On 5 November 2025, ASIC released its report “Advancing Australia’s evolving capital markets: Discussion paper response.” If implemented, it’s recommendations will have implications for publicly listed companies, fund managers, trustees, and institutional investors. Here’s a summary of the report and our take on what boards, issuers, fund managers and trustees should be alive to as a result.
Key insights
- The Report sets out “A roadmap for capital markets to grow our economy”. ASIC’s plan to strengthen the depth, resilience, and competitiveness of Australia’s public and private markets over the coming years.
- The tone of the Report is welcome, with ASIC committing to being “a backer, not a blocker of investment and capital”. This language represents a clear shift in ASIC’s approach from simply a regulatory monitor to a facilitator.
- In the Report, ASIC acknowledges the changing structure of Australia’s investment landscape, particularly the shift away from public listings to private markets.
- ASIC’s Roadmap contains several proposals to increase participation and retention in public markets including streamlining listing processes, modernising disclosure, and encouraging innovation in capital raising. It also suggests ways to introduce greater transparency and accountability in private markets.
- ASIC acknowledges the expanding role of private credit and suggests ways to uplift regulatory standards to ensure private credit is “done well”.
- Overall, the Roadmap sets a positive tone but the way forward and the timing of many necessary changes to implement it remain uncertain and contingent upon legislative support or engagement with other regulators (ASX, APRA, etc).
Let’s take a look at some of the positive aspects of the Report and some of the challenges that lie ahead.
More accessible and efficient public markets
ASIC acknowledges that Australia’s public markets have been losing ground in recent years, with fewer IPOs, smaller average deal sizes, and more capital flowing into private markets. The Roadmap suggests ways to provide greater certainty and efficiency which will no doubt appeal to issuers, underwriters, and investors.
In particular, ASIC proposes many progressive changes that, if implemented, will lower the barriers to entry and ongoing requirements for publicly listed companies. These include:
- exploring a “fast-track” IPO pilot for issuers with established reporting histories (note that a two year trial of this is currently underway with evaluation through 2026);
- reviewing prospectus disclosure rules (RG228 and RG254) to reduce duplication and modernise formats;
- considering adjustments to free float requirements and continuous disclosure settings to align with peer markets; and
- re-examining the two-strikes rule and executive remuneration reporting to simplify compliance.
These initiatives are pragmatic steps to reinvigorate public listings and attract mid-cap and growth-stage companies that might otherwise remain private or list offshore.
Greater oversight of private markets – an uplift in transparency
The Roadmap acknowledges the rapid expansion of private capital markets — including private credit, unlisted managed investment schemes and private equity structures – and suggests that additional transparency and surveillance is required to ensure market stability and investor confidence.
ASIC has signalled plans to:
- enhance transparency and disclosure for wholesale and sophisticated investor funds;
- strengthen governance expectations for fund trustees and managers;
- improve valuation and liquidity risk frameworks; and
- launch a “collect once” data reporting pilot for private market funds.
For fund managers, trustees, and institutional investors, these proposals represent a notable increase in regulatory compliance.
While ASIC’s focus on transparency is understandable, it’s unclear how these requirements will be implemented without imposing disproportionate compliance costs or constraining innovation in private capital formation.
As it builds out the legislative framework necessary to implement these changes, ASIC will need to consider how it appropriately balances this increased oversight with its self-proclaimed goal of being a “backer not a blocker”.
The practical challenges
While the Roadmap lays out an encouraging vision, its implementation remains uncertain. Many of the proposals — particularly those involving legislative change or expanded regulatory powers — will require collaboration between ASIC, Treasury, and the Government.
Key hurdles that must be overcome include:
- regulatory overlap with potential duplication between ASIC, APRA and ATO oversight in private markets;
- data capacity – as ASIC currently lacks sufficient visibility into private market activities, and building that capability will take time; and
- legislative dependency with reforms being flagged as “under consideration” rather than immediate, meaning tangible change may be slow.
The Road Ahead – Our Take
The Roadmap is an important and constructive initiative. It demonstrates that ASIC is seeking to balance growth with integrity — encouraging capital formation while safeguarding investor protection.
In our view:
- Boards and issuers should anticipate a simplified IPO process and streamlined prospectus disclosure in the short term (next 12 months or so).
- Fund managers and trustees should review their current processes against ASIC’s private credit principles (set out in the Report) – particularly in relation to valuation, liquidity risk management, governance, conflict management and fee structures as ASIC’s principles are likely to become requirements in the near future.
