Who must comply with Payment Service Provider (PSP) licensing reform — implementation pending?
The applicability test for Payment Service Provider (PSP) licensing reform — implementation pending (APRA and ASIC), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Only if
Applies only if you provide payment or stored-value facilities. Whether it applies turns on a fact that no industry, structure or size settles on its own.
What the obligation is
Treasury reform of payments licensing to capture digital wallets + Buy Now Pay Later + stored value.
Federal Treasury's payments licensing reform package (Strategic Plan for Australia's Payments System, 2023) introduces a tiered PSP licensing framework. Expected to capture digital wallets, stored value facilities + non-bank payment service providers. Final regulations expected 2025-2026.
The applicability test
Applies only if you provide payment or stored-value facilities. Whether it applies turns on a fact that no industry, structure or size settles on its own.
How the regulator frames it: Non-bank payment service providers offering captured services.
What triggers it: Final regulations and commencement (TBD 2025-2026).
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (1 of 35: only if a further fact applies; 34 of 35: no).
| Industry | Answer |
|---|---|
| Fintech (non-bank) | Only if a further fact applies |
| No | 34 other industries |
Business structure and size
Structure does not change the answer in fintech (non-bank): for every structure the answer is "only if a further fact applies".
Size does not change the answer in fintech (non-bank): at every size band the answer is "only if a further fact applies".
Worked examples
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 a trigger outside this questionnaire.
- Pty Ltd company in fintech (non-bank) with 6–19 employees, turnover $1M–$3M: check whether it applies. applies only if you provide payment or stored-value facilities.
When you need to check further
The engine shows this obligation as "check whether this applies" when a business has industry: Fintech (non-bank). It then applies only if you provide payment or stored-value facilities. That fact is not something Rules Mate can infer from industry, structure or size.
What you must do, and when
- When due
- TBD; transition period likely.
- Frequency
- Ongoing
- Evidence to keep
- Licence application; consumer protection compliance plan; AML/CTF + privacy alignment.
- Status
- Upcoming (not yet in force)
- Priority
- High
Penalty for not complying
Maximum penalty: Operating without licence will attract NCCP-equivalent civil + criminal penalties.
Criminal liability
Audit or assurance level
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.
Obligations with the same applicability test
If this obligation applies to you, so does this one: the engine uses the same rule for each.
Where it sits in the corpus
Rules Mate tracks 5 published obligations tagged "payments", 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.
Regulator, legislation and tools
Regulated by Australian Prudential Regulation Authority and Australian Securities and Investments Commission.
APRA: Prudential regulator of banks (ADIs), insurers (general, life, private health), and superannuation funds. Sets and enforces CPS standards including CPS 234 (information security) and CPS 230 (operational risk).
ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).
Free tools that help with this obligation:
Questions
- Who must comply with Payment Service Provider (PSP) licensing reform — implementation pending?
- Applies only if you provide payment or stored-value facilities. Whether it applies turns on a fact that no industry, structure or size settles on its own.
- Does Payment Service Provider (PSP) licensing reform — implementation pending apply to sole traders?
- Only if a further fact applies. Looking in fintech (non-bank) and every size band, the engine's answer for a sole trader is: only if a further fact applies.
- Does Payment Service Provider (PSP) licensing reform — implementation pending apply to businesses with 1–5 employees?
- Only if a further fact applies (1–5 employees, turnover $100K–$1M).
- When is "Payment Service Provider (PSP) licensing reform — implementation pending" due?
- TBD; transition period likely.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.