Does Stablecoin payments licensing — Treasury reforms (in scoping) apply to businesses with 1–5 employees?

No (1–5 employees, turnover $100K–$1M).

Who must comply with Stablecoin payments licensing — Treasury reforms (in scoping)?

The applicability test for Stablecoin payments licensing — Treasury reforms (in scoping) (ASIC, Treasury, APRA and RBA), computed across 35 industries, 9 business structures and 6 size bands.

Short answer: Only if

Applies only if you issue a stablecoin or provide payment stablecoin services. Whether it applies turns on a fact that no industry, structure or size settles on its own.

What the obligation is

Treasury reforms scoping payment stablecoin licensing under PSP regime.

Treasury continuing payments licensing reform — payment stablecoin regulation under PSP regime + ADI carve-outs in scoping. Regulations expected 2025-2026.

The applicability test

Applies only if you issue a stablecoin or provide payment stablecoin services. Whether it applies turns on a fact that no industry, structure or size settles on its own.

How the regulator frames it: Stablecoin issuers + payment service providers.

What triggers it: Issuance or facilitation of stablecoin payment.

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 (35 of 35: no).

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

Business structure and size

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".

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.

Answers that bring it into scope

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 becomes worth checking, because it applies only if you issue a stablecoin or provide payment stablecoin services.

When you need to check further

The engine shows this obligation as "check whether this applies" when a business has crypto / DCE activity. It then applies only if you issue a stablecoin or provide payment stablecoin services. That fact is not something Rules Mate can infer from industry, structure or size.

What you must do, and when

When due: TBC — regulations expected 2025-2026.
Frequency: Ongoing
Evidence to keep: TBC — likely AFSL + AML/CTF + custody arrangements.
Status: Upcoming (not yet in force)
Priority: High

Penalty for not complying

No maximum penalty is recorded for this obligation in the Rules Mate corpus; check the regulator source below.

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.

Where it sits in the corpus

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 is an ongoing duty.

Regulator, legislation and tools

Regulated by Australian Securities and Investments Commission, Department of the Treasury, Australian Prudential Regulation Authority and Reserve Bank of Australia.

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

Treasury: Federal economic + financial policy; markets policy + revenue + corporate law.

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).

RBA: Central bank — monetary policy, banknotes, payments system regulation (via Payments System Board).

Free tools that help with this obligation:

Compliance calendar builder

Run the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.

Questions

Who must comply with Stablecoin payments licensing — Treasury reforms (in scoping)?: Applies only if you issue a stablecoin or provide payment stablecoin services. Whether it applies turns on a fact that no industry, structure or size settles on its own.
Does Stablecoin payments licensing — Treasury reforms (in scoping) apply to sole traders?: No. Across every industry and every size band, the engine's answer for a sole trader is: no.
Does Stablecoin payments licensing — Treasury reforms (in scoping) apply to businesses with 1–5 employees?: No (1–5 employees, turnover $100K–$1M).
When is "Stablecoin payments licensing — Treasury reforms (in scoping)" due?: TBC — regulations expected 2025-2026.

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.