---
title: "Whistleblower policy for a company under Corporations Act section 1317AI"
url: "https://ailawframework.com/precedents/whistleblowing-and-public-interest-disclosures/whistleblower-policy-s1317ai"
type: "precedent"
site: "AI Law Framework"
id: "a67-whistleblower-policy-s1317ai"
area_id: "A67"
kind: "policy"
ai_level: "yellow"
version: 1
task_ids: ["A67-SB20261022-2", "A67-SB20261022-12"]
law_stated_as_at: "2026-10-22"
---

# Whistleblower policy for a company under Corporations Act section 1317AI

> A policy skeleton for a company that must set out each matter in Corporations Act s 1317AI(5), with the timing rules for a public company, a large proprietary company and a proprietary trustee of a registrable…

Canonical page: https://ailawframework.com/precedents/whistleblowing-and-public-interest-disclosures/whistleblower-policy-s1317ai  
Law stated as at: 2026-10-22

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

A policy skeleton for a company that must set out each matter in Corporations Act s 1317AI(5), with the timing rules for a public company, a large proprietary company and a proprietary trustee of a registrable superannuation entity.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [Whistleblowing & Public Interest Disclosures](https://ailawframework.com/precedents/whistleblowing-and-public-interest-disclosures.md)
- Jurisdictions: Commonwealth
- AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 6 authorities it cites, for Commonwealth.

## When to use it

Use when a public company, a proprietary company that has been a large proprietary company, or a proprietary company that is the trustee of a registrable superannuation entity is adopting or replacing its whistleblower policy. The lawyer confirms the company is in one of those classes before the policy is adopted.

## Used for these tasks

- [Work out which companies must have a whistleblower policy, and from which day](https://ailawframework.com/practice/whistleblowing-and-public-interest-disclosures.md#A67-SB20261022-2)
- [Issue the eligible-recipient card from the approved whistleblower policy](https://ailawframework.com/practice/whistleblowing-and-public-interest-disclosures/issue-the-eligible-recipient-card-from-the-approved-whistleblower-policy.md)

## How AI may be used

AI may fill the section headings from s 1317AI(5) and the company's own process notes. The lawyer checks that the company is obliged to have the policy and adopts the wording.

**AI may:**

- Place each matter in s 1317AI(5)(a) to (g) under its own heading
- Insert the company's nominated recipients, support steps and investigation steps from notes the lawyer has approved
- List the availability method the company will use for officers and employees

**AI must not:**

- Must not decide whether the company is a public company, a large proprietary company or a registrable-superannuation trustee
- Must not copy paragraphs from Regulatory Guide 270; the guide PDF was not the source of this skeleton
- Must not state that a group policy satisfies each subsidiary, or that the Act requires publication on a website

**The lawyer checks:**

- The company is within s 1317AI(1), (2) or (3), and the start day matches that subsection
- For a proprietary company, the large-proprietary test uses the amounts and employee number prescribed by reg 1.0.02B
- Each matter in s 1317AI(5) is covered, including any matter the regulations prescribe
- The policy is made available to the company's officers and employees
- Tax whistleblower content is checked against Taxation Administration Act Part IVD and the ATO page, not against an unread guide

## Authorities

- [Corporations Act 2001 (Cth) s 1317AI](https://classic.austlii.edu.au/au/legis/cth/consol_act/ca2001172/s1317ai.html)
- [Corporations Act 2001 (Cth) s 45A](https://classic.austlii.edu.au/au/legis/cth/consol_act/ca2001172/s45a.html)
- [Corporations Regulations 2001 (Cth) reg 1.0.02B](https://classic.austlii.edu.au/au/legis/cth/consol_reg/cr2001281/s1.0.02b.html)
- [ASIC, Whistleblowing](https://www.asic.gov.au/about-asic/asic-investigations-and-enforcement/whistleblowing)
- [ASIC Regulatory Guide 270 landing page (issued 13 November 2019)](https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-270-whistleblower-policies)
- [ATO, Tax whistleblowers (updated 2 October 2026, QC58244)](https://www.ato.gov.au/about-ato/whistleblowers)

## 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/whistleblowing-and-public-interest-disclosures/whistleblower-policy-s1317ai 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.*