Open your register and look at the top 20. A large part of it will sit behind nominee and custodian names: wrap platforms, custody accounts, nominee companies. In these cases, the registered holder is not the person who owns the shares or decides how they vote. These accounts effectively create a vacuum on the register; blocks of ownership and votes that sit beyond the reach of Investor Relations teams.
Take one custodial line, a single wrap platform account holding around nine million shares. To the Board, it is one entry. Inside it sit ten beneficial owners, and several of them trace back to the same adviser. Aggregated, that one adviser directs more than five million of the company’s shares, a fraction under half a per cent of the whole register. Those shares carry votes. Often, it is the adviser who decides whether they are voted for, and how.
The register tells you the name of a wrap platform. It does not tell you that the adviser exists. With the nominee account alone, engagement is blocked. Knowing who the adviser is enables Investor Relations teams to get to work.
What Prism Does
Prism is Relait’s nominee reporting for ASX-listed companies. It takes the data that comes back through the share register disclosure process and turns it into something you can act on.
Where disclosure permits, Prism identifies the beneficial owners behind nominee and custodian positions, as well as the investment managers or advisers connected to them. It aggregates those owners up to the person who actually directs the parcel, so the output is not a list of custodial names. It is the name of someone you can call.
Of course, there are some investment managers that are difficult to trace, and in those cases, Prism is honest about what it cannot see. Every identified holder is linked to its source, so you can see where the information came from, how much of the line is covered and what remains unresolved. Prism does not replace adviser judgment, IR relationships or market context. It gives the people doing that work a clearer picture of who is on the register.
Why this matters now
Although knowing who is behind the register is useful at any time, it is especially valuable at certain moments.
Before a General Meeting. Advised that platform money often does not vote at all, because nobody instructs it. The adviser is the instruction point. Knowing who they are, ahead of an AGM or a contested resolution, means you can engage the person who directs a block of votes you did not know was reachable.
Before a raise. One supportive adviser can place a parcel across a whole client book, and again at the next raise. Reaching that person is worth more than a dozen cold conversations with names on the register that turn out to be custodial shells.
There is a regulatory shift behind this too. The Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Act 2025 received Royal Assent in December 2025, with the substantial holding changes taking effect from December 2026 after a 12-month transition. It broadens who must disclose a substantial holding, bringing economic interests held through derivatives into scope, and it extends the tracing regime so that a wider group of people can be compelled to disclose who they are and who they act for. More of what sits behind your register will surface through disclosure, extending Prism’s reach further still.
Roger Hawkins, a partner at Pinsent Masons, has called it the most extensive change to Australian disclosure law since the Corporations Act itself was introduced 25 years ago. We’ll cover it in more detail in a future blog.
Why Prism
Our many conversations with ASX juniors and mid-caps have revealed that, historically, Nominee Traces and Beneficial Ownership Analyses have been treated like ad hoc projects, often with a multi-week turnaround. Deadlines are regularly missed, leaving Boards disappointed with out-of-date reports at their next meeting.
Prism has been built in an innovative way, where much of the process is underpinned by automated workflows, third-party integrations and smart AI data parsing to provide the following differentiated outcomes:
Layer 1 reporting in under 7 days, allowing Boards to reliably include this data in their monthly reporting cadence.
Multi-layer reporting, in which sub-nominees with significant holdings can themselves be analysed to provide a fuller picture of the register.
The data behind many international nominees is available.
Our insights tool identifies accumulation patterns across disparate accounts with common control to flag aggregated substantial holding risks.
‘Addressability’ for Investor Relations teams
The value shows up in what the team does next. Prism turns the holdings sitting behind nominee and custodian names into a working list: who directs the largest parcels, which of them the company has never spoken to and who to prioritise. Invite the adviser behind a large wrap position to the next briefing. Reconnect with a manager who has held quietly for a year. Line up the right conversations well in advance of the next raise or the AGM.
It also makes something measurable that used to be invisible. Once the holdings behind nominees are identified and mapped to the people who direct them, Investor Relations teams can set targets: what share of previously hidden holdings has had a direct engagement this quarter? A register that was a wall of custodian names becomes a number of shares the team works down, quarter by quarter.
See what Prism shows on your register
If a meaningful portion of your register is held in nominee and custodian accounts, this exercise should be a priority for your Investor Relations team.
Speak with Martin McGinty to walk through what Prism could show for your next register review, Board update or engagement programme.
