ASIC launches Fast-track pre-vet prospectus review to boost IPO activity

In a promising development for companies considering listing in Australian public markets, the Australian Securities and Investments Commission (ASIC) has launched its two-year pilot program to streamline the IPO process in Australia.

The changes are effective as of 10 June 2025 and forms part of ASIC’s broader effort to make Australia’s public markets more attractive and stimulate listing activity.

Confidential pre-lodgement review

The key development is a newly instituted pre-lodgement review by ASIC of a prospective IPO candidate's draft disclosure documents before formal lodgement takes place.

The changes represent a shift from ASIC's previous approach of refusing to pre-vet prospectuses and only commencing a review during the mandatory exposure period following lodgement.

As part of the pre-lodgement review, prospective issuers may submit a pathfinder prospectus or pathfinder PDS (generally excluding pricing information) on a confidential basis to ASIC at least 14 days ahead of formal prospectus lodgement.

The aim of this new pre-vet process is to allow ASIC to identify deficiencies in offer documents sooner, reducing the need to extend the post-lodgement exposure period and for supplementary or replacement disclosure documents to be lodged.

A condensed timetable for prospective issuers, which this new regime should help promote, reduces the impact of market volatility on pricing, offering greater certainty for underwriters and investors. It also allows issuers to focus on garnering investor interest in parallel with ASIC’s review.

The process is available to entities seeking ASX Fast-track listing. Recent changes by ASX to Guidance Note 1 provide that Fast-track is available to entities that will have a market capitalisation greater than $100 million upon listing and no ASX imposed escrow.

Prospective issuers seeking to use the ASX Fast-track listing process should note that they must submit the pathfinder prospectus or PDS to ASX at least four weeks before the formal lodgement date. This is in addition to the issuer lodging the same document with ASIC for review 14 days ahead of formal lodgement.

Retail investor applications

Another key change allows retail investors to apply for shares during the seven-day exposure period, conditional on ASIC’s completion of the pre-lodgement review. Retail investors were previously only entitled to apply for shares during the offer period, which commenced after the exposure period.

Throughout the trial period, ASIC will maintain a blanket no-action approach where the prospective issuer accepts offers during the exposure period from retail investors in relation to non-quoted securities. Prospective issuers will be permitted to engage earlier with retail investors, supporting the streamlined IPO process.

Takeaways

ASIC's position will deliver welcome changes to the IPO process in Australia, expediting access to equity capital markets and encouraging renewed interest in Australian listings, an area that has been flagging for a number of years.

The accelerated process will require eligible entities to remain proactive and disciplined to ensure they are capable of meeting the tighter deadlines. In particular, companies will need to focus on earlier preparation of offer documents, tighter coordination with financial and legal advisers and ASIC and clear internal processes for managing exposure-period risk.

Early investor engagement and a reliable, accurate pathfinder prospectus will be critical to take advantage of the streamlined process.

For more information, please contact our Capital Markets team.

Authors

David Schiavello | Partner | +61 3 8080 3704 | dschiavello@tglaw.com.au

Emma Cook | Partner | +61 7 3338 7557 | ecook@tglaw.com.au

Liam Di Martino | Lawyer | +61 3 8080 3576 | ldimartino@tglaw.com.au

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