General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.
AustraliaExchange / tradingCustodyTransition — no-action to 30 Sep 2026
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General information only — not legal advice
CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.
Australia's licensing story runs on two tracks. Now: digital asset financial products (stablecoins, wrapped tokens, tokenised securities, some wallets per updated INFO 225) need an AFSL, with ASIC's sector-wide no-action position extended to 30 September 2026 for applications and notifications. From 9 April 2027 the DAF Act commences: Digital Asset Platforms and Tokenised Custody Platforms become financial products requiring an AFSL, with an application window from April to October 2027 under regulatory relief. AUSTRAC VASP registration is separate and additional.
Application process
1
Map your products to the two tracks
Digital asset financial products need an AFSL under existing law (updated INFO 225); platform and custody operations become licensable when the DAF Act commences 9 April 2027.
2
Use the no-action window
Apply for the AFSL (or notify ASIC for market/CS facility licences with a pre-lodgement meeting) by 30 September 2026 to stay within the extended no-action position.
3
Prepare responsible managers and proofs
Competence of responsible managers, financial resources and compliance arrangements are the core of ASIC's assessment.
4
AUSTRAC in parallel
VASP registration under the AML/CTF regime (shifted from the DCE framework on 31 March 2026) is separate from and additional to the AFSL.
5
DAF window if you are a platform
DAP/TCP operators apply between April and October 2027 and may continue operating under regulatory relief while ASIC reviews.
Ongoing obligations
Financial resources — base AFSL requirements (solvency, adequate resources) apply now; DAP/TCP-specific standards on liquidity and net tangible assets are under ASIC consultation.
Responsible managers — maintained competence and organisational requirements.
AUSTRAC AML/CTF — VASP registration, transaction reporting and the travel rule (in force since 2025-26 reforms).
Penalties — unlicensed conduct after the relevant deadlines carries penalties up to 10% of annual turnover.
Common rejection & delay reasons
Applying late in the window
Congestion toward 30 September 2026 — and later the 2027 window — is the predictable failure mode.
Treating AUSTRAC registration as sufficient
It is not: the AFSL and AUSTRAC obligations are parallel regimes.
Custody arrangements below the coming standards
DAP/TCP custody and financial-resource standards are in consultation — build to the proposals, not the current minimum.
What's changing
ASIC no-action position expires — AFSL applications or market/CS notifications due
30 September 2026· confirmed
DAF Act commences: DAPs and TCPs become licensable financial products
9 April 2027· confirmed
DAF AFSL application window (April–October 2027) under regulatory relief; custody and financial-resource standards under consultation
31 October 2027· confirmed
Frequently asked questions
At a glance
JurisdictionAustralia
RegulatorASIC (+ AUSTRAC for AML/CTF)
TypeAFS Licence — DAP/TCP authorisations
CapitalBase AFSL requirements; DAP/TCP standards in consultation
Application feeStandard ASIC AFSL application fees apply — pull the exact figure from the ASIC schedule at application.
Ongoing feesASIC industry funding levies and annual compliance costs.
Realistic timelineAFSL applications historically run around 6–12 months (industry estimate); expect congestion around the 30 September 2026 and 2027 windows.
Grace / transitionNo-action position extended to 30 Sep 2026 (from 30 Jun 2026); DAF Act commences 9 Apr 2027 with an Apr–Oct 2027 application window under regulatory relief.
PassportingNone
Last verified28 Jul 2026
Local presence
Australian entity or registered foreign company; responsible managers with demonstrated competence; local compliance arrangements.
This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.