---
title: "Securities trading policy (closed periods, clearance, exceptions)"
url: "https://ailawframework.com/precedents/capital-markets-and-securities-ecm-dcm-and-disclosure/securities-trading-policy"
type: "precedent"
site: "AI Law Framework"
id: "a4-securities-trading-policy"
area_id: "A4"
kind: "policy"
ai_level: "green"
version: 1
law_stated_as_at: "2026-10-17"
---

# Securities trading policy (closed periods, clearance, exceptions)

> ASX-compliant securities trading policy covering every matter Listing Rule 12.12 requires, plus insider trading, hedging, margin loans, director notifications and trading plans, with a clearance request form.

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

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

## 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
- AI level: Green. AI can do most of the drafting. A lawyer still reviews the result.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 5 authorities it cites, for Australia.

## When to use it

Use when an ASX-listed entity adopts or updates its trading policy, including before listing. Give the adopted policy to ASX for release, and give material changes within five business days. Not a substitute for advice on a particular proposed trade.

## How AI may be used

AI may adapt this reviewed base policy to the company’s calendar and structure. Clearance decisions remain with the designated people.

**AI may:**

- Populate closed periods from the company’s reporting calendar
- Draft a plain-language summary and FAQ for employees
- Check the adapted policy covers each Listing Rule 12.12 item

**AI must not:**

- Must not give or refuse clearance to trade
- Must not assess whether a person holds inside information
- Must not process unannounced information when answering trading queries

**The lawyer checks:**

- Closed periods and exceptions match the company’s reporting cycle and plans
- Clearance officers and escalation are named and workable
- Policy lodged with ASX and changes released within five business days

## Authorities

- [ASX Listing Rules 12.9–12.12 (trading policy)](https://www.asx.com.au/content/dam/asx/rules-guidance-notes-waivers/asx-listing-rules/rules/Chapter12.pdf)
- [ASX Guidance Note 27: Trading Policies](https://www.asx.com.au/content/dam/asx/rules-guidance-notes-waivers/asx-listing-rules/guidance-notes/gn27-trading-policies.pdf)
- [Corporations Act 2001 (Cth) ss 1042A, 1042C, 1043A (insider trading)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) s 206J (no hedging of KMP remuneration)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) s 205G (director notification of interests)](https://www.legislation.gov.au/C2004A00818/latest/text)

## 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/securities-trading-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.*