Checklist · Capital Markets & Securities — ECM/DCM and Disclosure

Substantial holding notice preparation checklist (Corporations Act s 671B)

A checklist for preparing a substantial holding notice: which event triggers it, tracing relevant interests and associates, working the 1% movement against the last notice, the 2 business day deadline (or 9.30 am next trading day in a bid period), contents and the agreements that must accompany it.

Kind
Checklist. Steps or checks to work through and tick off.
Where it applies
Australia
AI use
Yellow AI can help in set ways. A lawyer checks specific points before use.
Law stated as at
18 October 2026
Status
Maintained. Checked on 18 October 2026 against the 3 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use whenever a client (fund, corporate or individual investor) acquires or disposes of interests in a listed company or listed scheme near or above the substantial holding threshold, enters a relevant agreement, makes a takeover bid, or changes its associates. Start as soon as the client becomes aware of the triggering information.

How AI may be used

AI may build the holdings and movement table from custody and trade records and draft the notice data; a lawyer decides the relevant interests, the associates and whether a notice is triggered, and checks the figures before lodgement.

AI may

  • Build a table of holdings by entity, custodian and account from the records supplied, with dates
  • Calculate the voting percentage and the movement since the last notice using the total votes from the latest issuer data
  • List the agreements that may have contributed to the change, for the lawyer to assess

AI must not

  • Must not decide who has a relevant interest, who is an associate or whether an agreement is a relevant agreement
  • Must not use a total votes figure that has not been checked against the issuer's latest ASX announcements
  • Must not lodge the notice

The lawyer checks

  • Relevant interests traced through the group (including control, power to vote or dispose, and s 671B(7) extensions) and associates identified
  • Trigger and awareness date identified, and the deadline calculated from it
  • Percentage and movement correct against the issuer's current total votes and the last notice lodged
  • Accompanying documents included unless the transaction took place on market, and copies endorsed as true copies

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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