Regulatory Tracker Update - What's Happened Since June 2025?

Since the last update to our Corporate Governance Regulatory Tracker in June 2025, regulatory guidance on navigating the Australian regulatory landscape has been a continued focus, reflecting a trend towards both transparency, and a lower tolerance for non-compliance by the Australian Government and regulators. Many of these developments have been recorded in the latest edition of the Regulatory Tracker, last updated as at 10 October 2025.

A summary of the changes we have updated in the tracker include:

Mandatory Climate Reporting: While most guidance has already been released and many companies are already navigating their additional climate reporting obligations, Australia’s first National Climate Risk Assessment Report was released by the Australian Government on 15 September 2025, serving as a critical source of information for companies preparing their climate risk assessments. We expect any further reports may provide additional guidance to businesses as they continue to comply with the climate reporting obligations.

Modern Slavery: The focus towards strengthening Australia’s modern slavery regime and the emphasis on a lower tolerance for non-compliance, including:

• The letter sent by the Australian Anti-Slavery Commissioner to relevant entities, reminding them of their obligations under the Modern Slavery Act on 17 July 2025; and

• The release by the Attorney-General’s Department on a consultation paper proposing the strengthen the Modern Slavery Act, particularly around transparent reporting, with consultation open between 21 July and 1 September 2025.

Anti-Money Laundering and Counter-Terrorism Financing: Tracking the continued reform to Australia’s AML/CTF regime, including:

• The tabling of the new AML/CTF Rules on 29 August 2025;

• Noting the timeline for compliance for tranche 2 entities newly captured, including enrolment opening on 31 March 2026, and the commencement of obligations on 1 July 2026; and

• Noting the application of the commencement of the revised reporting obligations for suspicious matter reporting and threshold transaction reporting, currently scheduled for 30 March 2029.

Privacy and AI: Noting the Attorney-General’s statement that another round of privacy reforms may be incoming, a response to the continued privacy breaches that have been impacting Australian consumers.

Capital Markets: Following the ongoing response to feedback arising from ASIC’s public consultation for its Discussion Paper ‘Australia’s evolving capital markets: A discussion paper on the dynamics between public and private markets’, including:

• ASIC’s release of a progress update on 22 September 2025 noting that it is considering the feedback, and expects to articulate its findings and its release of roadmaps for proposed implementation in November 2025; and

The release of ASIC Report 814 on 22 September 2025, outlining foundational insights on the private capital sector, validated, in part by feedback from ASIC’s public consultation.

Other: We have also noted the release of additional guidance, and proposed legislation, including:

• The release of ASX Guidance Note 17 on 11 August 2025;

• The passing of the Treasury Laws Amendment (Payment System Modernisation) Bill 2025 on 4 September 2025; and

• The introduction of the Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill 2025 on 4 September 2025.

We are seeking to expand the Regulatory Tracker as we head into 2026. If you have any other corporate governance regulations that you would like to see us track, feel free to contact Tim Bednall or Jack Wheatstone.

We are continuing to track changes to each of these regulations, so please continue to check the Regulatory Tracker for further updates. Please reach out to Owl Advisory by KWM or KWM if you would like to discuss navigating these regulations further.

This publication is a joint publication from King & Wood Mallesons, and KWM Compliance Pty Ltd (ACN 672 547 027) trading as Owl Advisory by KWM.   KWM Compliance Pty Ltd is a company wholly owned by the King & Wood Mallesons Australian partnership.  KWM Compliance Pty Ltd provides non-legal compliance and governance risk advisory services for businesses.  KWM Compliance Pty Ltd is not an incorporated legal practice and does not provide legal services. Laws concerning the provision of legal services do not apply to KWM Compliance Pty Ltd.