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

Authored by Jack Wheatstone

Since the last update to our Corporate Governance Regulatory Tracker in October 2025, we have seen extensive updates across a variety of areas in the Australian regulatory landscape. Of note, there have been several updates in the AML/CTF space as we rapidly approach the 31 March deadline for the expanded regime. We have also seen other areas that were previously slowed begin to gain traction again, with a variety of updates around the ASX Corporate Governance Principles and Recommendations, Australia’s modern slavery regime, and Australia’s private and capital markets.

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

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

• The announcement by the Minister of Home Affairs of intended additional AML/CTF reforms in 2026 on 16 October 2025;

• The Department of Home Affair’s release of a consultation paper, seeking feedback from industry participants around the proposed additional 2026 reforms on 17 December 2025;

• AUSTRAC’s release of an updated statement of their regulatory expectations for the new AML/CTF Rules taking effect from 31 March 2026 on 18 December 2025;

• The Department of Home Affair’s release of guidance on proposed transitional rules that will support the new AML/CTF Rules coming into effect on 31 March 2026 on 22 January 2026. The exposure draft for the transitional rules is expected to be released in February 2026;

• The release of tranche 2 sector-specific guidance for small, low-complexity tranche 2 businesses on 29 Jan 2029; and

• The proposed transitional period for the updated AML/CTF Rules as of 31 March 2026, including:

  • The deadline for existing reporting entities to notify ASIC of their AML/CTF compliance officer on 30 May 2026, and tranche 2 entities on 29 July 2026; and

  • The deadline for existing reporting entities to switch to the reformed customer due diligence obligations on 30 March 2029.

    
    

Modern Slavery: Tracking the progress of law reform to Australia’s modern slavery regime, including:

• The release of the Inaugural Annual Report of the Office of the Australian Anti-Slavery Commissioner on 20 October 2025; and

• The release of the Office of the Australian Anti-Slavery Commissioner’s Strategic Plan 2025-2028 on 22 October 2025.

• Corporate Governance Principles and Recommendations: Tracking the ASX’s progress on updating the ASX Corporate Governance Principles and Recommendations, including:

• The release of the ASX Corporate Governance Council independent review panel’s Panel Report, recommending the establishing of a new Advisory Group to replace the existing ASX Corporate Governance Council, on 16 October 2025;

• The appointment of Dr Philip Low as the inaugural Chair of the ASX Advisory Group on Corporate Governance on 3 November 2025; and

• The appointment of 7 inaugural members of the ASX Advisory Group on Corporate Governance on 29 January 2025.

Capital Markets: Tracking the progress of the proposed reform to Australia’s public and private capital markets following the release of ASIC’s Discussion Paper on 26 February 2025, including:

• The release of ASIC Report 823 Advancing Australia’s evolving capital markets: Discussion paper response report’ on 5 November 2025;

• The release of ASIC’s roadmap detailing its plan on advancing Australia’s private and capital markets over the next 12-18 months on 5 November 2025, including:

  • Reporting ASIC’s findings on its inquiry into governance, capability and risk management frameworks on 31 March 2026; and

  • Conducting a data pilot for a small sample of retail and wholesale funds to inform data reporting and information reforms in financial year 2026-2027; and

• The release of an updated RG 181, in reflection of the findings in ASIC Report 823 on 17 December 2025.

OTHER: And tracking a variety of other changes in regimes previously captured, particularly around the payment systems legislation amendments, including:

• Treasury’s release of the draft Payment Systems Legislation Amendment (2025 Measures No. 1) Regulations 2025 for consultation on 29 October 2025, and the subsequent registration of the regulations on 11 Dec 2025;

• The Senate’s release of their report on the Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill 2025 on 19 November 2025 and their subsequent passing by both houses of parliament on 27 November 2025;

• The publication of submissions on the Payment Systems Legislation Amendment (2025 Measures No. 1) Regulations 2025 on 16 December 2025.

As we continue to update the Regulatory Tracker in 2026, we expect to expand our scope to new regulations and reforms through the year. If you have any specific corporate governance regulations that you would like to see us track, please 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.