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Selected cases

Federal Court of Australia · [2026] FCA 490

ASIC v Nuix

A Federal Court case about IPO forecasts, ASX disclosure and why ASIC's claim against Nuix was dismissed.

Federal Court of Australia23 Apr 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • Disclosure decisions need evidence and process.
  • A Federal Court case about IPO forecasts, ASX disclosure and why ASIC's claim against Nuix was dismissed.

Use this to check

  • Assess disclosure questions at the time the decision is made, not with hindsight.
  • Keep board papers, draft announcements and forecast review notes in a disciplined evidence trail.
  • Investor updates should be checked against current data, assumptions and materiality thresholds.

Decision snapshot

  1. 1

    What happened

    • ASIC brought civil penalty proceedings against Nuix, an Australian investigative analytics software company, and its directors.
    • The case concerned Nuix's IPO prospectus forecasts, later ASX announcements that reaffirmed those forecasts, and an April 2021 announcement that downgraded FY21 revenue guidance.
    • ASIC alleged misleading conduct, continuous disclosure contraventions and related directors' duty breaches.
  2. 2

    What the court had to decide

    • The Court had to decide whether Nuix misled the market or breached continuous disclosure obligations in connection with forecast information, and whether directors breached section 180 if company contraventions were established.
  3. 3

    What the court decided

    • The Federal Court dismissed ASIC's claims.
    • The Court found no misleading conduct or continuous disclosure contravention by Nuix.
    • Because ASIC did not establish a contravention by Nuix, the directors' duty claims were also dismissed.

Practical impact

Practical read

  • Disclosure decisions need evidence and process.
  • Even where a regulator's case fails, the judgment shows why boards should document forecast reviews, draft announcements and the reasons information was or was not disclosed.

Useful next steps

  • Assess disclosure questions at the time the decision is made, not with hindsight.
  • Keep board papers, draft announcements and forecast review notes in a disciplined evidence trail.
  • Investor updates should be checked against current data, assumptions and materiality thresholds.
  • Keep one version-controlled pack for forecast assumptions, finance reviews and board decisions.
  • Record why information is preliminary, confidential or not yet sufficiently certain.

Practical read

Nuix is not a small-business case in size, but it is useful for founders, scaleups and boards because it shows how closely disclosure decisions can be tested after the fact. ASIC alleged that Nuix should have disclosed forecast information earlier and that its announcements or omissions were misleading.

The Court dismissed ASIC's case. A key theme was timing. The Court assessed the disclosure question from the position at the time, not with hindsight. It found that certain forecast information was preliminary, further analysis was required, confidentiality remained, and a reasonable person would not have expected disclosure at the earlier point ASIC alleged.

The practical lesson is not that businesses should delay bad news. It is that directors and executives need a documented process for financial forecasts, materiality calls and market statements. If the business is listed, raising capital or giving investor updates, the records around the decision can matter as much as the final announcement.

Checks to run

Key points

  • Keep one version-controlled pack for forecast assumptions, finance reviews and board decisions.
  • Record why information is preliminary, confidential or not yet sufficiently certain.
  • Review investor decks, ASX releases and shareholder updates against the latest internal numbers.
  • Minute who made the disclosure call and what information they had at the time.

Key takeaways

  • Assess disclosure questions at the time the decision is made, not with hindsight.
  • Keep board papers, draft announcements and forecast review notes in a disciplined evidence trail.
  • Investor updates should be checked against current data, assumptions and materiality thresholds.

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