Australia’s New Merger Laws Are Now in Force: What Business Owners Need to Know

Australia’s New Merger Laws Are Now in Force: What Business Owners Need to Know

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Australia’s New Merger Laws Are Now in Force: What Business Owners Need to Know

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3 min read

10 Sep 2026

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    Key Takeaways
  • ࠂ
    Mandatory ACCC notification has applied since 1 January 2026 to acquisitions that meet the relevant thresholds and are not exempt.
  • ࠂ
    Further requirements for certain asset acquisitions and share acquisitions resulting in specified voting-power increases commenced on 1 April 2026. The voting-power requirements apply only where the general notification thresholds are also met.
  • ࠂ
    A notifiable acquisition cannot be completed until ACCC approval is obtained or a notification waiver is granted.
  • ࠂ
    The Phase 1 notification fee is $56,800 for 2026-27, while Phase 2 fees can be significantly higher.
  • ࠂ
    Early advice can help businesses work out whether notification is required and build realistic timing and costs into the deal.

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Australia’s merger laws changed significantly on 1 January 2026. For acquisitions that meet the notification thresholds, businesses must now notify the Australian Competition and Consumer Commission (ACCC) and obtain clearance before the deal can proceed.

Since the new regime began, further asset and voting-power thresholds have commenced and the ACCC has updated its guidance based on the first months of operation. If you are buying a business, shares or assets, merger clearance now needs to be considered early - not just before completion.

What’s Changed on 1 January 2026?

Australia moved from a largely voluntary merger clearance system to a mandatory regime. If an acquisition is within scope, meets a notification threshold and no exemption applies, the parties must notify the ACCC and wait for clearance before completing.

The rules apply broadly to acquisitions of shares and assets. They can also capture a series of smaller acquisitions over time.

New from 1 April 2026: asset and voting-power thresholds

The merger regime was expanded further on 1 April 2026, introducing additional notification requirements that businesses need to consider when assessing a proposed acquisition. These changes apply to:

  1. Certain asset acquisitions

Some acquisitions of assets that do not comprise all or substantially all of a business may now require notification where the relevant acquirer-revenue and transaction-value thresholds are met.

  1. Changes in voting power

Additional rules can apply to certain increases in voting power. The precise trigger differs according to the type of target entity, the acquirer’s existing voting power and whether the acquirer controls the target. For example, this can include an increase from 20% or less to more than 20% in an unlisted company that is not widely held, or an increase from more than 20% but less than 50% to 50% or more in a body corporate. Not every increase in voting power above 20% automatically requires notification.

Do You Need to Notify the ACCC?

The thresholds are not simply a single dollar test. The main tests are generally summarised below:

Threshold When it may apply Key figures
Large merged firm The combined Australian revenue of the parties is substantial and the target revenue or transaction-value limb is met. Combined Australian revenue of at least $200m AND the:·         target Australian revenue is at least $50m; OR·         global transaction value is at least $250m
Very large acquirer A very large Australian business acquires a smaller target. Acquirer group Australian revenue is at least $500m AND target Australian revenue is at least $10m
Serial acquisitions Relevant acquisitions during the preceding
3 years may be aggregated where they predominantly involve the same or substitutable goods or services.Note: The ACCC’s August 2026 FAQs confirm that qualifying acquisitions completed before 1 January 2026 may be counted but acquisitions with target Australian revenue below $2m are excluded.
Ordinary $200m combined-revenue or $500m acquirer-revenue limb must still be met (subject to exclusions).  That is the accumulated target Australian revenue is at least $50m (large merged firm) or $10m (very large acquirer).
Certain asset acquisitions From 1 April 2026, some asset acquisitions that are not all or substantially all of a business can be caught. Applies where the acquirer group has Australian revenue of at least $200m AND:·         global transaction value is at least $200m; OR·         Australian revenue is at least $500m AND global transaction value is at least $50m

Important: Where one or more of the notification thresholds above are met, notification is only required if the target is connected with Australia and no exemptions apply.  Meeting a monetary threshold is only part of the analysis.  Every transaction needs to be considered on its own facts. The Australian connection, exemptions, transaction structure, voting power and previous acquisitions may also matter. 

