Understanding ASIC RG 162: Your Monitoring Obligations

Regulatory Guide 162 (RG 162) is ASIC’s framework for how listed entities should handle their continuous disclosure obligations. If you’re a company secretary, CFO, or IR professional at an ASX-listed company, this is the document that defines what “good” looks like — and most companies aren’t meeting the standard.

What does RG 162 actually require?

At its core, RG 162 requires listed entities to have “appropriate systems and processes” to ensure they can identify and disclose material information promptly. That sounds straightforward, but the detail matters.

The guide expects companies to actively monitor for information that could be price-sensitive — including market rumours, media speculation, and unusual trading patterns. It’s not enough to wait for someone to tap you on the shoulder.

Where most companies fall short

The gap between what RG 162 expects and what most ASX-listed companies actually do is significant. Common shortfalls include:

• No systematic monitoring — Relying on ad-hoc Google alerts or manual forum checks instead of structured surveillance
• Ignoring retail channels — Monitoring institutional broker reports but not HotCopper, Reddit, or social media where retail narratives form
• Reactive only — Responding to ASX price queries after the fact rather than detecting unusual activity proactively
• No audit trail — No documented evidence of what was monitored, when, and what action was taken

The audit trail problem

When ASIC investigates a potential continuous disclosure breach, one of the first things they look at is whether the company had adequate monitoring systems in place. “We didn’t know” is not a defence if you should have known — and RG 162 makes clear what “should have known” means.

Having a documented, systematic monitoring process creates a defensible record. It shows the regulator that your company takes its obligations seriously and has the infrastructure to detect issues early.

Building a compliant monitoring framework

A monitoring framework that satisfies RG 162 should cover three areas:

1. Price and volume surveillance — Track your stock’s trading patterns against sector benchmarks and flag statistical anomalies
2. Media and social monitoring — Monitor all public channels where your company is discussed, including forums, news, and social media
3. Internal escalation protocols — Clear processes for when monitoring flags something that may require disclosure

Quarterback was built to meet the monitoring standard set by RG 162. It covers price surveillance, forum and media monitoring, and creates a timestamped audit trail of every alert and action — so when the regulator asks what you were doing, you have a clear answer.