Importing Joint and Non-Beneficial Shareholdings from ASIC
Most ASIC company extracts import cleanly. Two situations need a little understanding because ASIC records them in a way that doesn't map one-to-one onto how StructureGram models ownership: joint shareholdings (two or more people holding the same parcel) and non-beneficial shareholdings (shares held on behalf of someone else, usually via a trust). This page explains what StructureGram does with them and what to check on the review screen.
If you want the underlying concepts first, see Joint Holdings and Non-Beneficial Ownership and Trusts. This page is about the import of those things specifically.
Why these are tricky
ASIC's "Shares Held" (or "Members") section lists each shareholding as a row. Two columns matter here:
- The holder name. ASIC often puts multiple people in a single name field — e.g.
ROBERT CAMERON & JACQUELINE HOOPER. That's one row in ASIC, but two people in reality. - The "Beneficially Owned" column.
Yesmeans the registered holder owns the shares for their own benefit.Nomeans they hold them for someone else — almost always signalling a trust sitting behind the registered holder.
StructureGram models ownership by substance, not just by what's on the register:
- A joint holding becomes a single joint-holding parcel that the holders own together, rather than two unrelated shareholdings.
- A non-beneficial holding usually becomes a trust interposed between the registered holder and the company:
Holder → Trust → Company, where the holder is a trustee.
The import has to bridge ASIC's flat rows to this richer model. Most of the work happens automatically; the review screen is where you confirm or adjust.
What StructureGram does on import
When you import an ASIC extract, the system classifies every shareholding row into one of three places, and surfaces each on its own review tab:
| ASIC row | Becomes | Review tab |
|---|---|---|
| Single holder, beneficially owned | A direct shareholder relationship | Direct shareholdings |
| Joint holders, beneficially owned | A joint-holding parcel | Joint shareholdings |
| Single OR joint holder, not beneficially owned | A non-beneficial holding (trust interposition by default) | Non-beneficial shareholdings |
A row appears on exactly one tab — never two. This means the decision you make for a shareholding lives in one place, with no risk of conflicting choices on different tabs.
Joint holders are split automatically
When ASIC packs two people into one name field (A & B, A && B, or A AND B), StructureGram splits them into separate individual entities and groups them into a joint holding. It also detects joint holdings that ASIC didn't label as joint but which clearly are — for example, two separate rows with identical share class, share count, and residential address are inferred to be the same joint parcel.
Non-beneficial holders get a trust by default
When a row is marked "Beneficially Owned: No", StructureGram defaults to interposing a trust — creating a placeholder "Holding Trust", making the registered holder(s) trustees of it, and giving the trust the shareholding. You can change this on the review screen (see below).
Where the extract comes from
The same review handles both ways an extract reaches StructureGram:
- A PDF you upload, from the Import Hub. The document's text is read where it has a text layer, and scanned where it does not.
- ASIC Direct Feed, ordered inside StructureGram. The data arrives structured from ASIC rather than as a document, so there is nothing to read off a page.
Everything below applies to both. Two differences are worth knowing: a Direct Feed extract asks none of the questions described further down, because there is no document to read and so nothing for two readings to disagree about, and ordering one requires purchase billing to be set up. The structural checks still run either way. See How to Import a Company Directly from ASIC.
Reviewing the import
The review follows the data model in seven steps:
- Companies — identify the primary company and any other companies involved with it. The other companies are separate entities, not additional primary companies; their shareholdings are reviewed later under Direct, Joint, or Non-beneficial shareholdings. Choose Create, Link, or Skip. Company details can be corrected before import.
- Individuals — identify each person once, regardless of whether they later hold shares, act as an officeholder, or both.
- Direct shareholdings — review beneficially-held parcels with one registered holder.
- Joint shareholdings — review parcels held by two or more registered holders.
- Non-beneficial shareholdings — resolve the trust or nominee treatment.
- Former shareholders — decide what happens to each holding the extract lists under Previous Members.
- Roles — review directors, secretaries, and other officeholder roles.
Every shareholding step shows the share class, number of shares, paid status, and whether the parcel is beneficially held. Use Edit shareholding details when an extracted value needs correction.
The Non-beneficial shareholdings tab
Each non-beneficial shareholding gives you three choices:
- Interpose trust (default) — insert a trust between the holder and the company. You can use a placeholder trust, link to an existing trust, or create a new named trust.
- Change to beneficially owned — you disagree with ASIC's flag; there's no trust, the registered holder is the real owner. The shareholding is created directly (a single shareholder edge, or a joint parcel if there are multiple holders).
- Skip — don't import this shareholding at all.
The Joint shareholdings tab
Each detected joint holding shows the grouped holders and the parcel they'll create. You can edit its share details, import it, or skip it. Joints inferred from matching addresses are flagged for you to review, since the inference is a best guess.
The Direct shareholdings tab
This shows beneficially-held parcels with one registered holder. The holder can be an individual or a company identified in the first two steps. Direct shareholdings are separate from officeholder roles, so a director who does not own shares is not presented as a shareholder.
