Key Highlights

  • Bubs Australia responded to an ASX query letter dated 20 October 2026 about a late Appendix 3Y for Managing Director Joe Coote.
  • Shareholders approved 7,132,645 performance rights for Mr Coote at the 20 November 2025 annual general meeting; 91,522 were later cancelled.
  • The cancellation took place on 25 March 2026, yet the related Appendix 3Y was lodged only on 20 October 2026.
  • The company attributes the delay to an administrative oversight and calls it an isolated incident.

Bubs Australia Limited (ASX:BUB) has told ASX that a late change of director's interest notice was the result of an administrative oversight, in a response dated 23 October 2026 to a query letter issued by ASX on 20 October 2026. The notice, an Appendix 3Y for Chief Executive Officer and Managing Director Mr Joe Coote, was lodged on 20 October 2026.

How the Delay Arose

The company explained that shareholders approved the grant of 7,132,645 performance rights to Mr Coote at the annual general meeting held on 20 November 2025. The securities were issued on 21 November 2025 and disclosed in an Appendix 3G and an Appendix 3Y that month.

Certain conditions attached to the rights were not met, and 91,522 performance rights were cancelled on 25 March 2026. That cancellation was disclosed in an Appendix 3H lodged on 30 March 2026. Bubs said it had intended to lodge the matching Appendix 3Y at that time, but due to an administrative oversight it was not filed until 20 October 2026.

ASX noted that the change in Mr Coote's notifiable interest occurred on 25 March 2026 and that the notice appeared to be due by 1 April 2026. Its letter stated that Bubs may have breached Listing Rules 3.19A and/or 3.19B, and that Mr Coote may have breached section 205G of the Corporations Act 2001 (Cth).

Disclosure Arrangements Described

Asked what arrangements it has under Listing Rule 3.19B, the company said it has established procedures and controls to identify, prepare and lodge director interest disclosures within the required timeframe. It maintains a Securities Trading Policy requiring directors to obtain prior clearance before dealing in company securities. Directors are required to notify the Company Secretary promptly of changes in their notifiable interests, and directors' interests are a standing agenda item at Board meetings.

Why This Could Matter

The exchange sets out how the company describes its compliance framework and its view of the incident. Bubs said it considers the late lodgement an isolated incident and believes its existing arrangements are adequate and operating effectively. It said the episode does not reflect any deficiency in its disclosure procedures and that it will continue to monitor compliance with the ASX Listing Rules.

The Bottom Line

Bubs attributes the late Appendix 3Y to an oversight following the 25 March 2026 cancellation of 91,522 performance rights, and describes its trading policy, director notification requirements and Board agenda practices as the framework for compliance. The response was released with the authority of the Board.