ASIC is consulting on remaking wholly-owned company financial reporting relief. Use this checklist to review deeds of cross guarantee, entity scope, consolidated reports and evidence.
ASIC is consulting on remaking financial reporting relief for wholly-owned companies. For CFOs, General Counsel and Company Secretaries, the practical job is to confirm which entities rely on the relief, whether the deed of cross guarantee is current, whether the holding entity's consolidated financial report covers the right companies, and where the evidence sits. ASIC says comments on CS 61 close on 28 August 2026.
General information only, not legal advice. Groups relying on reporting relief should verify their position against ASIC materials and professional advice.
On 3 August 2026, ASIC released CS 61, a consultation on the proposed remake of ASIC Corporations (Wholly-owned Companies) Instrument 2016/785.
ASIC says the current instrument provides financial reporting relief to wholly-owned companies if the holding entity lodges a consolidated financial report. The relief is subject to conditions, including executing a deed of cross guarantee in the form of Pro-forma 24, or PF 24.
The current instrument is due to sunset on 1 October 2026. ASIC proposes to remake the relief for five years while the Australian Government progresses broader law reform for simplified reporting relief for group entities. ASIC's proposal says:
The governance point is not just that relief may continue. The point is that relief depends on records, deeds, scope and annual evidence being correct.
Reporting relief can be easy to describe and hard to control.
In a multi-entity group, the finance team may know that a subsidiary does not lodge a separate financial report. The legal team may know that a deed of cross guarantee exists. The company secretary may hold the annual ASIC compliance calendar. The auditor may have a separate view of the consolidated group. The board pack may only show the end result.
That split creates a simple risk: no single person can quickly prove why a specific entity is relying on relief this year.
For a clean governance process, each relying entity should have a live record showing:
If those answers sit across spreadsheets, signed PDFs, email trails and adviser memory, the relief process becomes a reconstruction exercise.
ASIC's general financial reporting guidance says some entities must prepare and lodge financial reports, including disclosing entities, public companies, large proprietary companies that are not disclosing entities, registered schemes, certain foreign-controlled small proprietary companies and other specified entities. ASIC also warns not to assume an entity qualifies for an exemption.
That matters because corporate groups change.
A subsidiary may join or leave the group. A holding structure may be reorganised. A dormant entity may start trading. A debt structure may change. A deed may not have been updated after a restructure. The finance reporting perimeter may not match the governance record. An entity may be wholly-owned in commercial language but not captured correctly in the relief evidence.
The safe operating posture is not "we relied on relief last year." It is "we can show the current basis for relying on relief this year."
Use this checklist before year-end reporting, before audit planning, and whenever the group structure changes. It is designed for CFOs, General Counsel, Company Secretaries and governance teams managing multiple Australian companies.
Start with a plain inventory of every company that may be relying on wholly-owned company financial reporting relief.
For each entity, capture:
Do not begin with the deed alone. Begin with the full group list, then reconcile the relief population against it. That helps catch entities that have been added, removed, deregistered, acquired, transferred or left dormant.
The relief is about wholly-owned companies. That means the ownership record needs to be current enough to support the conclusion.
Check:
The practical failure mode is a static structure chart that says "100%" while the source records tell a more complicated story. If the ownership map has not been reconciled since the last acquisition, restructure or share change, treat the relief position as unverified until it is checked.
ASIC's CS 61 materials confirm that a deed of cross guarantee in PF 24 form remains central to the relief conditions. They also note proposed savings provisions intended to preserve the effect of deeds entered into under previous instruments.
For each relying entity, verify:
This is where governance teams often discover a record gap. The deed may exist, but the evidence may sit in an old matter folder, an adviser portal, a scanned PDF, or a former employee's inbox. The question is not only "was the deed signed?" It is "can the group produce the executed deed and explain its current scope without a manual hunt?"
ASIC says the relief under Instrument 2016/785 applies if the holding entity lodges a consolidated financial report, subject to conditions. The operational check is whether the consolidated report and the deed population align with the entities relying on relief.
Ask:
This is the point where finance and CoSec records need to meet. Finance may own the consolidated report. Legal or CoSec may own the deed and entity records. Relief depends on the two staying aligned.