What about Exemptions?

Some transactions are exempt even if a threshold would otherwise be met. Exemptions cover particular land and financial-market transactions, internal restructures, acquisitions by external administrators and other specified arrangements.

The practical message? Do not assume a deal is outside the regime because it involves assets, a minority interest or a smaller target. Check the rules early.

The Application Process

For a transaction that may need ACCC clearance, the process can be viewed in four steps:

 

ACCC-Flow-Chart

Which Pathway Should You Use?

For straightforward transactions, the ACCC says the short notification form will be appropriate in most cases. A long form is more likely to be needed where there is greater competition risk or complexity.

A notification waiver may be available for a transaction that technically meets a threshold but clearly does not raise material competition or consumer concerns. If granted, the waiver removes the obligation to lodge a formal notification. A waiver application is not simply a preliminary step before a formal notification, and businesses should choose the pathway that best fits the transaction. If the ACCC does not decide a waiver application within 25 business days, it cannot grant the waiver and is considered a deemed refusal.

Pre-notification discussions are optional but can be useful for complex deals or where the information requirements are unclear. The FAQs also confirm that parties may be able to notify on the basis of a sufficiently developed Heads of Agreement rather than waiting for every transaction document to be finalised.

How long can the ACCC review take - and what does it cost?

Stage Timing What it means 2026-27 fee
Pre-notification discussion No set timeline Allows parties to provide draft notification application and transaction documents to identify if further information is needed.ACCC recommends parties initiate this process at least 2 weeks before formal notification for acquisitions that clearly do not raise material concerns.If no determination is made in 25 business days, the application will be deemed to be denied. $8,300
Phase 1 Up to 30 business days* Initial review of application lodged.  Most transactions are expected to be resolved here. Earliest approval is generally in
15 business days.  Merger will either be cleared in this phase or progress to Phase 2.
$56,800
Phase 2 Up to a further 90 business days* A deeper review where competition concerns require further assessment. At the end, the merger can be put into effect with or without conditions or be blocked by the ACCC. $475,000 to $1.595m (additional fee, depending on transaction value)
Public-benefit application
(where available)
50 business days* Optional application. Only available after the ACCC has either not approved the acquisition or approved it subject to conditions. Must be made within 21 calendar days after the relevant ACCC decision. $401,000

* Statutory periods can be extended or adjusted in certain circumstances or unilaterally varied by the ACCC.

One Timing Trap to Remember

ACCC approval does not always mean the transaction can complete immediately. There is generally a 14-calendar-day period after the ACCC publishes its reasons before completion can occur, allowing time for an application to the Australian Competition Tribunal. An approved acquisition generally also needs to be completed within 12 months of the ACCC’s decision.

What’s Happening in Practice

The ACCC’s half-year results give businesses some useful comfort. From 1 January to 30 June 2026, it received 145 merger notifications and 286 notification waiver applications. It approved 115 notifications in Phase 1, with 6 notifications progressed to Phase 2 for a more in-depth assessment.

The ACCC also reported that 92% of acquisitions were decided within 20 business days through either an early Phase 1 decision or a notification waiver. That is encouraging, but businesses still need to allow time before lodgement to assess thresholds, prepare the application and deal with information requests.

Four Things to do Before Your Next Acquisition

1. Check the ACCC notification rules early, while the deal structure and timetable are still being developed.

2. Look at the parties’ Australian revenue, transaction value and relevant acquisitions made during the previous 3 years and consider whether the April 2026 asset or voting-power rules apply.

3. Build ACCC timing, fees and the post-approval waiting period into the transaction documents and completion plan.

4. Get advice before assuming an exemption or notification waiver will apply.

The Bottom Line

The new merger regime is now part of doing deals in Australia. For many acquisitions, the ACCC process will be straightforward. But if notification is required, getting the timing or threshold analysis wrong can delay completion and add significant cost.

