Overview
On 4 December 2026, Australia's major shareholding disclosure rules will expand significantly.
This article explains the changes to the Australian regime, the key properties you must populate, and the necessary aggregation configuration steps to prepare your account before the new rules go live.
What to Know Before the Change
The regulatory scope expands across three main areas.
More In-Scope Securities
Cash-settled derivatives were previously excluded; now included and treated as deemed economic interests.
Physically-settleable derivatives are now split into:
relatable interests (with identifiable counterparty interests)
non-relatable deemed economic interests (without identifiable counterparty interests).
Offsetting short positions, which is a new category that requires separate tracking.
New Disclosure Triggers
A movement of 1% or more in any of the five derivative or short position categories now triggers a disclosure obligation. This applies in addition to the original 5% threshold and 1% change disclosures.
Broader Issuer Scope
Foreign issuers whose securities (including ADRs/CDIs) are listed on Australian financial markets now fall under the regime.
Because of these changes, we've created ten new rules and updated our existing Statutory rule.
We’ll use 11 rules working together to monitor each category and flag disclosure obligations. It’s essential that clients approve all 11 rules, and all versions of those rules, before 3 December 2026. Some of the V1 versions of those rules are designed to run only on 3 December 2026 to set an anchor point for all derivative buckets.
Key Properties
We’ve created two new properties for use in the Australian rules, and added an existing one to the mix. Understand what they are and how to populate them.
IsRelatableDerivativeAU
A new asset-level property that categorises physically settleable derivatives based on whether the counterparty has an identifiable interest in the underlying security.
Why It Matters
Under the new regime, not all derivatives are treated the same way.
Cash-settled derivatives: Always treated as deemed economic interests (no IsRelatableDerivativeAU property needed).
Physically-settleable derivatives: Can be either relatable or non-relatable, depending on the counterparty's holdings.
This distinction affects which rules monitor changes in your position and how those changes are reported.
How to Populate
For cash-settled derivatives, no action is needed.
For physically-settleable derivatives, populate IsRelatableDerivativeAU for each position.
True means the counterparty has an identifiable interest in the underlying securities.
False means the counterparty has no identifiable interest.
Example
Situation | IsRelatableDerivativeAU |
You hold a call option on XYZ Ltd shares with Bank A as counterparty. Bank A also holds shares in XYZ Ltd. | True |
You hold a call option on ABC Ltd shares with Bank B as counterparty. Bank B has no holdings in ABC Ltd. | False |
What Happens If Missing
You'll receive Missing Data warnings for physically-settleable derivatives. Those positions won't be monitored by these rules, and you risk incomplete disclosure.
IsListedIssuerAU
A new issuer-level property that flags foreign issuers whose securities are listed (or could be) on Australian financial markets.
Why It Matters
Securities listed directly on Australian exchanges are automatically in scope.
However, some foreign issuers are only present in Australia via depositary receipts (CHESS Depositary Interests/CDIs).
This property is an optional second pathway to bring those issuers into scope.
How to Populate
Set IsListedIssuerAU = "true" for any foreign issuer whose DRs/CDIs are listed (or could be listed) on Australian markets.
What Happens If Missing
This will not cause missing data warnings. However, if not populated, you forfeit an alternative way to include that foreign issuer.
Please note that any DRs/CDIs that are actually listed on Australian markets will still be captured automatically.
You only miss coverage if the issuer is not currently listed via DRs on Australian markets.
TotalVotingRightsInTreasury
This value is used for regulations that require a calculation of total voting rights, including treasury shares.
Why It Matters
The previous rule didn’t require this property, as treasury shares are not a feature of Australian law.
However, now that foreign issuers are potentially in scope, treasury shares may be relevant.
How to Populate
If this data can not be sourced, please set the value to zero.
What Happens If Missing
You’ll receive Missing Data warnings. Those positions won't be monitored by these rules, and you risk incomplete disclosure.
Changes to Aggregation
The Australian regime defines both parent and child companies and associates, and it appears that all associates are deemed to have the same interests.
This also aligns with A.4.9(d) on intra-group deemed economic interests. Therefore, the rules will run at the Top Entity and Portfolio aggregation level, rather than the AllEntities level.
If you have any specific aggregation set-ups such as Disaggregation, ExcludedRuleCodes relating to Australian rules, or AggregationLevelWorkaround, please contact your CSM.
Actions to Take Before the Change
To recap, these are the recommended actions before the rules go live.
Step | Action | Required? |
1 | Review the Key Properties section above and populate (or set default overrides) as needed. | Recommended |
2 | Review your aggregation configuration as explained above. | Recommended |
3 | Approve all versions of all rules once released. | Mandatory |
4 | Test in a staging environment. | Highly Recommended |
When testing, please be aware of the following:
You must approve all versions of all the rules.
You’ll need to use test files dated 3 December 2026 and 4 December 2026 at minimum.
These rules do not include Room-in-a-Name or Pre-Trade functionality at this time.
A note on staging environments: Without testing in a staging environment first, any missing properties or configuration issues will surface in production, potentially delaying or complicating your first disclosures under the new regime.
If you're interested in a staging environment, please reach out to your CSM or Account Manager.