Diggers, Dealers & Disclosure: ASX focus areas for mining companies

Each year, Diggers & Dealers provide listed mining companies with an opportunity to update the market on exploration success, project development milestones, corporate activity and capital requirements. It is one of the most important investor engagement forums on the Australian mining calendar and, with the Noosa Mining Conference held last week, forms part of a broader period of investor meetings, roadshows and financing discussions.

ASX's recently released Listed Entity Supervision Report 2026 provides a useful insight into how ASX's supervisory priorities are evolving ahead of this year's conference season.

While ASX is generally satisfied with disclosure practices in recent times, there are four observations from its recent report that we think are particularly relevant for listed mining companies preparing for Diggers & Dealers.

 

Ramping is increasingly about disclosure patterns, not individual announcements

ASX's focus on 'ramping' is not new. Ramping concerns generally arise where disclosure practices appear directed towards generating investor interest, supporting a share price or facilitating a capital raising, rather than informing the market of genuinely material developments.

More notable is how ASX intends to supervise it. Historically, many boards have focused on whether an individual announcement is defensible. The report suggests that, rather than looking for a single "gotcha" moment, ASX is increasingly interested in how a sequence of announcements appears when considered together. Factors that may inform the assessment include: timing, frequency, proximity to capital raisings, whether information is genuinely new and how sensitivity has been characterised when released on the platform. 

Companies will need to test whether their disclosure record, viewed as a whole, demonstrates disciplined market communication rather than an attempt to artificially manage market sentiment around their stock.

Given the proliferation of AI and data analytics, we expect ramping practices will become easier for regulators to detect going forward.

 

Investor decks need to be tested against ASX's FY27 mining disclosure focus areas

Investor presentations released by mining entities are public reports that must comply with Chapter 5 of the Listing Rules and the Joint Ore Reserves Committee (JORC) Code. ASX's review of mining sector presentations found that compliance could be improved and mining disclosure remains a focus area for FY27.

While we await the long-foreshadowed updates to the JORC Code, ASX has identified specific areas that regularly feature in Diggers presentations.  We suggest that companies releasing investor decks ahead of conference presentations consider these focus areas when finalizing their presentations.

Focus area	Practical takeaway
Visual results	Qualify visual observations and photographs appropriately. Do not present them as a substitute for compliant exploration results.
Isolated assays	Provide sufficient geological context. Avoid highlighting the strongest intercepts (eg in the headline of an announcement) if that does not fairly reflect the broader programme.
Historic and foreign results and estimates	Check whether verification, reconciliation or cautionary statements are required. Do not imply current confidence unless the technical basis supports it.
First-time disclosure of metal equivalents	Clearly disclose assumptions, recoveries, prices and metallurgical inputs. Review first-time use carefully before release.
Production targets, financial forecasts and non-qualifying estimates	Ensure assumptions are reasonable, disclosed and supported by underlying technical work. These disclosures can materially affect valuation and investor expectations. Do not include productions targets (and financial forecasts) in the headline of an announcement.
In-ground values	In-ground or ‘in situ’ financial valuations must not be reported in relation to Exploration Results, Mineral Resources or deposit size. The JORC Code treats such valuations as inherently unreliable.
Initial disclosure of exploration targets, exploration results, resources and reserves	Ensure first-time disclosures include the required ASX Listing Rule Chapter 5 and JORC information, Competent Person statement and relevant Table 1 disclosures.

 

Sensitivity classifications need to be driven by substance

ASX's focus areas extend beyond suboptimal disclosure. During the reporting period, ASX issued warning letters for entities classifying:

• announcements as price sensitive when ASX considered they were not; and 
• announcements as non-sensitive to avoid disclosure of material terms.

This means sensitivity assessments should be driven by the substance of the information rather than a desired market outcome. A routine operational update should not become 'price sensitive' because management hopes it will attract investor attention (the same ramping issues apply here), just as genuinely material information should not be classified as non-sensitive for transactional convenience.

 

Investor relations and promotion arrangements need careful review

ASX continues to focus on stock promotion arrangements. Identified concerns include insufficient disclosure of promotional arrangements, selective disclosure of material information with promoters before the market and promotional activity occurring close to capital raisings or other market transactions.

Diggers & Dealers frequently coincides with increased investor engagement activity. Companies utilising external investor relations firms, sponsored research, social media campaigns or other promotional initiatives should satisfy themselves that arrangements are appropriately disclosed, governance protocols are clear and material information is not being selectively disseminated.

 

How we can help 

If you would like to discuss these practical takeaways further and how they may impact your upcoming disclosures, please contact the team below.