Fintech + payments + crypto
PSP licensing reform, CDR Action Initiation, stablecoin + crypto asset platform licensing, ePayments Code reform, Mandatory Payments System.
11
Obligations
2
Regulators
6
Recent enforcement
Regulators
Obligations (11)
- criticalCWLTHupcomingMajor banks must provide CDR Banking + Action Initiation (2026)
CDR Action Initiation lets accredited recipients initiate payments + actions on consumer behalf.
- highCWLTHcurrentConsumer Data Right (CDR) participant accreditation + compliance
Banking, energy and (soon) non-bank lending data sharing — accredited participants must comply with privacy safeguards.
- highCWLTHupcomingPayment Service Provider (PSP) licensing reform — implementation pending
Treasury reform of payments licensing to capture digital wallets + Buy Now Pay Later + stored value.
- highCWLTHcurrentComply with Stored Value Facility rules (banking exception)
SVF providers must operate within APRA + Treasury rules on purchased payment facility regulation.
- highCWLTHcurrentComply with CDR Banking (Open Banking) — major + non-major ADIs
Banking data holders must share consumer data with accredited recipients on consumer consent.
- highCWLTHupcomingCrypto Asset Secondary Service Provider (CASSPr) licensing reforms
Treasury consultation 2024 on bespoke crypto licensing — separate from AFSL.
- highCWLTHupcomingCrypto Asset Platform licensing (Treasury reforms 2024-2025)
Treasury scoping CASP regime for digital asset platforms.
- highCWLTHupcomingCrypto-Asset Reporting Framework (CARF) — implementation 2026-2027
AU adopts the OECD CARF for crypto reporting; reporting expected from 2027, first international exchange ~2028 (per Dec 2025 MYEFO).
- highCWLTHcurrentCDR Energy sector — phased
Energy retailers + distributors must share data via CDR.
- highCWLTHupcomingStablecoin payments licensing — Treasury reforms (in scoping)
Treasury reforms scoping payment stablecoin licensing under PSP regime.
- mediumCWLTHcurrentComply with the ePayments Code
Voluntary but industry-standard code covering electronic transaction terms, mistaken internet payments, and unauthorised transactions.
Recent enforcement
- accccivil penalty2025ACCC CDR enforcement progressing 2024-2025
ACCC + OAIC CDR enforcement progressed in 2024-2025 — first civil penalty proceedings + significant infringement notices.
- asiccivil penalty$15.0M2024ASIC v Binance Australia
ASIC alleged Binance Australia Derivatives misclassified 500+ retail clients as wholesale; failed AFSL retail client protections.
- acccreview2024ACCC CDR Banking compliance reviews 2024
Periodic ACCC + OAIC compliance reviews of CDR Banking data holders + accredited recipients.
- austraccivil penalty$4.0M2024AUSTRAC v Bell Financial Group
Bell Financial failed to conduct adequate enhanced customer due diligence on high-risk customers including those with PEP and adverse media flags.
- asiccivil penalty$350K2024ASIC v Block Earner (unlicensed crypto financial product)
Block Earner operated a crypto-asset 'Earner' product Federal Court found was a financial product requiring AFSL.
- asiccourt judgment2024ASIC v Finder Wallet (crypto financial product)
ASIC alleged Finder Wallet's Earn product was a financial product requiring AFSL — Federal Court ruled in Finder's favour.