The best approach is to consider merger clearance at the start of the transaction, so you know what is required before the deal gathers momentum.

Planning an Acquisition? Talk to Us Early.

If you are buying a business, shares or assets, getting the ACCC analysis right from the outset can save time, cost and uncertainty later.

Our Hillhouse Corporate & Commercial team can help you assess whether notification is required, identify the right ACCC pathway and structure the transaction around a realistic approval and completion timetable.

Contact Vicki Yeung, Senior Associate or Malcolm Chan, Associate, to discuss your proposed acquisition before you commit to the deal timetable.

E: vicki@hillhouse.com.au or malcolm@hillhouse.com.au

P: 07 3220 1144

This article is general information only and reflects the position as at September 2026. It is not legal advice. Merger notification requirements are transaction-specific and may change.

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Proposed Testamentary Trust Tax Changes: Government Signals Further Change

Proposed Testamentary Trust Tax Changes: Government Signals Further Change

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Proposed Testamentary Trust Tax Changes: Government Signals Further Change

Author: Robert Lamb

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3 min read

23 Jun 2026

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    Key Takeaways
  • ࠂ
    Recent reports indicate the Government intends to revise its proposed testamentary trust tax changes, however the legislation has not yet been introduced or passed by Parliament.
  • ࠂ
    Testamentary trusts remain an important Estate Planning tool, with flexibility continuing to be a key feature of a well-structured Will.
  • ࠂ
    There is no need to make immediate changes based on media reports alone, but if you have concerns about your Estate Plan, now is an appropriate time to seek advice.

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When the Federal Budget was handed down in May, the Government announced a proposal to introduce a minimum 30% tax rate on income from discretionary trusts, including discretionary testamentary trusts established from 1 July 2028.

At the time, we shared in our recent Federal Budget Proposal article that the proposal represented a significant potential change to Estate Planning and that, importantly, the legislation had not yet been introduced or passed by Parliament.

Since then, the Government has indicated it intends to revise the proposal. It has been widely reported that discretionary testamentary trusts established for genuine Estate Planning purposes will no longer be subject to the proposed 30% minimum tax. Instead, the proposed minimum tax is expected to only apply where income from those trusts is distributed to a corporate beneficiary.

While this is welcome news for many Australians, it is important to remember that the proposed legislation has not yet been finalised or passed by Parliament. The detail of the final law, including any exclusions and how they will operate in practice, remains uncertain.

What does this mean for your Estate Plan?

Our advice remains largely unchanged.

Testamentary trusts continue to be an important Estate Planning tool. They can provide significant benefits including:

  • Asset protection
  • Flexibility in administering inheritances
  • Protection for vulnerable beneficiaries, and
  • Tax planning opportunities where appropriate

The recent developments reinforce the importance of building flexibility into Estate Planning rather than reacting to proposals that may ultimately change before becoming law.

Should you change your Will?

For most people, there is no immediate need to amend an existing Will solely because of these announcements.

However, if you have questions about how the proposed changes may affect your Estate Plan, or you are considering updating your Will for other reasons, now is an appropriate time to seek advice.

As the legislation is still being developed, we are not yet able to provide definitive advice on how the final laws will affect individual Estate Plans. Once the legislation is settled, we will be able to provide more specific recommendations where required.

We're here to help

Our Wills & Estates team is here to discuss the proposed changes and answer any questions you may have about your Estate Planning arrangements. To arrange a confidential discussion, please contact Robert Lamb, Tracy Pratt or our Wills & Estates team on (07) 3220 1144 or send our team an email via email@hillhouse.com.au.

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A Judgment Isn’t Enough: Can the Debtor Actually Pay?

A Judgment Isn’t Enough: Can the Debtor Actually Pay?

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A Judgment Isn’t Enough: Can the Debtor Actually Pay?

