Australia

Licensing, Authorisation & Market Access

ASIC's sector-wide no-action position for digital-asset businesses expired on 30 September 2026. Businesses that had been relying on that position to continue operating without an Australian Financial Services licence were required to have applied for, or varied, an AFS licence by that date; those that had not done so now risk operating in breach of financial services law. The no-action position had functioned as a transitional accommodation while firms brought their licensing status into line with standard AFS licensing requirements, and its lapse closes that transitional window for the sector.

No primary-source figures on how many firms met the deadline, or on any post-deadline enforcement action taken against firms that did not, were available this cycle. The practical effect on market access is accordingly a matter of the deadline itself having passed rather than of its enforcement outcome being observable yet.

Outlook

The immediate question is whether ASIC follows the lapsed no-action position with visible enforcement against firms that continued operating without having applied for or varied a licence. A separate line of reform — the status and commencement timing of broader activity-based AFSL changes for payments and digital-asset firms — remains unverified from an accessible primary source and is not addressed here pending confirmation.

Licensing, Authorisation & Market Access

Australia's payments-licensing perimeter is being fundamentally rebuilt through the Payments System Modernisation reform programme. Treasury released Tranche 1 exposure-draft legislation on 12 March 2026, building on an October 2025 Tranche 1a consultation, with the exposure-draft consultation itself closing 9 April 2026. The structural centrepiece of this reform is the repeal of the Purchased Payment Facility regime, which has governed non-bank stored-value products for over two decades, and its replacement with an activity-based Australian Financial Services Licence framework. Under the new framework, stored-value-facility providers, remitters, merchant acquirers and payment facilitators will all fall within the AFSL licensing perimeter, representing a substantial broadening of the categories of payment business subject to formal licensing.

A further structural element of the Tranche 1 reforms is the removal of the sophisticated-investor exemption currently available to stored value facilities, payment instruments and payment services. In its place, the reforms propose a value-based retail/wholesale threshold to be set by regulation rather than fixed in the primary legislation itself. This is a significant open variable for market participants: the direction of travel (narrowing the population able to rely on a sophisticated-investor carve-out) is clear, but the specific value threshold has not yet been quantified in the material available this cycle, meaning affected providers cannot yet precisely determine which of their existing exempt arrangements will fall within the new retail perimeter.

The bank-PSP versus non-bank payment-institution distinction is central to this reform: the AFSL-based licensing framework is explicitly designed for non-bank payment institutions and electronic-money-institution-equivalent entities, operating alongside rather than replacing the existing prudential framework that applies to authorised deposit-taking institutions. The reform's activity-based design means a single entity providing multiple payment services (for example, both remittance and merchant acquiring) may need to consider its licensing obligations across each activity class rather than under a single unified category.

Outlook

The Tranche 1 exposure-draft consultation closed 9 April 2026; the next milestone is the finalisation of the AFSL-based licensing Bill informed by submissions received. The value-based retail/wholesale threshold remains unset pending future regulation, and market participants currently relying on the sophisticated-investor exemption should treat this as an open compliance-scope question until that threshold is determined.

Licensing, Authorisation & Market Access

Australia's digital-asset licensing perimeter enters an enforcement phase this cycle. The Corporations Amendment (Digital Assets Framework) Act 2026 passed Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and commences fully on 9 April 2027 under an eighteen-month implementation runway; it is the governing statute underlying a nearer-term deadline now falling on firms operating under the regulator's transitional posture. Building on that statute, the Australian Securities and Investments Commission issued a final call for firms relying on its sector-wide no-action position for digital-asset financial services: affected firms must hold or have applied for an AFS licence, or have notified ASIC of intent to seek a Market or CS Facility licence with a pre-application meeting, by 30 September 2026, or risk civil or criminal penalties from 1 October 2026. This finding is sourced via trade-press reporting rather than a directly retrieved ASIC primary source this cycle, and is carried at Assessed rather than Confirmed confidence pending direct confirmation.

