Who must report
Track 1 covers directors. Section 205G(1) of the Corporations Act 2001 requires a director of a listed public company to notify the market operator (ASX) of two things: relevant interests in securities of the company or a related body corporate, and contracts that confer a right to call for, or deliver, shares, debentures or managed-investment interests. "Relevant interest" is defined in section 9 of the Act and reaches through legal wrappers, which is why so many notices list securities the director does not hold in their own name.
Track 2 covers substantial holders. Any person who, together with associates, has relevant interests in voting shares carrying 5 percent or more of the total votes is a substantial holder, with the notification obligation sitting in section 671B. A bidder also has a substantial holding throughout a takeover bid period. This track captures anyone who crosses the line, and in practice most filers are institutions and funds, not company insiders.
The six forms
| Form | Trigger | Deadline |
|---|---|---|
| Appendix 3X | Initial director's interest notice, on listing or on appointment. A director with no holdings still files a nil 3X. | 5 business days (LR 3.19A.1) |
| Appendix 3Y | Any change in a director's notifiable interests, including issue, conversion, forfeiture or lapse of shares, options or rights under employee incentive schemes. | 5 business days (LR 3.19A.2) |
| Appendix 3Z | Final director's interest notice, on ceasing to be a director. | 5 business days (LR 3.19A.3) |
| Form 603 | Becoming a substantial holder: crossing 5 percent of total votes. | 2 business days |
| Form 604 | A movement of at least 1 percent in voting power, or a change in the nature of the interest. | 2 business days |
| Form 605 | Ceasing to be a substantial holder: falling below 5 percent. | 2 business days |
Forms 603, 604 and 605 are lodged with the listed company and the market operator, not with ASIC, and carry no lodgement fee.
The 5 business day deadline
Two clocks run in parallel, and only one of them matters day to day. Under s205G(3) and (4), the director personally has 14 days after appointment, listing, or any change of interest. Breaching s205G(1) is a strict liability offence carrying 10 penalty units, 3 months imprisonment, or both. Under Listing Rule 3.19A, the listed entity must lodge the relevant Appendix no more than 5 business days after the trigger, and it lodges as agent for the director.
ASIC Corporations (Disclosure of Directors' Interests) Instrument 2016/881 connects the two: a director need not comply with s205G personally if they reasonably believe the entity has complied with Listing Rule 3.19A on their behalf. So the 5 business day entity filing is the deadline that governs when the market actually sees the trade.
One detail with real screening consequences: for an on-market trade, the 5 business days run from the trade date, not from settlement. The relevant interest arises at execution.
The substantial holder track is faster. Outside a takeover, a 603, 604 or 605 is due within 2 business days of becoming or ceasing to be substantial, or of a movement of 1 percent or more (ASIC Regulatory Guide 5). During a takeover bid the notice is due by 9.30 am on the next trading day.
Where filings are published
Everything is released through the ASX Market Announcements Platform on asx.com.au, with the notice PDFs served from announcements.asx.com.au. Access is free and public. Director interest notices and substantial holder notices appear in the same announcements stream as results, capital raisings and everything else a listed entity publishes, so filtering by announcement type is the first job of anyone consuming the feed.
How to read an Appendix 3Y
The 3Y is a fixed template, and its header already tells you who is speaking: the entity states that it gives the information under Listing Rule 3.19A.2 "and as agent for the director for the purposes of section 205G". Then three parts:
- Part 1 (securities): whether the interest is direct or indirect; the nature of an indirect interest, naming the registered holder (a trustee, for example); the date of the change; securities held before the change; the class; the number acquired and the number disposed; the value or consideration; securities held after, split between direct and indirect; and the nature of the change, such as "on-market trade".
- Part 2 (contracts): interests in contracts conferring rights over securities.
- Part 3 and the closed period section: whether the trade happened during a closed period that required prior written clearance, and if so whether and when clearance was given.
Read the nature of the change and the consideration before anything else. An on-market trade with cash consideration is a decision. An issue of performance rights with nil consideration is payroll.
Interpretation traps
The company files, not the director
Every 3X, 3Y and 3Z is lodged by the entity as agent. Listing Rule 3.19B obliges the entity to have an arrangement with each director to make that possible. The practical consequence: a late notice may be the company's administrative failure rather than a director hiding something.
Indirect interests hide the registered holder
Australian directors routinely hold through family trusts, self-managed superannuation funds and private companies. These show up as "indirect" interests with the registered holder named in the nature-of-interest field. The director is often not the registered holder of a single share, and the 3Y is still complete and correct.
Substantial holder notices are not insider signals
Forms 603, 604 and 605 mostly capture fund managers and institutions rebalancing. Treating a 604 as conviction from someone with inside knowledge of operations misreads the population of filers.
Performance rights make 3Ys look like trades
Issue, vesting, exercise, forfeiture and lapse under employee incentive schemes all trigger a 3Y. A notice showing thousands of securities "acquired" for nil consideration is a compensation event, not a purchase.
A 604 can fire with no trade at all
A change in the nature of an interest triggers Form 604 even when not a single share moved. Voting-power arithmetic adds a second wrinkle: options are not themselves counted in voting power, but underlying voting shares subject to a relevant interest are.
How insiders-trades.com tracks ASX filings
The announcements page on asx.com.au is JavaScript-driven, so we ingest from its underlying Markit JSON API instead of scraping the rendered page. We take both families: Appendix 3X, 3Y and 3Z director interest notices (Corporations Act s205G plus Listing Rule 3.19A) and Forms 603, 604 and 605 substantial holder notices (s671B). Filings merge into the same declaration model we use for every regulator, with roles normalised and amounts converted to EUR for cross-market comparison.
Browse the live output on the Australian market hub, or start from a company page such as Woodside Energy or Megaport.
For the US regime this system is most often compared with, see our SEC Form 4 guide, and for how every market's rules line up side by side, the insider disclosure rules by country index.
Sources
- ASX Compliance Course, Module 11: Directors' interest notifications (s205G, LR 3.19A/3.19B, Instrument 2016/881)regulator
- ASIC Regulatory Guide 5: Relevant interests and substantial holding notices (March 2024)regulator
- ASX Appendix 3Y template: Change of Director's Interest Noticeregulator
- ASIC Form 604: Notice of change of interests of substantial holderregulator
- ASX Listing Rules, Chapter 3: Continuous disclosurelaw