The Former shareholders tab
An ASIC extract lists former members as well as current ones. This step decides what each of those rows means for your data. It is not the only step that can change what you already hold: wherever the extract says a holding or a role ended, the relevant step offers Cease and writes a cease date to the existing record.
Most rows offer three outcomes:
- Cease an existing holding — StructureGram already has this holding open, and the extract says it ended. Pick the holding and give the date it ceased. The badge reads Will cease, and the holding gets that cease date when the import runs.
- Import it as a former holding — you do not have the holding at all. It is created with a start date, if the extract gives one, and the cease date you supply. The badge reads Will be imported.
- Leave StructureGram as it is — nothing is created and nothing is changed. The row is still kept in the company's ASIC history. The badge reads Kept in history.
Not every row offers all three. A holding the extract also lists as current offers none of them, because nothing ended. A former holding with more than one holder, or one whose joint holders could not be told apart, cannot be imported with dates, so it is kept in the history instead.
A cease date is required before the import can run, for both of the first two outcomes. Until you supply one the row shows Needs a cease date and the Execute Import button stays disabled. Where the extract's own ending document gives a date, it is filled in for you, and a deregistered company defaults every member to the deregistration date.
Some rows ask you for more:
- Choose the holder — the extract names the holder in a capacity, such as "as executor of" an estate, so StructureGram will not invent a person from that label. Pick the person or company it refers to, or leave StructureGram as it is.
- Possible match — more than one existing holding could be the one that ended, so the choice is yours rather than a guess.
- Still a member — the extract lists this holding as current as well, so nothing ended. It is kept in the history only.
- Holder is skipped — the holder you chose is skipped or merged elsewhere in this import. Choose another holder, or leave StructureGram as it is.
The Roles tab
This shows directors, secretaries, and other officeholder roles. Shareholdings are reviewed in their own steps and do not appear here.
Questions the review asks
Where the extract is unclear and no rule settles it, the review asks you rather than guessing. A question appears at the top of the review with the reading it is unsure about, and the import waits until you have answered or confirmed each one. Two kinds are common:
- Two readings of the same company number or date disagree, because the page's text and the scan of it do not match.
- A holder cannot be identified with confidence from what the extract prints.
Separately, some notices ask nothing and simply record what happened, so they do not hold the import. One you may meet: the scan listed a holder that the extract's own Previous Members section does not print, so that row was not imported.
When anything is still outstanding, the foot of the review shows how many decisions remain, which step they are on, and what each step wants. Execute Import stays disabled until the count reaches zero.
How the four combinations import
| Beneficially owned | Not beneficially owned | |
|---|---|---|
| Single holder | Direct Holder → Company shareholding | Default: Holder → Trust → Company (holder is trustee). Or correct-to-beneficial → direct shareholding. |
| Joint holders | One joint-holding parcel: [Holders] → Company | Default: [Holders] → Trust → Company (all holders are trustees of one trust). Or correct-to-beneficial → joint parcel. |
This works whether the holder is an individual or a company. A company can be a trustee of an interposed trust (e.g. a corporate trustee), and a company can be a joint holder.
Re-importing the same extract
If you import the same ASIC extract a second time — to pick up changes, or after refreshing the file — StructureGram tries to avoid creating duplicates:
- Entities (the company, individuals, company shareholders) are matched against what already exists. Exact matches link automatically; likely-but-not-certain matches ask you to choose Link or Create.
- Non-beneficial chains are recognised: if a
Company → Trust → Holderschain already exists from a prior import, the matching non-beneficial holding defaults to Skip with an "Already imported" badge, so you don't create a second holding trust. - Holdings and roles that ended since the first import are matched to what you already have, and a notice above the steps says how many relationships will cease. Those rows stay visible in their own step even when historical relationships are hidden, so you can see exactly what is about to change. Choose Skip on any row you do not want updated.
- Holdings that already carry the same cease date are left alone rather than ceased twice.
The re-import duplicate detection for trusts only works once the company and all holders are linked to their existing entities. If you choose "Create" for any of them, the chain can't be matched — so link them and the dedup will recognise the existing trust.
Share classes: matching scanned classes to existing ones
ASIC records share classes with terse codes — most often ORD for ordinary shares, and codes like A, PREF, or RED. A company you already have in StructureGram often uses the plain-English form — Ordinary Shares, Preference. Left unchecked, importing ORD onto a company that already has Ordinary Shares would create a second, duplicate class and split the ownership figures.
When you import into an existing (linked) company, StructureGram reconciles the two:
- Standard ASIC codes are recognised as the same class.
ORD↔Ordinary↔Ordinary Sharesare treated as one class; likewisePREF/Preference,RED/Redeemable, and the code/label pattern (A↔A Class↔Class A). The scanned holdings attach to your existing class instead of creating a duplicate. - The company review shows a "Share classes" panel listing each scanned class and how it will resolve — "links to Ordinary Shares" for a recognised match, or "new class" otherwise. Each row has a Link / Create control so you can override the default.
- Close-but-not-certain names are suggested, not merged. If a scanned class merely looks similar to an existing one (a typo, say), StructureGram shows it as a suggestion with a one-click Link — it never silently merges classes. Genuinely distinct classes such as
OrdinaryandOrdinary Aare kept separate.