Separately, the RBA's own Review of Payments System Regulation moved from evidence-gathering into a prioritisation phase: the stakeholder submission window closed on 7 August 2026, and the RBA is to publish a list of regulatory priorities by the end of 2026, with further consultation on prioritised issues to follow from mid-2027. On resilience, the Cash Distribution Framework Act 2026 commenced on 27 August 2026, establishing a regulatory backstop with crisis powers to manage risks to the continuity of Australia's cash distribution system where market-led solutions fail; this is a crisis-powers mechanism over cash-system continuity rather than a customer-fund segregation or insurance mechanism in the payment-institution safeguarding sense. The Reserve Bank of Australia's Payments System Board endorsed the RBA's annual Financial Stability Standards Assessment of ASX clearing and settlement facilities in the same period, and that assessment noted continued ASX governance, culture and risk-management concerns alongside progress on CHESS Replacement Release 1.

The licensing deadline applies across both bank and non-bank market participants operating digital-asset financial services in Australia, while the cash-distribution backstop is tagged as most relevant to non-bank payment-institution and e-money-issuer contexts within the module's bank/non-bank tracking convention.

Outlook

Three forward markers anchor this module's horizon: the RBA's regulatory-priorities list due by the end of 2026, with further consultation on prioritised payments-system-regulation issues expected from the second quarter of 2027; the ASIC no-action position's 30 September 2026 expiry, with civil and criminal penalty exposure for non-compliant digital-asset firms beginning 1 October 2026; and the Corporations Amendment (Digital Assets Framework) Act 2026's full commencement on 9 April 2027. Direct ASIC primary-source confirmation of the no-action-position expiry remains an open verification item for the next cycle.

Licensing, Authorisation & Market Access

Australia's payments licensing perimeter has been fundamentally restructured this cycle. The foundational step was the Treasury Laws Amendment (Payments System Modernisation) Act 2025, which received Royal Assent on 19 September 2025 and updated the Payment Systems (Regulation) Act 1998 to extend Reserve Bank of Australia and Australian Prudential Regulation Authority oversight to digital wallets, stablecoins and crypto payment providers for the first time. This legislative change is corroborated directly by the Parliament of Australia's own bill record, which confirms passage through both Houses, giving the underlying legislative history a high evidentiary foundation independent of secondary commentary.

The implementing detail followed on 12 March 2026, when Treasury released Tranche 1 exposure draft legislation establishing Australian Financial Services Licence-based licensing foundations for payment service providers. This exposure draft also empowers the Australian Prudential Regulation Authority to set prudential standards for a newly defined major stored value facility category, applicable to providers whose aggregate credit exceeds an indicative A$200 million threshold. This threshold-based approach draws a clear line between ordinary licensed payment service providers, who fall under the general AFSL-based licensing foundation, and systemically significant providers, who face bank-like prudential supervision.

The product-definition groundwork for this licensing architecture was laid earlier, in Treasury's Tranche 1A consultation released 9 October 2025, which proposed two new financial products — a stored value facility, including a tokenised SVF variant, and a payment instrument — together with a new payment-service financial service covering payment initiation, facilitation, and technology/enablement services. These definitions are the building blocks the March 2026 exposure draft licensing framework is constructed around, and they matter because they determine which categories of provider — from card-scheme operators to digital-wallet providers to emerging technology-enablement firms — fall within the new AFSL-based perimeter at all.

A notable design feature of the emerging regime is the discretionary ministerial power to designate a payment service provider for prudential regulation on financial-stability grounds, operating as a supplementary safeguard alongside the fixed A$200 million threshold test. This gives the prudential regulator flexibility to reach a systemically important provider that might not meet the standard quantitative threshold but nonetheless poses financial-stability risk, a design choice consistent with a 'break glass' approach to systemic-risk designation seen in other payments regimes internationally.

