive, risk-based, pattern-focused
As the first major publication from the newly rebranded ASX Supervision team (formerly ASX Compliance), the report articulates a deliberate evolution in supervisory posture. The practical effect should be greater predictability about where ASX’s attention will fall.
A significant operational change is ASX's move away from routine pre-release review of announcements. ASX has concluded that intervening before release does not produce lasting compliance uplift and can foster a culture of dependence where entities expect ASX to catch their errors rather than get it right themselves. That said, ASX has flagged that it will still review draft announcements in limited circumstances. These include scoping studies submitted for advance review, announcements made while an entity is in a trading halt or suspension and any announcements referred to it by ASX’s Market Announcements Office. The practical effect is less handholding on individual announcements, but materially greater exposure to post-release enforcement action where a company's disclosure track record reveals a concerning pattern.
For boards and company secretaries, the message is straightforward: you own your disclosure. ASX will no longer be the safety net that catches deficient announcements before they reach the market. And where it identifies a pattern after the fact, the response will be formal, escalating and potentially public.
Continuous disclosure and ramping: the enforcement priority
Continuous disclosure remains ASX's core enforcement focus, with most of the more than 2,000 investigations in the nine months to 31 March 2026 falling in this area. The report’s language on ramping is notably stronger than previous guidance and the enforcement record supports the rhetoric: nine warning letters were issued for ramping alone. ASX is targeting companies that use disclosure practices to engineer share price outcomes, focusing on four key behaviours:
- timing announcements around capital raisings
- releasing announcements lacking substantive new information
- maintaining post-placement trading levels through promotional activity
- mischaracterising sensitivity.
ASX has signalled that it will now assess ramping as a course of conduct rather than debating the merits of individual announcements. The factors ASX will consider include the timing of announcements relative to capital raisings, the volume and frequency of announcements during periods of limited operational progress, whether announcements contain genuinely new information and whether the entity has previously been put on notice about its disclosure practices. That shift matters: it is considerably harder for a listed entity to address a pattern than a single borderline announcement.
Mining entities: eight specific disclosure focus areas
Looking ahead, ASX has identified eight specific areas of focus for disclosure by mining entities. These are:
- visual results which do not follow ASX guidance
- isolated assays which can mislead as to the program’s success
- historic and foreign results and estimates which do not follow Listing Rule 5 disclosure requirements
- first-time disclosure of metal equivalents which do not follow Joint Ore Reserves Committee (JORC) Code guidelines
- production targets, financial forecasts and non-qualifying estimates inconsistent with ASX guidance
- in-ground values not supported by fully compliant production targets
- independent geologist reports for IPOs
- initial disclosure of exploration targets, exploration results, resources and reserves and Table 1 in announcements which do not comply with Listing Rule 5 disclosure requirements.
ASX also intends to conduct a targeted review of annual mineral resources and ore reserves statements, alongside its ongoing focus on reserves and resources disclosure more broadly.
ASX has stated it will not actively look for non-compliance outside these focus areas in FY27, considering them to have higher potential for adverse market impacts. That is a useful signal for compliance planning: mining entities operating in these areas should expect closer scrutiny.
Earnings surprises: ASX steps back from targeted reviews
One area where ASX has taken a less interventionist posture is earnings surprises. ASX conducted targeted reviews of results releases in August 2023, 2024 and 2025, progressively raising the investigation threshold from a 5% to 10% share price movement on results day for S&P/ASX 200 entities.
ASX was generally satisfied with ASX 200 compliance and does not intend to undertake further targeted reviews in August 2026. It observed increasing pre-results earnings updates in each successive year.
That said, listed entities should not treat this as a relaxation of ASX’s expectations. ASX will still investigate on a case-by-case basis where a company materially misses its own guidance without warning the market beforehand, particularly where the share price impact is significant. Companies issuing vague or imprecise guidance that is not updated as circumstances change remain squarely in ASX's sights.
Targeted reviews on the horizon: Chapter 7 and Chapter 10
Beyond the identified focus areas, the report flags planned targeted reviews during FY27 in areas that are likely to have broad application:
- The placement capacity requirements in Chapter 7 of the Listing Rules (Listing Rules 7.1 and 7.1A).
- The rules around transactions with a person in a position of influence in Chapter 10 of the Listing Rules (Listing Rules 10.1, 10.11 and 10.14).
- Simultaneous disclosure by foreign exempt entities.
- An admissions-related review of private credit entities.
- A backward-looking review of entities with demonstrated patterns of repeated non-compliance.
- An investigative study of biotechnology and life science disclosure.
For companies that regularly raise capital through placements or engage in related party transactions, the Chapter 7 and Chapter 10 reviews are a prompt to stress-test internal processes now, before ASX does.
The Chapter 7 review is particularly timely: on 17 June 2026 ASX released a separate consultation proposing to narrow Listing Rule 7.2 Exceptions 6 and 7, which currently allow listed bidders to issue equity under a takeover or scheme without shareholder approval. Under the proposed amendments, an S&P/ASX 300 bidder would need shareholder approval before issuing 25% or more of its share capital in connection with a regulated transaction. The Consultation Paper and Exposure Draft also propose new requirements for voluntary delistings and changes to ASX Foreign Exempt Listing status. Submissions close on 29 July 2026, with the amendments proposed to take effect on 21 October 2026.
