Late Filing of Director Interest Notice Highlights Domino’s Compliance Gap

Background to the Disclosure Delay

Domino’s Pizza Enterprises Limited (ASX, DMP) recently responded to an ASX query concerning the delayed lodgement of an Appendix 3Y notice. The notice, which details changes in director Tony Peake’s shareholdings, was lodged on July 25, 2025, several months after the relevant transaction date of February 28, 2025. The ASX raised concerns that this delay may have breached key listing rules governing timely disclosure of director interests.

Company’s Explanation and Compliance Framework

In its formal response, Domino’s attributed the late filing to an inadvertent administrative oversight. The company emphasized that it has robust arrangements in place to ensure directors disclose changes in their interests promptly, including agreements with directors and notifications from its share registry. Domino’s stated that directors are aware of their disclosure obligations and that the company enforces these procedures diligently.

Regulatory Implications and ASX Concerns

The ASX’s letter highlighted potential breaches of Listing Rules 3.19A and 3.19B, which require entities to disclose director interests within five business days of a change. The delay also raised questions about compliance with section 205G of the Corporations Act, which governs insider trading and disclosure. While Domino’s acknowledged the late lodgement, it maintained that the oversight was isolated and that the company was aware of the transaction within the prescribed timeframe.

Market and Governance Perspectives

Timely disclosure of director interests is a cornerstone of market transparency and investor confidence. Although this incident appears to be procedural rather than indicative of deeper governance issues, it underscores the challenges companies face in maintaining flawless compliance. Investors and regulators alike will be watching closely to see how Domino’s reinforces its internal controls to prevent recurrence.

Looking Ahead

Domino’s has committed to enforcing its existing arrangements and ensuring future disclosures meet ASX requirements. The company’s response will likely satisfy immediate regulatory concerns, but the episode serves as a reminder of the importance of meticulous compliance in an environment of heightened scrutiny.