REG-INSIGHT

ASIC CP 387 Series


📝 Understanding the Single Substantial Holding Notice

With the enhanced beneficial ownership disclosure rules following ASIC Consultation Paper 387 (CP 387) taking effect on December 4, 2026, market participants are overhauling their compliance workflows. The headline operational change is the consolidation of market disclosures: Forms 603, 604, and 605 are being merged into a single, unified Substantial Holding Notice (SHN).

While moving from three separate documents to a single standardized filing simplifies administrative overhead, completing the new SHN requires continuous aggregate data tracking across expanded position definitions.

📋 What Changed: Three Forms Become One

Historically, compliance teams selected a specific document depending on the event trigger:

  • Form 603: Notice of initial substantial holder (crossing 5%)
  • Form 604: Notice of change of interests (movement by at least 1%)
  • Form 605: Notice of ceasing to be a substantial holder (falling below 5%)

Under the finalized framework, the unified Substantial Holding Notice replaces all three legacy forms. Whether you are establishing an initial position, disclosing a 1% movement, or exiting, the same unified SHN framework applies.

  • December 4, 2026: The enhanced beneficial ownership regime and the new SHN format officially commence.
  • December 4, 2026 – June 3, 2027 (6-Month Transitional Window): Market participants may submit updated transitional replacement forms (or old forms with required annexures).
  • June 4, 2027: The transitional window closes. The unified SHN becomes mandatory for all disclosures.

📌 The Bottom Line

While moving from three separate documents to a single standardized filing simplifies administrative overhead, completing the new SHN requires continuous aggregate data tracking across expanded position definitions.

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.

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