ASIC Form RL31 Requires Liquidators to Notify of Inaccuracies in Lodged Returns Within Ten Business

Key Takeaways

• ASIC's Form RL31 is the mechanism registered liquidators must use to notify the regulator of inaccuracies in annual liquidator returns, annual administration returns, and end of administration returns.
• The notice must be lodged within ten business days of when the liquidator could reasonably be expected to be aware of the event, and late lodgement attracts fees.
• Compliance teams at firms that provide or rely on insolvency services should confirm that their processes can meet this deadline.
• The document is an existing form and guide, not a new rule, though it is presented as a press release dated 2026-09-16.

Deep Dive

ASIC's Form RL31 is the mechanism registered liquidators must use to notify the regulator of inaccuracies in annual liquidator returns, annual administration returns, and end of administration returns. The notice must be lodged within ten business days of when the liquidator could reasonably be expected to be aware of the event, and late lodgement attracts fees. Compliance teams at firms that provide or rely on insolvency services should confirm that their processes can meet this deadline. The document is an existing form and guide, not a new rule, though it is presented as a press release dated 2026-09-16.

The form covers three return types, and the liquidator ticks the relevant box. For each, the liquidator must provide the original document ID, the date of the event, the date the liquidator became aware of it, and a description of the inaccuracy. Annual administration returns and end of administration returns also require the company name and ACN. The form must be signed by the registered liquidator personally, and attachments must be signed by the same person. Attachments must use white A4 paper, dark blue or black ink, and numbered pages. The form is lodged by post to ASIC at PO Box 4000, Gippsland Mail Centre VIC 3841.

The key timeline is ten business days after the liquidator could reasonably be expected to be aware that the event occurred. This is an objective test, not purely a test of actual knowledge. Records of the date of the event and the date of awareness therefore carry evidentiary weight. Lodgement is free if made within the prescribed period. Late fees apply otherwise, as set out at www.asic.gov.au/forms. The form is dated 1 March 2017 and the guide 28 August 2020, so teams should check ASIC's website for the current version and fee schedule.

Recommended actions:
- Add RL31 and Form 492 to insolvency practice procedures, with a ten business day clock that starts when awareness is reasonably expected.
- Build quality assurance checks on return preparation to reduce the number of inaccuracies.
- Log inaccuracies, awareness dates, and lodgement dates to support audit and regulatory inquiries.
- Make sure the registered liquidator is available to sign, and verify the current form version before lodging.
- Handle the personal information in the form in line with ASIC's privacy policy and internal data handling standards.

The risk impact is moderate. Late or missed notifications mean fee exposure, potential regulatory scrutiny of the liquidator's conduct, and reputational harm. Repeated inaccuracies or late notices could indicate weak controls and may draw attention from ASIC as the regulator of registered liquidators.

Source: Australian Securities and Investments Commission