I must be confused as I thought you had to disclose any movement...

I must be confused as I thought you had to disclose any movement in percentage that is greater than 1% from the last notice. The previous notice was for a holding of 9183358 dated 27 July 2018. which was 7.79%. In fact, the seller actually bought more shares so that at the end of their term as director they disclosed on 4 February 2019 holding 9913382 shares or 8.34%. However, on 30 June 2019, the annual financial statements show that the substantial holder held 8253068 shares or 6.93% so still within a 1% movement of the last substantial holder notice issued. So no change was required. However, when this ceasing to be a substantial holder disclosure was made recently it reveals that there was a sale of 200,000 shares on 16 July 2019 which in fact would have pushed it very close to the 1% ( we don't have a detail of sales from resignation of director to the 16 July 2019 but they were indirectly disclosed in the AFS. However, the next few transactions up to 31 July 2019 would have made it a movement of more than 1% and certainly on today's disclosure by 20 August 2019 a total of 1.69 million shares had been sold from 1 July 2019 to 20 August 2019 and that is substantially more than 1% of the 119 million in issue. These sales are recorded in the notice ceasing to be a substantial holder. Again no change of shareholding notice was lodged at the end of August or if a mistake was made the end of October.

Having read the ASX rules it appears that the holder is responsible for submitting changes when required.