IR best practice · 5 min read · 8 July 2026
Why honest companies still get disclosure wrong
Disclosure risk can arise when claims drift across documents. Check the context, record the changes and state how much of the history was reviewed.
Reviewed and updated 7 September 2026. Original publication date retained.
Disclosure risk can arise when documents drift apart. A guidance comment, an investor reply and a results presentation may use different figures or assumptions without explaining what changed.
Good intent is not enough to establish accuracy or timely disclosure. Equally, a difference between two statements is not automatically a breach: it may be a properly explained update. The review needs the facts, dates and materiality assessment. ASX Listing Rule 3.1 and the statutory civil-liability provisions have distinct elements. ASX Chapter 3; Corporations Act, ss674-674A.
Check the claim in context
Start with the subject: the guidance range, project milestone, dividend policy or repeated figure. Locate the source, its date, the period it describes and any assumptions. Then compare the new statement on the same basis.
A useful finding shows both passages and explains the possible conflict. If guidance has changed, the next question is when the company became aware and whether disclosure is required now. Waiting for the next scheduled results release may not satisfy the obligation. ASX Guidance Note 8.
Keep four habits
- Use the record. Find the relevant statement before drafting a reply. Check that it remains current rather than copying a stale answer.
- Reconcile the current set. Compare the release, presentation, FAQ and script before sign-off. Explain deliberate changes.
- State the coverage. Record the documents and dates examined. A three-document comparison cannot support a claim that the entire history has been checked.
- Keep the reasons. Record the decision and owner when a number changes, language is retired or a finding is rejected.
Where Diolog fits
Diolog’s disclosure-consistency workflow can help reviewers compare a draft with prior documents and inspect the findings. Ask which documents were included and how each source is shown; verify the scope in the current release.
The check supports the reviewer. It does not guarantee completeness, legal compliance or that ASX will not ask questions. A report with no findings means no issues were detected within the stated scope.
We check two recent announcements against your published record.