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3 min read

16 Jun 2026

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    Key Takeaways
  • ࠂ
    A judgment confirms that money is owed, but it does not guarantee payment.
  • ࠂ
    Before commencing, it is important to consider whether the debtor has assets or income that any judgment can be enforced against.
  • ࠂ
    Legal costs are only partly recoverable in most cases, and a costs order will rarely if ever cover all costs incurred.
  • ࠂ
    An effective debt recovery strategy considers both the strength of the claim and the likelihood of recovering the debt and your legal costs.

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Further to our previous article on the options available when chasing an unpaid invoice, one of the most important questions a creditor should ask before commencing legal proceedings is whether the debtor actually has the ability to pay. A successful court outcome is only part of the equation. The real issue is whether the debt can actually and practically be recovered.

Even where a creditor obtain judgment confirming that money is owed, payment is not automatic. If the debtor does not pay voluntarily, further enforcement action may be required to recover the money and your legal costs.

Judgement Is Not Recovery

It is understandable to assume that obtaining judgment means the matter is effectively over. However In reality, a judgment simply confirms that the debt is legally due.

If the debtor has no assets, no income, or no practical source of funds, enforcement may be futile for a host of reasons.

Therefore a strategic and cost-benefit analysis of the question even if we “win” the court case can the money ultimately be obtained should be undertaken before commencing court proceedings. Legal fees, court filing fees, and enforcement costs can quickly outweigh the amount in dispute, particularly if the debtor is potentially insolvent or difficult to locate.

Costs and Commerciality 

Legal costs are another important consideration.

You have to assume you will be out of pocket even if you “win” the case and the person pays.

Even if you are successful in a court case and obtain a costs order, those costs are usually assessed on a standard basis. This generally results in recovery of only about 50–60% of the actual legal fees actually incurred.

An indemnity costs order is more favourable but it is typically reserved for exceptional circumstances where the other party has acted unreasonably, improperly, or in a way that justifies a more significant costs order. Even in those cases, recovery may be closer to 70–80% of actual legal fees, and sometimes more depending on the circumstances.

Accordingly, the existence of a strong claim does not necessarily mean litigation is commercially worthwhile. The likely recovery outcome should always be weighed against the anticipated legal costs.

Assessing the Debtor's Position

Before commencing the debt recovery process or court proceeding, creditors should make reasonable enquiries into the debtor’s financial circumstances. Some practical steps include:

  • Conducting a land title search to determine whether the debtor owns real property;
  • Do a company search (if the debtor is a company) or a bankruptcy search (if the debtor is a natural person)
  • Identifying whether the debtor is employed, which may assist with enforcement through a redirection of earnings
  • Investigating whether any third parties owe money to the debtor, which may support a redirection of debts
  • Considering whether there are other assets, guarantees, or corporate structures that may improve recovery prospects

These enquiries can provide valuable insight into whether legal proceedings are likely to result in a meaningful recovery or whether the better commercial decision is to avoid further costs.

Enforcement After Judgment 

If the debtor still fails to pay after judgment, the law provides a number of enforcement options. These include enforcement warrants for seizure and sale of property, redirection of debts, and redirection of earnings, which can allow part of the debtor’s wages to be paid directly to the creditor.

In practice terms, a creditor may be able to enforce against property, redirect income at source, or recover money owed to the debtor by third parties.

However, all of these options depend on the debtor having assets, income or other recoverable funds available in the first place.

A statutory demand could also be issued against a Company debtor.

A Commercial Decision 

Sometimes the most commercially sensible decision is not to proceed if the debtor has little or no capacity to pay. Where there is no meaningful asset base, no employment, and no identifiable source of recovery, additional litigation may simply increase losses rather than improved the outcome.

That is why debt recovery should always be approached strategically. The key question is not simply whether judgment can be obtained, but whether it is likely to result in actual recovery.

A Measured Recovery Strategy 

A staged approach is often the most effective. Issue a demand first, assess the debtor’s financial position, and then decide whether proceedings are justified.

This approach helps ensure that legal action is supported by sound commercial judgment and that enforcement prospects are considered from the outset.

