ASIC's Capital Markets Roadmap: What It Means for Small and Mid-Cap Issuers

On 5 November 2025 ASIC released its roadmap for Australia's capital markets, together with reports on private credit surveillance, global reporting practices and the forces shaping the market over the next decade. The roadmap caps a year of consultation that began with ASIC's February 2025 discussion paper and drew close to 100 submissions.

Much of the commentary has focused on private markets. For ASX-listed and pre-IPO companies, the more immediate content sits in the public markets workstreams.

What is changing

• IPO settings. The fast-track IPO process introduced in June 2025 will continue, and ASIC has encouraged ASX to consult on admission settings including free float calibration and tailored pathways for smaller and growth entities.
• Prospectus disclosure. ASIC will review Regulatory Guide 228 with the stated aim of purposeful disclosure, including the treatment of forecasts.
• Fundraising publicity. ASIC has acknowledged that the pre-prospectus publicity restrictions have not kept pace with modern communication channels and proposes to modernise the framework.
• Sell-side research. ASIC will review its research policy settings to simplify requirements while preserving independence and conflict management.
• Competition between venues. ASIC has approved Cboe Australia's listing rules and expanded the approved foreign market list, and ASX has signalled a proposal to lower the foreign exempt listing threshold from A$2 billion to A$500 million.

Why it matters in Western Australia

The WA market is dominated by exploration and small resources companies for which the cost and timing of a listing, and the flexibility of secondary raising rules, are commercial issues rather than abstract policy. Faster admission timetables reduce underwriting and market risk. Recalibrated free float and spread settings may open the ASX to companies that currently structure around the thresholds. Modernised publicity rules would reduce a persistent compliance trap in pre-IPO marketing.

What boards should do now

• Companies planning a 2026 or 2027 IPO should assess eligibility for the fast-track pathway early, because the pathway rewards issuers whose due diligence and pathfinder are genuinely complete at first submission.
• Boards should not assume the current publicity restrictions have relaxed. Until ASIC finalises reform, the existing advertising restrictions in the Corporations Act continue to apply in full.
• Watch the ASX consultation pipeline. Changes to free float, spread and foreign exempt settings will flow through to transaction structuring, and early movers tend to benefit.

How Luma Legal can help

We advise boards, brokers and pre-IPO companies on listing pathways, capital raising structures and disclosure. We will publish further analysis as ASIC and ASX release consultation papers under the roadmap.