ASIC's company record-keeping guidance says companies must keep certain records, records may be digital if hard copies can be produced, and financial records must generally be kept for at least seven years.
For reporting relief, the governance evidence pack should include:
The goal is not to create paperwork for its own sake. The goal is to make the relief position reviewable by the board, auditors, advisers or a new CFO without relying on memory.
Relief control should have one accountable owner, even if finance, legal, CoSec and external advisers all contribute.
At minimum, define:
For larger groups, treat this like a recurring governance control. Review it during year-end planning, after major restructures, and before signing financial reporting or board papers that assume relief applies.
Use these questions before the 28 August 2026 consultation deadline, or as a pre-year-end control if you are reading this later.
| Diagnostic question | Green flag | Red flag | |
|---|---|---|---|
| Do we know every entity relying on wholly-owned company relief? | Current list reconciled to the group structure | "Finance has the list somewhere" | |
| Can we prove each relying entity is wholly-owned? | Register, ownership map and source documents agree | Static chart not tied to source records | |
| Can we produce the relevant deed of cross guarantee? | Executed deed, version and parties are stored with the entity record | Deed is in an old legal folder or adviser inbox | |
| Does the consolidated report cover the right entities? | Finance and governance entity lists have been reconciled | Different entity lists in audit, legal and CoSec files | |
| Do we know what changed since last year? | Change log captures acquisitions, exits, deregistrations and transfers | Reliance is based on last year's assumption | |
| Is there one accountable owner? | Named owner, annual review date and exception process | Split ownership between finance, legal and advisers |
If two or more answers are red, treat the relief position as needing active review.
EntityFlo is built for Australian corporate groups that need one system of record for entity data, obligations, approvals, documents and evidence.
For wholly-owned company reporting relief, the system-of-record problem is clear: the group needs to connect entities, ownership, reporting obligations, deed evidence, annual review tasks and supporting files. A spreadsheet can list entities. A shared drive can store documents. Neither is a reliable operating record unless the team can see status, owner, source document and review history together.
EntityFlo helps governance teams manage that record in one place, so finance, legal, CoSec and advisers can work from the same entity truth instead of rebuilding it at reporting time.
This draft is based on ASIC sources retrieved for the EntityFlo content workflow:
Before publishing after 28 August 2026, check whether ASIC has published an update following the consultation close.
Wholly-owned company reporting relief refers to relief that may allow certain wholly-owned companies in a corporate group not to prepare or lodge separate financial reports, where the holding entity lodges a consolidated financial report and the required conditions are met. ASIC Instrument 2016/785 is the current instrument discussed in ASIC's CS 61 consultation.
CS 61 is ASIC's consultation on the proposed remake of ASIC Corporations (Wholly-owned Companies) Instrument 2016/785. ASIC released it on 3 August 2026 and invited feedback by 5pm AEST on 28 August 2026.
A deed of cross guarantee is a deed used in the wholly-owned company relief framework. ASIC's CS 61 materials refer to a deed in the form of Pro-forma 24, or PF 24, as one of the conditions connected to the relief. Groups should seek professional advice on whether their deed is valid and current.
No. ASIC's financial reporting guidance warns not to assume an entity qualifies for an exemption. Relief depends on the applicable law, ASIC instruments and specific conditions. Groups should verify the position for each entity before relying on it.
Governance teams should check the relying-entity list, wholly-owned status, deed of cross guarantee coverage, consolidated financial report coverage, ASIC lodgement evidence, ownership changes, joining or exit documents, internal approvals and the accountable owner for the annual review.
At minimum, review it annually before financial reporting sign-off. It should also be reviewed after acquisitions, restructures, share transfers, deregistrations, changes in holding company structure or any event that changes which entities sit inside the group.
Software can help when it connects entity records, ownership structure, obligations, documents, approvals and evidence history. The important point is not just storing files. The team needs a controlled record showing which entities rely on relief, why, who reviewed it and where the supporting evidence lives.
If your group relies on spreadsheets, shared drives and adviser memory to prove which entities are covered by reporting relief, book an EntityFlo demo to see how a governance system of record can keep entities, deeds, obligations and evidence connected.
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