The law can provide a remedy, but it cannot guarantee payment. For creditors, the ultimate objective is not a judgment on paper, but money in hand.

How We Can Help 

If you are considering legal action to recover debt, our Litigation and Dispute Resolution team can help you assess both the strength of your claim and the practical prospects of recovery. Contact Hillhouse Legal Partners to discuss your circumstances and the most commercially sensible path forward.

Leaving Your Home to a Loved One: Understanding Life Interests and Rights to Reside

Leaving Your Home to a Loved One: Understanding Life Interests and Rights to Reside

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Leaving Your Home to a Loved One: Understanding Life Interests and Rights to Reside

Author: Tracy Pratt

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3 min read

9 Jun 2026

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  • ࠂ
    Understanding the distinction between a life interest and a right to reside under a Will is important, as each arrangement carries different legal rights and obligations.
  • ࠂ
    Life interests and rights to reside can delay the final administration of an estate and should be carefully considered as part of the estate planning process.
  • ࠂ
    An effective estate plan should align with your family's long-term needs while minimising potential legal, financial, and administrative complexities.

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When preparing a Will, many people want to ensure a loved one can continue living in the family home after they pass away while ultimately preserving the property for children or other beneficiaries.

A common way to achieve this is through either a life interest or a right to reside. These arrangements are often used in blended family situations, where a surviving spouse or partner is provided with housing security while the property is ultimately passed to the testator's children or other intended beneficiaries.

Although these terms are sometimes used interchangeably, they have very different legal consequences.

What is a Right to Reside?

A right to reside generally gives a person the personal right to live in a property for a specified period or for the remainder of their life, without receiving any ownership interest in the property.

In most cases, the occupant cannot sell, transfer or rent out the property. The property will usually remain in the name of the executor or trustee of the estate until the right to reside comes to an end.

A right to reside can be an effective option where the intention is simply to provide accommodation without granting broader rights over the property.

What is a Life Interest?

A life interest provides broader rights than a right to reside.

A person who receives a life interest (known as a life tenant) is entitled to use and enjoy the property for the duration of their lifetime. Depending on the terms of the Will, this may include the right to receive rental income from the property or, in some circumstances, the ability to sell the property and reinvest the proceeds.

A life interest can provide greater flexibility while still ensuring the property ultimately passes to the beneficiaries nominated under the Will.

Key Differences

While both arrangements allow a person to occupy a property, the rights and responsibilities attached to each can differ significantly.

Importantly, both a life interest and a right to reside can delay the final administration of an estate for many years. This may affect beneficiaries who are waiting to receive their entitlement and can create ongoing responsibilities for executors and trustees.

There may also be taxation, asset protection and aged care implications that should be carefully considered before either arrangement is included in a Will.

Practical Considerations

Careful drafting is essential to ensure your wishes are clearly expressed and can be effectively carried out.

A Will should address matters such as:

  • Who is responsible for council rates, insurance and utility costs
  • Who is responsible for maintenance and repairs
  • Whether the occupant can rent out the property
  • What happens if the occupant permanently leaves the property
  • What happens if the occupant moves into residential aged care
  • When and how the arrangement comes to an end

Addressing these issues upfront can help avoid uncertainty and minimise the risk of disputes after death.

The Risk of Poor Drafting 

Poorly drafted life interest or right to reside clauses can create significant conflict between the occupant and the residuary beneficiaries.

Disputes often arise regarding responsibility for expenses, maintenance obligations, the extent of the occupant's rights, or when the arrangement should terminate. These disputes can result in unnecessary legal costs, delays and emotional stress for families.

In some cases, Court intervention may be required to determine whether a clause creates a mere right of occupation or a true life interest.

Planning Ahead

A life interest or right to reside can be a valuable estate planning tool when structured appropriately. However, these arrangements should always be considered in the context of your broader estate plan, family circumstances and long-term objectives.

Careful planning and tailored legal advice can help ensure your Will provides certainty for your loved ones while minimising the potential for future disputes.

