Who must comply with ASX continuous disclosure (Listing Rule 3.1)?

Listed entities must immediately disclose price-sensitive information to the market.

ASX Listing Rule 3.1 requires a listed entity, once it is or becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of its securities, to tell ASX that information immediately, through ASX's market announcements office. Section 677 of the Corporations Act explains when information is taken to have a material effect, and the rule works together with the statutory continuous disclosure provisions in sections 674 and 675. Listing Rule 3.1A carves out information only while all three limbs hold: it falls within one of five situations (disclosure would breach a law; an incomplete proposal or negotiation; supposition or insufficiently definite matters; information generated for internal management purposes; or a trade secret), it remains confidential, and a reasonable person would not expect it to be disclosed. Under Listing Rule 3.1B, if ASX considers there is or is likely to be a false market and asks for information to correct or prevent it, the entity must give that information immediately, even where 3.1A would otherwise apply.

Applies when the business has an ASX listing.

How the regulator frames it: Every entity admitted to the ASX official list, acting through its board and the officers responsible for market disclosure.

What triggers it: The entity becoming aware of information about it that a reasonable person would expect to have a material effect on the price or value of its securities (for example a material contract, earnings surprise or major transaction), loss of confidentiality over information previously withheld under 3.1A, or an ASX request to correct a false market.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Outcome across the 35 industries Rules Mate maps (35 of 35: no).

The answer is the same in every industry: no. Industry does not change who must comply.

Structure does not change the answer across all industries: for every structure the answer is "no".

Size does not change the answer across all industries: at every size band the answer is "no".

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

• Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires an ASX listing.

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

• The business is listed (or listing) on the ASX: it then applies (ASX-listed (or preparing to list)).

When due

Immediately on becoming aware of the information; immediately when ASX asks for information to correct or prevent a false market (Listing Rule 3.1B).

Frequency

When a triggering event occurs

Evidence to keep

Board-approved continuous disclosure policy; disclosure committee minutes and materiality assessments; log of information withheld in reliance on Listing Rule 3.1A with confidentiality controls; market announcements and their lodgement times; records of ASX queries and responses.

Status

Current

Priority

Critical

Maximum penalty: Breach of Listing Rule 3.1 is a breach of the ASX Listing Rules, which ASX enforces, and also engages the statutory continuous disclosure obligations in sections 674 and 675 of the Corporations Act, which ASIC enforces; penalty amounts are set by the Corporations Act.

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

If this obligation applies to you, so do these 5: the engine uses the same rule for each.

• Apply 'if not why not' against ASX Corporate Governance Council Principles &
• Two-strikes rule on listed-company remuneration report (s 250R)
• Maintain insider trading policy + share trading window (listed entities)
• Lodge a prospectus for offers requiring disclosure
• ASX-listed entity board independence + composition (CGC Principle 2)

Rules Mate tracks 1 published obligation tagged "continuous disclosure", 1 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated critical priority and carries criminal liability, and is triggered by events.

Regulated by Australian Securities Exchange (listing rules supervision) and Australian Securities and Investments Commission.

ASX: Operator of the principal Australian securities exchange. Listing Rules govern continuous disclosure, corporate governance, and capital raising for listed entities.

ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).

• Australian Securities Exchange (listing rules supervision)
• Australian Securities and Investments Commission

Corporations Act: The foundational federal Act for Australian corporate law.

• Corporations Act 2001

Free tools that help with this obligation:

• Compliance calendar builder