Who must maintain insider trading policy + share trading window (listed entities)?

ASX Listing Rule 12.12 requires written policy on directors + senior managers trading entity securities.

ASX Listing Rule 12.12 requires listed entities to publish a written share trading policy covering directors + key management personnel. Must specify trading windows, blackout periods around results announcements, requirements for clearance, and prohibition of trading on inside information (Corporations Act s 1043A).

Applies when the business has an ASX listing.

How the regulator frames it: ASX-listed entities + their KMP.

What triggers it: Being listed.

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

Continuous; trading windows enforced around price-sensitive announcements.

Frequency

Ongoing

Evidence to keep

Published policy; trading window register; clearance approvals.

Status

Current

Priority

Critical

Maximum penalty: Insider trading criminal up to 15 years prison + 3× benefit; civil to financial-services max.

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.

• Comply with ASX continuous disclosure (Listing Rule 3.1)
• Apply 'if not why not' against ASX Corporate Governance Council Principles &
• Two-strikes rule on listed-company remuneration report (s 250R)
• Lodge a prospectus for offers requiring disclosure
• ASX-listed entity board independence + composition (CGC Principle 2)

Rules Mate tracks 4 published obligations tagged "corporate governance", 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 an ongoing duty.

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

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

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

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

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

• Corporations Act 2001

Free tools that help with this obligation:

• Compliance calendar builder