FundApps works with over 150 of the world's largest financial institutions, helping them navigate shareholding disclosure requirements across global markets. When Australia's financial regulator, ASIC, opened a consultation on how to implement new shareholding disclosure laws, we responded on behalf of our clients.
Our submission to Consultation Paper 387 sets out a clear position: the technical choices regulators make about data formats are not administrative footnotes. They have direct operational consequences for compliance teams already juggling disclosure obligations across dozens of jurisdictions.
These reforms are coming into force by the end of the year regardless. What we care about is whether how they’re implemented represents the best long-term solution for market participants. You can read our full submission here - FundApps' response to CP 387.
Structured data formats are how information moves reliably across the internet, and financial markets are no exception. However, ASIC raised concerns that structured formats like XBRL might require specialist software, potentially creating barriers. While it is a reasonable instinct, the conclusion does not follow.
XML and JSON do not require clunky specialist viewers. Any well-built web portal renders them cleanly and accessibly for any user. The data stays structured and machine-readable behind the scenes. The interface handles human readability. This is not a theoretical position for us. We process shareholding disclosure data across hundreds of jurisdictions for some of the largest institutions in the world. We know what well-structured data enables, and we know what happens when it is absent. Applied to ownership disclosures, this means:
So why does this matter? Because the alternative ASIC is being asked to preserve is significantly worse.
For a compliance officer responsible for a global investment mandate, Australia is one item on a long list. When any jurisdiction introduces a format that sits outside established data standards or conventionally accepted practices, it does not just create a local inconvenience. It adds manual work, introduces validation gaps, and increases the opportunity for mistakes.
ASIC's current system relies on static, often scanned PDF documents. The result?
Framing PDFs as the accessible, human-readable option gets it backwards. They are in practice one of the least accessible and least functional formats available.
A structured data standard, rendered through an accessible web interface, delivers both. The format carries the data. The interface carries the readability. There is no trade-off to make here.
The transparency objectives behind these reforms are sound. Regulators and investors should be able to see who owns and controls listed companies, track changes over time, and interrogate the data at scale. None of that is possible with static documents. All of it becomes straightforward with structured data rendered through a modern, accessible web interface.
Our response to CP 387 is a reflection of how we work. We track regulatory developments across every major jurisdiction, engage directly with the consultations that shape them, and make sure our services capture the necessary changes. That way, when the rules shift, our clients already have what they need.