New mandatory Jobkeeper disclosure obligations

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: https://jobkeeper.asic.gov.au/#/.

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.

Deadlines

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:

Contact

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

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