The gap between AI disclosure and AI governance is now a regulatory and reputational liability. For listed companies and their IR teams, the time to get this right is before the query letter arrives.
The Numbers That Should Concern Every Board
In April 2026, The Conference Board published a finding that deserves far more attention than it received: the share of S&P 500 companies disclosing AI as a material risk has jumped from 12% in 2023 to 83% today. That is a sevenfold increase in less than three years.
What did not move in lockstep? Board expertise. In the same period, the proportion of S&P 500 directors disclosing AI expertise ticked up from 1.5% to 2.7%. Just 23% of surveyed executives consider their board "highly fluent" in AI. Fewer than 10% say their companies are fully prepared to comply with AI regulations.
The picture that emerges is striking. Companies are talking about AI risk in unprecedented volume, but the people responsible for overseeing that risk barely understand it.
Why the ASX Is Watching Closely
On the same week that data landed, Australia's own exchange regulator issued a pointed reminder to listed companies. Speaking at an Australian Shareholders' Association conference in Melbourne, ASX Chief Compliance Officer Lucinda McCann warned businesses not to exaggerate the impact of artificial intelligence on their operations. The ASX, she said, is monitoring the market for instances of "ramping" — using AI-related announcements to generate share price uplift that isn't substantiated by the underlying facts.
This is not a general housekeeping notice. It is a targeted signal. The ASX has seen enough AI-adjacent announcements to be concerned, and it is telling companies clearly: if you cannot demonstrate that AI claims have reasonable grounds, expect a query letter, a potential trading halt, and scrutiny of your directors.
For ASX-listed companies, the combination of these two data points — boards that lack AI fluency and a regulator that is watching AI disclosures closely — creates a specific kind of vulnerability that IR teams need to address now.
What "AI Disclosure" Actually Means in Practice
There is a meaningful difference between three things that often get conflated:
Disclosing AI as a risk to the business is now standard practice and essentially table stakes. Most boards have signed off on generic language about AI disrupting business models, creating cybersecurity exposure, or affecting workforce composition. This is largely checkbox compliance.
Disclosing AI as an opportunity — announcing partnerships, pilots, product integrations, or cost-saving programs tied to AI — is where the regulatory risk concentrates. These announcements are the ones the ASX is watching. Claims about AI-driven productivity gains, revenue growth, or competitive advantage need to be grounded in evidence and should have the same rigour applied to them as any other forward-looking statement.
Actually governing AI across the enterprise, with board-level accountability, documented policies, and audit trails, is where most listed companies are furthest behind. And it is this gap that creates the most significant long-term exposure.
When regulators and activist investors start asking hard questions about AI governance, the answer "we disclosed AI as a risk in our annual report" will not be sufficient.
The Investor Perspective Is Shifting
Investors are not naive about this dynamic. Institutional allocators have lived through enough technology cycles to know that companies announcing AI programs ahead of genuine capability are a reputational liability waiting to surface. The more sophisticated fund managers are starting to apply a simple test: does what management says about AI in investor communications match what the board can actually substantiate?
The Conference Board data makes clear that for the vast majority of listed companies globally, the honest answer is no. Disclosure has outpaced governance. Communication has outpaced understanding.
That is not a criticism of the companies themselves. AI is genuinely difficult to govern, the regulatory environment is still forming, and boards cannot develop expertise overnight. But the window for getting ahead of this has narrowed. Regulators on both sides of the Pacific have now signalled that substantiation matters. The question for IR teams is not whether to address this, but how.
What IR and Communications Teams Should Do Now
The practical response is not to strip AI language from investor communications. That would be an overcorrection, and frankly, it would be its own signal to markets. The response is to ensure that what companies say is defensible, specific, and traceable to board-level decisions.
A few principles worth building into process:
Audit what you have already said. Go back through the last 12 months of ASX announcements, investor presentations, earnings calls, and media releases. Where have claims been made about AI capability, cost savings, or strategic advantage? For each claim, can you identify the data, the project, or the board decision that substantiates it?
Match your disclosure to your governance. If you are talking about AI in investor communications, your board should be able to speak to it. That does not require every director to become a machine learning specialist. It does require a clear line of accountability, a named executive owner for AI strategy, and regular board reporting on progress against stated commitments.
Apply forward-looking statement discipline to AI claims. The same rigour applied to revenue guidance or capital expenditure forecasts should apply to AI-related projections. Vague language about "leveraging AI to unlock operational efficiencies" without underlying figures or timelines is exactly the kind of announcement that draws attention.
Build a coordinated narrative. IR and communications teams should be working from the same brief as the technology and strategy teams. An announcement drafted by communications without input from the people actually running AI programs is a compliance risk, not just a messaging issue.
The Broader Point
The acceleration of AI disclosure in corporate communications has happened faster than the governance infrastructure needed to support it. That gap is now visible to regulators, and it is becoming visible to investors.
For ASX-listed companies, the ASX warning is an opportunity as much as it is a caution. Companies that build genuine AI governance, communicate it clearly, and hold themselves to the same evidentiary standards they would apply to any other material claim will be in a stronger position when the scrutiny intensifies.
At ARC, we work with listed companies and their IR teams to build communications that are not just compelling but defensible. In 2026, those two things need to be the same thing.
Frequently Asked Questions
What is the ASX's position on AI disclosures? The ASX has warned listed companies against exaggerating the impact of AI on their operations to generate share price uplift. ASX Chief Compliance Officer Lucinda McCann confirmed in May 2026 that the exchange is actively monitoring AI-related announcements for "ramping" behaviour, and companies making forward-looking AI claims should ensure those claims have reasonable evidentiary grounds.
How widespread is AI risk disclosure among listed companies? In the S&P 500, 83% of companies now disclose AI as a material risk, up from 12% in 2023, according to The Conference Board's April 2026 report. While comparable ASX-wide data is not yet available, the trajectory is similar, and the regulatory environment in Australia is now moving in the same direction.
What should IR teams do if they have already made AI claims that lack clear substantiation? The priority is to assess each claim against available evidence and, where gaps exist, to work with internal stakeholders to either substantiate the claims or update market guidance. Proactive communication of refined AI strategy, properly supported, is generally better received than having a regulator surface the discrepancy.