Who must comply with Crypto Asset Secondary Service Provider (CASSPr) licensing reforms?

Treasury consultation 2024 on bespoke crypto licensing — separate from AFSL.

The licensing reform for crypto intermediaries is now law. The Corporations Amendment (Digital Assets Framework) Act 2026 received Royal Assent on 8 April 2026 and brings two new financial products into the Corporations Act: a digital asset platform (s 761GC), where an operator possesses digital tokens for or on behalf of clients, and a tokenised custody platform (s 761GD), where an operator holds a real-world asset and issues a single digital token that confers a right to redeem it. Operators therefore need an Australian financial services licence (AFSL) authorising those services. Schedule 1 commences the day after the 12 months beginning on Royal Assent, and a six-month transition period follows commencement. A business that applies to ASIC for the licence or variation during the transition period can keep operating until ASIC decides; one that does not apply is covered as soon as the transition period ends.

Applies when the business has crypto / DCE activity.

How the regulator frames it: Operators of digital asset platforms and tokenised custody platforms that hold digital tokens or underlying assets for clients (exchanges and custodial wallet providers, for example). Small platforms may rely on the s 911A(2)(ja) exemption only if no financial products are held, platform transactions in the last 12 months total no more than $10 million, each client's underlying assets do not exceed $5,000 in entry value, and the operator has lodged a notice with ASIC.

What triggers it: Providing a financial service in relation to a digital asset platform or tokenised custody platform on or after commencement of Schedule 1 to the Corporations Amendment (Digital Assets Framework) Act 2026.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Outcome across the 35 industries Rules Mate maps (35 of 35: no).

The answer is the same in every industry: no. Industry does not change who must comply.

Structure does not change the answer across all industries: for every structure the answer is "no".

Size does not change the answer across all industries: at every size band the answer is "no".

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

• Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires crypto / DCE activity.

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

• The business deals in crypto-assets or runs a digital currency exchange: it then applies (deals in crypto / digital currency exchange).

When due

Schedule 1 commences on the day after the 12-month period beginning on Royal Assent (8 April 2026). Apply for a new AFSL, or a variation of an existing AFSL, within the six-month transition period that starts on commencement to keep operating while ASIC decides.

Frequency

Ongoing

Evidence to keep

Assessment of whether each product is a digital asset platform or tokenised custody platform; AFSL application or variation lodged within the transition period; for small-scale operators, the ASIC exemption notice and monitoring of the $10 million and $5,000 limits; custody, client-asset and platform-rules documentation.

Status

Upcoming (not yet in force)

Priority

High

Maximum penalty: Providing a financial service without the required AFSL contravenes Corporations Act s 911A; s 911A(5B) is a civil penalty provision. Under s 1317G the maximum civil penalty is the greater of 5,000 penalty units ($1.82M) or three times the benefit for an individual, and for a body corporate the greatest of 50,000 penalty units ($18.2M), three times the benefit, or 10% of annual turnover capped at 2.5 million penalty units.

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

If this obligation applies to you, so do these 2: the engine uses the same rule for each.

• Crypto-Asset Reporting Framework (CARF) — implementation 2026-2027
• Crypto Asset Platform licensing (Treasury reforms 2024-2025)

• Stablecoin payments licensing — Treasury reforms (in scoping): Treasury reforms scoping payment stablecoin licensing under PSP regime.

Rules Mate tracks 4 published obligations tagged "crypto", 0 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated high priority and carries criminal liability, and is an ongoing duty.

Regulated by Australian Securities and Investments Commission.

ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).

• Australian Securities and Investments Commission

Free tools that help with this obligation:

• Compliance calendar builder