How Can We Help

If you are considering a life interest or right to reside in your Will, or would like to review your existing estate planning arrangements, our Wills & Estates team can assist. Contact our team at Hillhouse Legal Partners on (07) 3220 1144 to discuss your circumstances and the most appropriate approach for your estate planning needs.

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5 Things to Know About the AML/CTF Reforms from 1 July 2026

5 Things to Know About the AML/CTF Reforms from 1 July 2026

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5 Things to Know About the AML/CTF Reforms from 1 July 2026

Author: Craig Hong 

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3 min read

4 Jun 2026

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    Key Takeaways
  • ࠂ
    From 1 July 2026, professional service providers like Hillhouse Legal Partners will be legally required to verify client identity and conduct additional compliance checks.
  • ࠂ
    Clients may need to provide documents such as photo ID, company or trust records and information about the source of funds for certain transactions.
  • ࠂ
    These checks apply to everyone and are part of a broader effort to help prevent money laundering, fraud and financial crime in Australia.

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From 1 July 2026, major new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws will change how professional service providers, including law firms like Hillhouse Legal Partners, work with their clients across Australia.

For many people, this will mean providing more identification and information when working with lawyers, accountants, real estate agents and other advisers.

While the process may feel unfamiliar at first, these changes are designed to help protect Australia’s financial system, businesses and communities from criminal activity.

  1. More industries are now captured by the laws

Australia’s AML/CTF laws are expanding to include more industries and professions.

From 1 July 2026, these obligations will apply to businesses including:

  • Law firms like Hillhouse
  • Accounting firms
  • Real estate agencies
  • Trust and company service providers
  • Businesses involved in high-value transactions

These reforms will require firms to:

  • Verify client identity
  • Understand who owns or controls companies and trusts
  • Assess money laundering risks
  • Monitor certain transactions and activities
  • Report suspicious matters to AUSTRAC
  1. Clients will need to provide more information

From 1 July, Hillhouse clients may notice additional checks and requests for information when engaging our team for certain legal services and transactions.

Depending on the work involved, our team may request:

  • A passport or driver licence
  • Proof of address
  • Company, trust or SMSF documentation
  • Information about ownership or control of entities
  • Source of funds information for certain transactions

These checks will become a standard legal requirement across many industries and services.

Importantly, businesses and professional advisers, including law firms, may not be able to provide some services if the required information is not supplied.

  1. The laws are designed to target financial crime

AUSTRAC estimates more than $68 billion of crime-related money is laundered through Australia every year.

The reforms are designed to:

  • Help prevent organised crime and fraud
  • Reduce financial abuse and illegal activity
  • Protect businesses and consumers
  • Bring Australia in line with global AML standards

These laws are not aimed at everyday Australians doing the wrong thing.

They are designed to stop criminals from using legitimate businesses and professional services to move illegal money through the economy.

  1. The checks apply to everyone

Under the new laws, firms like Hillhouse will need to understand who they are acting for and assess whether certain transactions or arrangements present higher risks.

For example, where companies or trusts are involved, firms may need to identify the individuals who ultimately own or control those structures.

This does not mean there is a problem with a client or transaction.

The law requires firms to apply consistent checks across their client base.

  1. Hillhouse is preparing now to support clients

At Hillhouse Legal Partners, our team has been preparing for these reforms for some time to ensure we are ready to support our clients well before the changes commence.

Our focus is on making the process as practical, secure and straightforward as possible.

Hillhouse clients can expect:

  • Clear communication about what is required
  • Secure handling of personal information
  • Streamlined systems and processes
  • Support and guidance throughout the process

We understand these changes may raise questions for clients and businesses alike.

The Hillhouse team is here to help clients understand what the new obligations mean and how they may affect future transactions and engagements.

While the additional checks may feel like another layer of administration, they form part of a much broader effort to help protect Australia’s financial system and reduce financial crime.

For further guidance and information please visit www.austrac.gov.au.

If you have any questions please reach out to us at email@hillhouse.com.au

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