REG-INSIGHT

ASIC CP 387 Series

📝 Completing the New Form

With the enhanced beneficial ownership disclosure rules following ASIC Consultation Paper 387 (CP 387) taking effect on December 4, 2026, preparing your compliance workflow for the unified Substantial Holding Notice (SHN) is critical. Completing the unified form requires entering data into four integrated sections that reflect total economic exposure.

🛠 Step-by-Step Guide: How to Complete the New SHN

Completing the unified form requires entering data into four integrated sections that reflect total economic exposure:

1. Holder & Target Entity Details

  • Entity Identification: State the targeted listed entity and the primary lodging entity (or control group).
  • Notice Nature: Select the trigger type—Initial, Change, or Ceasing—within the unified form structure.

2. Position Breakdown & Exposure Categories

Unlike legacy forms that focused primarily on voting power and direct physical equity, the SHN requires itemized disclosures across three core position types:
  • Direct & Physically Settled Relevant Interests: Shares directly held or physically deliverable derivatives.
  • Deemed Economic Interests (DEI): Cash-settled derivatives (such as total return swaps or CFDs) evaluated at full notional underlying value.
  • Offsetting Short Positions: Short exposures to determine net positioning where permitted by statutory calculation rules.

3. Details of Changes & Consideration

  • Transaction History: Detail the date, nature, and consideration given/received for every transaction that contributed to crossing the 5% initial mark or subsequent 1% movement.
  • Agreement Annexures: Attach relevant copies of non-standard derivative contracts or voting agreements that establish the underlying interest.

4. Associate Disclosures & Registers

  • Group & Associate Reporting: Map out linked corporate entities or concerted parties sharing control or economic interests.
  • Register Integration: Ensure entries reconcile with your internal Register of Relevant Interests (RORI).

🔑 Best Practices for a Smooth Transition

  • 📊 Update Surveillance Engine Mappings: Re-configure automated monitoring systems so position tracking aggregates direct equity, physical derivatives, and cash-settled DEI into a single reporting output.

  • 🕒 Mind the 2-Business-Day Window: Consolidating forms does not alter statutory deadlines. The clock begins as soon as aggregate exposure crosses a threshold.
  • 📁 Standardize Document Templates early: Begin populating data fields using the new SHN layout during the transition period to avoid last-minute lodgement errors before the June 2027 cut-off.

There’s a simpler way. Contact us to find out how you can automate form filling.

About:

Artius Global:

Artius Global is a Regtech that is Simplifying Regulatory Disclosures. Our proven solutions are by practitioners for practitioners. Our Shareholding Disclosure solution is a complete automated end-to-end solution with form filling. It overcomes the complex and onerous process of complying with shareholding disclosure with ease. The solution aggregates, monitors, and generates disclosure forms covering the regimes of Substantial Shareholding, Short Selling, Sensitive Industries, and Issuer Limits across 100+ capital markets to meet mandatory regulatory requirements for financial institutions. For more information, visit ArtiusGlobal.com or request a demo.

This website uses cookies to ensure you get the best experience on our website.