In recent months, we have heard of and seen growing frustrations caused by the time taken to complete backdoor listing transactions, and recent policy amendments implemented by ASX look likely to entrench the increased time required to complete a backdoor listing transaction.

Therefore, in planning your backdoor listing, the following timelines and periods, communicated to us by ASX, should be noted:

• The time period for ASX to review a notice of meeting for a backdoor listing is now up to 21 days (increased from 7 days historically).
• ASX will not respond on a draft notice of meeting until any waivers applied for have been granted by ASX.
• The time period for review of non-standard waivers that are required to be considered by ASX’s National Management Committee isapproximately 4 weeks.
• A company should allow between 4 – 6 weeks after lodging its Appendix 1A application for quotation for that application to be considered by ASX.
• ASX will take up to 21 days to review a prospectus once it is announced on the ASX announcements platform, including time for consideration by the ASX’s new Policy and Listings Standards Committee, should they considered it appropriate.
• A company should allow a period of time from the date of the shareholder meeting (assuming closure of the capital raising during that period) for ASX to process the listing application and for the company to be re-instated to trading on ASX.

Whilst some of these time periods will naturally occur concurrently, the reality is that increased internal processes within ASX will result in delays in the completion of transactions. Because of this, careful planning needs to be undertaken to ensure that a transaction can be implemented and processed in a methodical manner.

Steinepreis Paganin continues to consider ways in which we can make it easier for ASX to meet their internal requirements, and we continue to communicate with ASX to find ways in which we can facilitate the easier processing of waivers, notices of meeting and applications for listing that can enable ASX to address their internal processes and meet client expectations.

Due to these changes, we recommend discussing with us at the earliest opportunity any proposed transaction so that an appropriate plan of action can be implemented.