Under the Treasury Law Amendment (2022 Measures No.1) Act 2022, large proprietary companies in Australia, which were previously exempt from having their accounts audited under grandfathering provisions, are now required to be audited and to lodge their reports with ASIC.  

In 2025 ASIC reported that more than half of companies which had previously been exempt under the grandfathering provisions, and who continue to meet the definition of a large proprietary company, had not submitted returns for the 2023 and 2024 financial year.

Upon investigating 58 such companies suspected to be large proprietary entities, ASIC discovered that 32 had not lodged their reports as required. Most of those investigated have since lodged their reports however some remain outstanding.

Due to these persistently high rates of non-compliance, ASIC has intensified its review processes and initiated a broader enforcement campaign for 2026.

ASIC Commissioner Kate O’Rourke has advised that companies should proactively assess their financial reporting responsibilities and rectify any non-compliance as soon as possible. She has stated that ASIC will continue to investigate lodgement failures and take regulatory action using its full range of enforcement and compliance tools, when needed.

What is a large proprietary company?

A proprietary company is defined as ‘large’ for a financial year if it satisfies at least two of the criteria set out below:

• The company and any entities it controls has consolidated revenue of $50 million or more for the financial year;
• The company and any entities it controls has gross assets at the end of the financial year of $25 million or more;
• The company and any entities it controls have 100 or more employees at the end of the financial year.

What does this mean for you?

If you suspect your company or group meets two of the above criteria you should contact your HCQ advisor to confirm if you are required to have your financial report audited and lodged with ASIC.