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20RU-021 COVID-19 financial reporting deadlines – December 2020

20RU-021 COVID-19 financial reporting deadlines

ASIC extended the deadline for both listed and unlisted entities to lodge financial reports under the Corporations Act 2001 by one month for balance dates up to and including 7 January 2021. We have been advised that the ASX will extend its relief, on the same as the last class waiver, which is expected to be released before the end of November.

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In summary

ASIC has provided further extensions for both listed and unlisted entities to extend the deadline to lodge financial reports under the Corporations Act 2001 (Corps Act) by one month for balance dates up to and including 7 January 2021.

This announcement extends the relief already given for balance dates up to and including 7 July 2020. Refer to 20RU-019 COVID-19 financial reporting deadlines for details on the earlier extensions. This means that entities with 30 September 2020 and 31 December 2020 balance dates are afforded this relief.

We have been advised that te ASX is expected to extend its relief, on the same terms as the earlier class waiver (see 20RU-019 COVID-19 financial reporting deadlines). We anticipate it will be issued before the end of November.

The ASIC relief does not apply to registered foreign companies.

ASIC is still encouraging entities to lodge within the normal statutory deadlines, having regard to the information needs of shareholders, creditors and other users of their financial reports.

ASIC has advised that it will continue to monitor market conditions and COVID-19 and may issue updated guidance in the future.

The following table is the current state of play:

Entities reporting to ASIC Balance dates up to 7 January 2021 Balance dates after 7 January 2021
Listed entities1 1 month extension2
(i.e. 3 months to 4 months)
No announcement – ongoing monitoring by ASIC
Unlisted disclosing entities and unlisted registered schemes 1 month extension3
(i.e. 3 months to 4 months)
No announcement – ongoing monitoring by ASIC
Other unlisted entities 1 month extension3
(i.e. 4 months to 5 months)
No announcement – ongoing monitoring by ASIC
  1. ASX is expected to issue (by end of November 2020) relief to match the deadline extension issued by ASIC
  2. Entities with balance dates before 21 February 2020 will not receive the one month extension
  3. Entities with balance dates before 31 December 2019 will not receive the one month extension

In all cases entities may apply for individual relief, with ASIC, for extending a financial reporting deadline.

KPMG comment

“Before taking the one month extension offered entities should consider other contractual obligations which may require financial statements to be made available. For example, borrowing covenants which require the financial report by a prescribed deadline.”

Michael Voogt
Director, Department of Professional Practice

Reporting periods ending after 7 January 2021

ASIC continues to assess the impact on financial reporting for balance dates after 7 January 2021. ASIC is also carefully monitoring how market conditions and COVID-19 developments are affecting financial reporting obligations for entities. ASIC may make further announcements on these matters depending on market developments, however, ASIC expects that any further extensions may not be required.

Further detail can be found in the PDF version of the Reporting Update including further discussion on:

  • the impact on financial reporting deadlines for both listed and unlisted entities
  • consequential amendments to other ASIC Instruments resulting from the deadline extension
  • guidance on a timing extension for public company requirements to hold annual general meetings (AGMs)
  • guidance on the ability for public companies to hold hybrid or virtual AGMs.

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