ASIC Regulatory Activity – December 2025

There has been significant guidance and direction from ASIC in recent months in the external reporting space.

In this section, we will consider ASIC’s findings from review of financial statements, recent restatements and the focus on non-lodgement of financial statements.

ASIC Report REP 819 ASIC’s oversight of financial reporting and audit 2024-25

In October 2025, ASIC released REP 819 which sets out their findings from reviews of:

• Financial statements
• Audit files, and
• Voluntary sustainability disclosures.

In relation to financial reporting, ASIC made the following comments:

• ‘Companies and other entities should ensure they have the right expertise and resources devoted to the preparation of high-quality and timely financial information. We particularly note the significance of asset valuations. Not only are these a subject of possible estimation uncertainty and judgement, the capacity of investors and members to compare entities’ financial position and performance relies on how assets have been categorised and valued.
• We ask preparers to pay attention to other areas where there is estimation uncertainty and judgement, such as revenue recognition and provisions and topics which may be qualitatively material for investors and members. We also encourage preparers of financial reports to be open in disclosing approaches and key assumptions they have taken in preparing their financial reports, especially in newer areas, and being candid on material business risks such as in the OFR [Operating and financial review].’

We note that some of you may not have investors, however these comments are equally relevant to all primary users of the financial statements.

During their reviews, ASIC found errors with:

• Operating and financial review (OFR) relating to material business risks
• Disclosures about consolidation, disaggregation in the balance sheet and the inclusion of a statement of cash flows
• Presentation of non-IFRS profit and reconciling this to statutory profit
• Gross disclosure of employee expenses where some of the expenses had been capitalised
• Non-consolidation of subsidiaries (refer to restatement section), and
• Impairment (refer to restatement section).

Restatements

There has been two recent restatements, a high level overview of these and the associated media release references are shown below:

Non-lodgement of financial statements

As reported in previous editions of this newsletter, ASIC has increased their focus on companies that have failed to lodge financial statements, in breach of their obligations under the Corporations Act.

ASIC’s focus on non-lodgement has intensified, with recent media releases noting that, due to widespread non-compliance among entities previously exempt under the grandfathering provisions, ASIC has commenced a broader surveillance program targeting large proprietary companies.

We note that some of our clients have received letters noting that based on ASIC’s intelligence they require explanation of whether the company is large and whether they have complied with their lodgement requirements under the Corporations Act. If they have then how, and if not then why not.

We encourage all our clients to ensure that they are aware of and understand their obligations to prepare, have audited and lodge financial statements with a regulatory authority and understand whether there are any breaches.

If you discover any inadvertent breaches, then please reach out to your Bentleys contact as soon as possible so we can assist you in reporting to the relevant authority, if appropriate.

Note to audited companies: ASIC has updated its guidance on auditor reporting obligations.  Non-lodgement / late lodgement of financial statements is now considered a significant breach of the Corporations Act and is required to be reported to ASIC by auditors.

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Disclaimer: This information is general in nature and should not be relied on as advice. It does not take into account the objectives, financial situation or needs of any particular person. You need to consider your financial situation and needs and seek professional advice before making any decisions based on this information.