ASX is signalling it will look across an entity's compliance history as a whole. A one-off breach may be recharacterised as part of a pattern if subsequent issues emerge. That has real implications: resolving an issue informally today does not guarantee it will not be revisited as part of a broader conduct assessment tomorrow.
Enforcement outcomes and the close review procedure
The report provides detailed disclosure of ASX's enforcement activity. During the period, ASX:
- Requested information in relation to over 1,300 Listing Rule issues.
- Released correspondence to the market for over 500 Listing Rule issues.
- Directed companies to make announcements for over 700 Listing Rule issues.
- Provided private advices and warnings for over 650 Listing Rule issues.
- Interrupted trading for over 100 Listing Rule issues.
ASX has now issued three public censures under Listing Rule 18.8A and during 2025 and 2026 has required three entities to retain independent experts to review their policies and processes after identifying compliance concerns. A further seven entities were directed to undertake internal reviews.
ASX introduced a close review procedure in June 2025. Where ASX has serious concerns about an entity's willingness or ability to comply with disclosure obligations, it can place the entity under additional scrutiny for six months, publicly announced against the entity's ASX code with obvious reputational consequences. In practice, this signals that entities should avoid a track record of late, incomplete or reactive disclosure responses, rather than treating individual lapses as isolated events, since it is a pattern of non-compliance, not a single breach, that is likely to attract this level of scrutiny. No entities have yet been placed under the procedure, but it represents an important new tool in ASX's enforcement toolkit and boards should treat it as a material compliance risk if disclosure practices are not up to standard.
Other supervisory areas: cryptocurrency, stock promotion and committee composition
The report also addresses several other supervisory areas that listed entities should note.
On cryptocurrency treasury strategies, ASX engaged with the 12 listed entities it identified as holding or intending to hold cryptocurrency. The Listing Rule issues are broader than many appreciate, spanning continuous disclosure (Listing Rule 3.1), change in nature or scale (Listing Rule 11.1), ‘cash box’ entities (Listing Rule 12.3) and appropriateness for listing (Listing Rule 12.5). Cryptocurrency treasury is not simply a treasury decision; it can raise fundamental questions about whether activities have changed and whether the market is properly informed. Entities considering this path should engage ASX early.
Stock promotion services remain a live enforcement risk. ASX is focused on whether terms and costs are properly disclosed, whether material information is shared with promoters before market release and whether paid reports are released suspiciously close to placements. Price impact from stock promotion will be treated as an aggravating factor and may result in referral to the Australian Securities and Investments Commission. Entities engaging promoters should apply the same rigour as any market-facing disclosure.
On committee composition, the news is positive. ASX reviewed approximately 400 corporate governance statements across S&P/ASX 300 and All Ordinaries entities and found only four concerns about Listing Rule 12.7 audit committee compliance and none regarding Listing Rule 12.8 remuneration committees. Existing governance practices appear generally sound, though ASX expects non-compliance to be self-identified and rectified through a proper appointment process.
Practical steps for listed entities
Listed companies should take the following steps in response to the report:
- Review the report in full: the report is accessible on ASX's website and should be reviewed by company secretaries, general counsels and compliance teams.
- Assess internal processes against the planned reviews: companies in sectors flagged for targeted review (particularly mining, private credit, biotech and foreign exempt entities) should assess whether their existing disclosure and compliance processes are fit for purpose against the specific focus areas ASX has identified. Private credit entities should review their processes for meeting post-admission continuous disclosure obligations. Biotechnology and life sciences entities should review their processes for handling clinical and trial data held by third parties and managing disclosure timing around scientific conference presentations. Foreign exempt entities should review their processes to ensure information disclosed on their home exchange is released to ASX simultaneously.
- Mining entities – audit disclosure practices: for mining entities, this means approval and sign-off processes covering the eight identified focus areas, including visual results, isolated assays, historic and foreign results and estimates, metal equivalents disclosures, production targets and in-ground values. Practices that could be characterised as selectively disclosing positive results, relying on non-compliant foreign estimates, or releasing announcements without substantive new information should be addressed as a priority.
- Chapter 7 and Chapter 10 compliance: companies that regularly raise capital through placements or engage in transactions with persons in a position of influence should review internal processes to identify when the rules apply and test current compliance. ASX has signalled it will periodically test compliance.
- Review ramping risk: companies should assess whether their announcement practices, including the timing of releases, could be characterised as supporting a placement price, maintaining post-raising trading levels, or inducing speculative interest and consider them through that lens. ASX's focus is now on patterns of behaviour, not individual announcements, which means that a history of borderline announcements is more likely to attract enforcement attention than a single isolated disclosure.
- Engage proactively: where existing practices are uncertain or where a company is aware of a potential compliance gap, early engagement with ASX is likely to produce a better outcome than reactive engagement after a query or investigation.
The report does not change the rules. But it makes ASX's supervisory expectations and enforcement priorities materially more visible. For listed entities and their advisers, it should be treated as a practical compliance baseline against which future supervisory engagement will be measured.