ASIC extends reporting deadlines due to COVID-19

The impact of COVID-19 is being felt in all areas of business and many Australian entities are finding it challenging to adhere to their financial reporting obligations.

The Australian Securities and Investments Commission (ASIC) has acknowledged this and announced on 13 May 2020, there will be an extension of the deadline for both listed and unlisted entities to lodge their financial reports under the Corporations Act.  For those entities with reporting dates up to and including 7 July there will be a one month extension.

Please note this extension will not apply to any registered foreign companies.

Listed entities are required to inform the market when they rely on the extended period for lodgement, please note there will be no extension to reporting time frames for lodging the Appendix 4E with the ASX.

The Australian Charities and Not-for-profits Commission (ACNC) has already provided blanket extensions to charities whose 2019 Annual Information Statement is due between 12 March and 30 August 2020 to 31 August 2020.

We would recommend, where possible, for entities to lodge within the normal statutory deadlines.

ASIC has also adopted a ‘no-action’ position on holding Annual General Meetings (AGMs) up to seven months after year-end, instead of the usual five.  It was noted that entities are encouraged to not hold their AGMs in the peak holiday period of late December 2020 through to early January 2021.

Lodgement of full year financial reports, directors' report and auditor's reports	Usual deadline	Extended deadline
Listed entities	3 months after year end	4 months after year end
Unlisted disclosing entities and Unlisted registered schemes	3 months after year end	4 months after year end
All other unlisted entities	4 months after year end	5 months after year end

Lodgement of half year financial reports, directors' report and auditor's reports	Usual deadline	Extended deadline
Listed entities	75 days	75 day plus 1 month
Unlisted disclosing entities and Unlisted registered schemes	75 days	75 day plus 1 month

Lodgement of profit and loss and balance sheets	Usual deadline	Extended deadline
Unlisted Australian financial services (AFS) licensees that are bodies corporate and also disclosing entities or registered schemes	3 months	4 months
Unlisted AFS licensees that are body corporates and are not disclosing entities or registered schemes	4 months	5 months
AFS licensees that are not bodies corporate	2 months	3 months

What you need to do

• Take some time to assess the impact of COVID-19 on your financial reporting obligations and your overall business.
• Discuss any challenges and your plans with your Auditors to ensure everyone is working towards the same deadline.
• If circumstances and resources allow, we would recommend that unlisted entities aim to adhere to the statutory reporting deadlines.  However if this is not possible, entities should plan to meet the deferred lodgement date.

Reporting periods ending after 7 July 2020

ASIC will continue to monitor how market conditions and COVID-19 developments are affecting financial reporting and AGM obligations for balance dates after 7 July 2020.