For a new company (Create, not Link) there are no existing classes to match against, so classes import exactly as scanned.
The same recognition applies when you add or rename a class by hand — StructureGram won't let a new ORD sit alongside an existing Ordinary Shares.
Edge cases worth knowing
Joint holders merged into one record. Occasionally the extraction reads ROBERT CAMERON & JACQUELINE HOOPER as a single person named "Robert Cameron & Jacqueline" with surname "Hooper". StructureGram has a recovery step that detects the &/and inside a name field and splits it back into two people. If you ever see a single individual whose name still contains "&", flag it — but in practice the recovery handles it.
Company shareholders. A company holding shares non-beneficially is unusual but valid (it's acting as a corporate trustee or nominee). It imports the same way as an individual non-beneficial holder — a trust is interposed with the company as trustee. If you believe the company really is the beneficial owner, use "Change to beneficially owned".
The "Beneficially Owned" column can be misread. This column sits next to "Fully Paid" in the ASIC layout, and both are Yes/No. If you notice a shareholding classified as non-beneficial that you know is beneficial (or vice-versa), use the review controls to correct it — the import respects your decision over the extracted flag, and records that you overrode the source.
Historical shareholdings. Ended roles and holdings are hidden by default; turn on Historical relationships to review them alongside the current ones. Members the extract lists under Previous Members are not hidden by that switch: they always get their own Former shareholders step, because they may change data you already have.
Troubleshooting
A shareholder I expected isn't on the Direct shareholdings tab. If it is a joint or non-beneficial shareholding, check Joint shareholdings or Non-beneficial shareholdings. Each shareholding lives in exactly one step.
On the diagram, a shareholder became a "Holding Trust" instead of a direct shareholder. That shareholding was marked "Beneficially Owned: No" in the ASIC extract, so StructureGram interposed a trust by default. If there's genuinely no trust, re-run the import (or edit) and choose "Change to beneficially owned" for that holding.
Re-import created a second "Holding Trust" instead of reusing the first. The trust dedup needs the company and every holder linked to their existing entities. If any defaulted to "Create", the existing chain couldn't be matched. Link them and the dedup will find the existing trust and default to Skip.
The review says a number of decisions are needed, but I cannot see what is missing. The message at the foot of the review names each step with something outstanding, and the step's tab carries a count. The commonest causes are a duplicate person waiting on Create or Link, and a former shareholding without a cease date.
"Ceased relationships could not be checked." The check that compares the extract's ended holdings against your data did not complete. If the message asks you to reload the review, do that: it means the review's own state was refused and trying again would send the same thing. If it offers Retry, the request simply failed and retrying is worth it.
"StructureGram changed since you reviewed." Someone or something altered the data this review was based on after you loaded it, so the import stopped rather than applying decisions to a world that had moved. Reload the review and check the affected holding before importing again.
Two people who jointly hold shares were imported as two separate shareholdings. ASIC didn't label them as joint and they didn't match on address, so the inference didn't fire. You can model them as a joint holding manually after import — see Joint Holdings.
The trust StructureGram created has a generic placeholder name.
The default name is {Company} Holding Trust. Rename it to the real trust name once you know it — the re-import dedup matches on the relationship structure, not the name, so renaming won't break future imports.
After import the company shows both ORD and Ordinary Shares.
This can only happen if the ASIC company was Created rather than Linked to the existing company (class matching runs on the link path). Re-run the import and Link the company, or merge the duplicate class from the company's share-capital screen.
A scanned class linked to the wrong existing class. On the company review, open the Share classes panel and switch that row from Link to Create (or Link it to the correct class). Your choice overrides the automatic match.
Best Practice
- Link existing entities before deciding joint/non-beneficial actions. The trust dedup, the "existing trust" picker, and accurate duplicate detection all work better once the company and holders are linked.
- Treat "Beneficially Owned: No" as a strong hint, not gospel. It usually means a trust — but sometimes it's a nominee with no formal trust deed. Use "Change to beneficially owned" when you have evidence the registered holder is the substantive owner.
- Check each step before importing. The summary counts show how many companies, individuals, shareholdings, and roles were extracted. Review Direct, Joint, and Non-beneficial shareholdings to confirm the ownership structure matches your understanding of the company.
- Give every former shareholding a cease date you can defend. Where the extract's ending document supplies one it is filled in for you; where it does not, the date is yours to supply, and it is the date the holding is recorded as ending.
- Rename placeholder trusts promptly. Future-you will thank present-you for replacing "Acme Pty Ltd Holding Trust" with the trust's actual name.
- Glance at the Share classes panel when linking to an existing company. Confirm that scanned codes like
ORDare linking to your existingOrdinary Sharesrather than creating a new class — the default is usually right, but it's a two-second check that keeps ownership figures clean.
Related Topics
- Joint Holdings — the concept and how to model joint parcels.
- Non-Beneficial Ownership and Trusts — why trusts are interposed and how legal vs beneficial ownership differs.
- Data Importing — all import sources.
- Trust Entities — managing the trusts that get created.