Eugene Fung and Sarah Beattie

New mandatory Jobkeeper disclosure obligations

Eugene Fung and Sarah Beattie

20 October 2021

Competition & Regulation Legislation & Regulatory Updates

Under recent amendments to the Corporations Act 2001 (Cth), listed entities are required to provide the ASX (or relevant market operator) a notice detailing the Jobkeeper payments they (or their subsidiaries) have received in a financial year.

This Jobkeeper notice must be provided even where information about Jobkeeper payments were included in the entity’s accounts.

What must be disclosed

Listed entities must disclose the following information in their Jobkeeper notice:

  • (ABN) the listed entity’s name and ABN;
  • (Employees) the number of individuals for whom the listed entity (or its subsidiaries) received a Jobkeeper payment for a ‘Jobkeeper fortnight’ that ended in the financial year;
  • (Quantum) the sum of all Jobkeeper payments received by the listed entity (and its subsidiaries) in a ‘Jobkeeper fortnight’ that ended in the financial year; and
  • (Voluntary Repayments) whether or not the listed entity (or its subsidiaries) have made voluntary repayments of the Jobkeeper payments they received in a financial year to the Commonwealth (whether or not these repayments were made in the financial year) and the amount of such voluntary repayments.

How to make the disclosure

ASIC has issued a template Jobkeeper notice available here:

It should be noted that pressing the ‘submit’ button does not provide the Jobkeeper notice to the ASX (or other relevant market operator).  Submitting the notice will send a PDF to the email address included in the notice.  This PDF should then be provided to the ASX (or other relevant market operator) for release to the market.


The obligation to disclose the Jobkeeper payments for a financial year depends on when the entity lodged their financial report with ASIC for that financial year:

Lodgement of financial report with ASIC Jobkeeper notice deadline
On or before 14 September 2021 13 November 2021
After 14 September 2021 Within 60 days after the annual report for that financial year is lodged with ASIC


If you would like further advice or assistance, please contact a member of our national Corporate & Advisory Team.


Sarah Beattie | Associate | +61 7 3338 7953 |

Eugene Fung | Partner | +61 7 3338 7524 |