---
title: "Continuous disclosure policy and disclosure committee charter"
url: "https://ailawframework.com/precedents/capital-markets-and-securities-ecm-dcm-and-disclosure/continuous-disclosure-policy"
type: "precedent"
site: "AI Law Framework"
id: "a4-continuous-disclosure-policy"
area_id: "A4"
kind: "policy"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# Continuous disclosure policy and disclosure committee charter

> Board-approved continuous disclosure policy for an ASX-listed entity, with a disclosure committee charter and a disclosure decision record.…

Canonical page: https://ailawframework.com/precedents/capital-markets-and-securities-ecm-dcm-and-disclosure/continuous-disclosure-policy  
Law stated as at: 2026-10-17

Site index for agents: https://ailawframework.com/llms.txt

Board-approved continuous disclosure policy for an ASX-listed entity, with a disclosure committee charter and a disclosure decision record. It covers LR 3.1 to 3.1B, ss 674 and 674A, leaks, analyst briefings and use of AI tools.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [Capital Markets & Securities — ECM/DCM and Disclosure](https://ailawframework.com/precedents/capital-markets-and-securities-ecm-dcm-and-disclosure.md)
- Jurisdictions: Australia, New Zealand, United Kingdom (England and Wales)
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 7 authorities it cites, for Australia, New Zealand and United Kingdom (England and Wales).

## When to use it

Use when a listed entity adopts or refreshes its continuous disclosure policy, or prepares to list. Adapt for entities listed on other markets. Not a substitute for advice on whether particular information must be disclosed.

## How AI may be used

AI may help monitor media and draft flags or announcement wording from a lawyer’s facts brief. Materiality and disclosure decisions are made and approved by people.

**AI may:**

- Monitor news, social media and trading data and flag items for the Disclosure Officer
- Assemble a who-knew-what-when chronology from documents for the disclosure decision record
- Check a draft announcement for consistency with earlier announcements and guidance

**AI must not:**

- Must not decide whether information is material or whether the LR 3.1A carve-out applies
- Must not originate statements about future matters such as forecasts or guidance
- Must not process unannounced price-sensitive information in a tool outside the entity’s approved environment

**The lawyer checks:**

- Policy reflects current Listing Rules, Guidance Note 8 and the entity’s actual decision-makers
- Escalation routes work outside business hours and during leaks
- AI-use section matches the entity’s approved tools and information barriers

## Authorities

- [Corporations Act 2001 (Cth) ss 674, 674A, 677 (continuous disclosure; material effect)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) s 1041H (misleading or deceptive conduct)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [ASX Listing Rules 3.1, 3.1A, 3.1B](https://www.asx.com.au/content/dam/asx/rules-guidance-notes-waivers/asx-listing-rules/rules/Chapter03.pdf)
- [ASX Guidance Note 8: Continuous Disclosure: Listing Rules 3.1 – 3.1B](https://www.asx.com.au/content/dam/asx/rules-guidance-notes-waivers/asx-listing-rules/guidance-notes/gn08-continuous-disclosure.pdf)
- [ASX Listing Rule 17.1 (trading halts)](https://www.asx.com.au/content/dam/asx/rules-guidance-notes-waivers/asx-listing-rules/rules/Chapter17.pdf)
- [Financial Markets Conduct Act 2013 (NZ) s 270](https://www.legislation.govt.nz/act/public/2013/69/en/latest/)
- [Regulation (EU) No 596/2014 (UK Market Abuse Regulation, as it forms part of UK law) art 17](https://www.legislation.gov.uk/eur/2014/596/article/17)

## Official form

[Official form](https://www.asx.com.au/about/regulation/rules-guidance-notes-and-waivers/asx-listing-rules-guidance-notes-and-waivers)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/capital-markets-and-securities-ecm-dcm-and-disclosure/continuous-disclosure-policy and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*