ASIC's IPO reforms: a faster path to market

As part of a two-year trial, the Australian Securities and Investments Commission (ASIC) has introduced a shorter Initial Public Offering (IPO) timetable for eligible entities seeking to list on the Australian Securities Exchange (ASX). The trial, announced on 10 June 2025, comes in response to a reduction in IPO activity in the Australian market and aims to streamline listings and encourage more companies to go public. 

JWS welcomes this positive step towards streamlining the IPO process and revitalising public markets activity. The reforms have been flagged by ASIC as the first in a series of proposed regulatory changes it is considering to enhance and improve the attractiveness of Australia’s public markets. 

Reasons for the reform

In recent years, Australia’s IPO market has experienced a significant decline, with 2024 marking a 20-year low in listing activity. Several factors have contributed to this decline, including market volatility, regulatory hurdles, and a preference for private capital raising. ASIC has acknowledged these challenges and launched a two-year trial aimed at making the IPO process more efficient, with the aim of encouraging more ASX listings.

Key changes to the IPO process

The trial aims to reduce the time required for eligible entities to complete an IPO. The key changes include:

• Informal review of offer documents: Eligible entities can provide a pathfinder prospectus or pathfinder PDS to ASIC for informal review at least 14 days before formal lodgement. This allows the entities to make necessary adjustments before the statutory exposure period begins. ASIC will then generally not need to extend the seven-day exposure period to 14 days after lodgement, other than where new material information comes to light or where there is an extended delay between the informal review completing and formal lodgement of the prospectus or PDS.
• Faster retail investor access: ASIC has also announced a no-action position where an eligible entity accepts retail investor applications for non-quoted securities (under a prospectus or PDS issued by the entity) during the exposure period, rather than waiting until the end of the exposure period. This aligns IPOs more closely with managed fund offerings and reduces administrative delays. Entities do not need to apply to ASIC to avail themselves of this no-action position.
• Shorter IPO timetable: These changes could shave up to a week off the standard IPO timeline for eligible entities, reducing the deal execution risk resulting from market volatility and consequential pricing changes.

Who can benefit?

ASIC’s initiatives are only available to entities who are eligible for a fast-track listing with ASX, i.e. entities with a market capitalisation of at least $100 million upon listing and no ASX imposed escrow. As entities applying to list on ASX under the “assets test” are usually subject to ASX escrow, many smaller or earlier-stage companies will not be able to benefit from the reforms.^[1] 

ASIC has advised that it will monitor the impact of these reforms and may expand these initiatives if they prove successful. Given these reforms will likely be extremely beneficial to companies seeking a small or mid-cap listing (and which may be more vulnerable to volatile market conditions and deal-execution risk), JWS is hopeful that the scope of the reforms is expanded in the future.

For advisers advising clients on IPOs, these reforms present an opportunity to help businesses navigate the IPO process in a shorter timeframe. Companies considering an ASX listing should assess whether they meet the eligibility criteria and how the changes might affect their IPO strategy.

Looking ahead

JWS welcomes these changes as a step toward enhancing the attractiveness of the Australian public markets. These changes, together with further upcoming regulatory adjustments alluded to by ASIC, signal a renewed focus on IPO activity and the regulator’s commitment to fostering a more efficient, accessible and attractive public market environment in Australia.

For more details, see ASIC’s official announcement.

^{[1] ASX may exercise its discretion not to apply escrow where an entity has a track record of profitability or revenue acceptable to ASX. An acceptable track record of revenue includes being a going concern (or a successor of a going concern) that has had continuing operations for at least three full financial years, having conducted the same business activity during the last three full financial years, having aggregated revenue from continuing operations for the last three full financial years of at least $20 million, having consolidated revenue from continuing operations for the 12 months to a date no more than two months before the admission date of at least $15 million, raising at least $20 million in the IPO, and having a market capitalisation at the date of listing of at least $100 million.}