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Transactions in Disclosure Form Requirements

2 December 2025

Overview

Several regulatory jurisdictions require you to disclose historical transactions either directly in their standard disclosure form or as an annexure to the standard form. To streamline this process, we provide tools to automate the disclosure of historical transactions.

It's important to note that the transaction file is for document generation purposes only, and omitting transaction information will NOT result in Missing Data exceptions.

However, utilising the Transactions in Disclosure functionality will minimise the manual work required for disclosure in jurisdictions that require transaction-level data and facilitate the successful document generation of your results.

How It Works

When you generate a disclosure form that requires transaction data, the system completes the following steps:

  1. Reviews rule coding and identifies the information required by the regulator (such as historical transactions for the previous 30, 45, or 90 days).

  2. Uses the AssetId provided in your transactions file to pull in corresponding data for that transaction and populate the form.

Providing Transaction Data

You can upload transaction data in a CSV file via the API endpoint or directly in the UI by navigating to Monitoring > Shareholding Disclosure > Other > Transactions. Once there, use the Import (.CSV) button to upload the appropriate file.

Our sample transaction file illustrates the file format and the fields required to pass validation. Please see the README for more information on the columns and the valid transaction types.

Important Notes

You cannot overwrite transactions by re-uploading them for previous NAV dates, as each transaction has a unique ID. You can only upload new transactions that have not been uploaded previously. Any re-uploading requires a new TransactionID to pass validation, resulting in double-counting.

To correct an erroneous transaction, cancel it by submitting an adjustment transaction. An adjustment transaction is the only method that allows you to re-use a TransactionID, but it must contain an equal and opposite value to the original transaction.

For example:
Transaction ID 1: Buy 200
Transaction ID 1: Adjustment -200

The following rules require you to upload historical transactions to generate disclosures correctly:

  • MajorAU-Statutory-Custodian

  • MajorAU-Statutory

  • MajorHK

  • MajorID

  • MajorJP

  • MajorKR

  • MajorKR_10

  • MajorPH_Form18A

  • MajorPH_Form23A

  • MajorPH_Form23B

  • MajorSG

  • MajorTH-S

  • MajorTH_246-2

  • MajorTH_Notification_Sheet

  • MajorTR-ENG

  • MajorTR

  • TakeOverBE

  • TakeOverCH

  • TakeoverFR-Dealings

  • TakeOverGB_8-3_Transactions

  • TakeOverHK_Transactions

  • TakeoverIE_8.3

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