Taken as a whole, this cycle's evidence — a Royal Assent-confirmed foundational Act, a corroborating parliamentary bill record, and a detailed March 2026 exposure draft — represents Confirmed-confidence, T1-and-T3-sourced evidence of the most significant restructuring of Australia's payments licensing perimeter identified this cycle. The bank-PSP versus non-bank payment-institution distinction is central to this restructuring: it is precisely because digital wallets, stablecoin-adjacent stored value facilities, and card-scheme-adjacent payment providers have not previously sat within a bank-style prudential perimeter that the new AFSL-based licensing foundation, coupled with the major-SVF prudential carve-out, has been designed to draw that line explicitly for the first time.

Outlook

The next marker to watch is whether the Tranche 1 licensing regime moves from exposure-draft to enacted, operative law, expected in the fourth quarter of 2026 on current guidance. Key open questions include whether the A$200 million major-SVF threshold and the ministerial designation power survive consultation in their current form, and how the AFSL-based licensing foundation is calibrated to distinguish bank-affiliated payment providers from independent non-bank payment institutions and e-money issuers as the detailed rules are finalised.

Licensing, Authorisation & Market Access

Australia's Tranche 1 payments-licensing reform represents the most significant expansion of the AFSL-based payment-regulation perimeter in over a decade. The Treasury Laws Amendment Bill 2026: Payment Systems Modernisation, whose exposure draft was released on 12 March 2026 with consultation closing 9 April 2026, creates three new categories of AFSL-regulated payment service: payment facilitation, payment initiation, and payment technology/enablement. It also introduces a new stored-value facility (SVF) authorisation sitting alongside the AFSL structure. For non-bank payment institutions and e-money issuers, this marks the end of a long period in which many payment activities were conducted under exemptions or informal regulatory tolerance. The consolidated Tranche 1 package is targeted for introduction to Parliament in 2026, with a Tranche 2 covering access regimes, industry standards, and systemic infrastructure to follow in a subsequent legislative cycle.

The regulatory architecture established by the reforms is tripartite. ASIC will serve as the conduct regulator and licensor for payment service providers across the new AFSL categories. APRA will exercise prudential oversight over major SVF operators and designated payment-facilitation-service providers, with its threshold set at approximately A$200 million in aggregate stored value across a group's SVFs; entities crossing that threshold will access APRA oversight via a streamlined registration pathway that stops short of full ADI authorisation. The Reserve Bank of Australia retains payments-system oversight and designation powers under the Payment Systems (Regulation) Act, preserving its role as the macro-level architect of the payments system even as ASIC and APRA take on the firm-level regulatory functions.

The bank versus non-bank distinction is structurally embedded in this architecture. ADIs — authorised deposit-taking institutions — already hold full prudential authorisation and direct Exchange Settlement Account access. Non-bank payment institutions entering the new licensing perimeter will be regulated by ASIC for conduct and, above the SVF threshold, by APRA for prudential purposes, but they will not automatically acquire ADI status or the settlement-access rights that come with it. The ESA access question is deferred to a separate RBA review commencing H2 2026 (see W12). This sequencing means that the licensing reforms will bring non-bank PSPs into a formal regulatory perimeter before the question of their direct central-bank settlement access is resolved — a gap that has operational and competitive implications for the non-bank sector.

The primary source gap for this module is notable: no Tier-1 primary Treasury or legislation.gov.au source was captured for the Payment Systems Modernisation Bill 2026 exposure draft this cycle; the findings rest on law-firm Tier-3 sources. The analytical conclusions are assessed as reliable given the convergence of multiple independent law-firm analyses, but readers requiring primary-source verification should consult the Treasury consultation page directly.

Outlook

The Tranche 1 package is targeted for Parliament in 2026. The precise legislative calendar has not been confirmed, and the exposure-draft consultation closed in April 2026, meaning the bill is likely in drafting or pre-introduction review at the time of this cycle. Non-bank PSPs that will fall within the new payment facilitation, payment initiation, or SVF categories should be assessing their licensing pathways now, including whether they will require a new AFSL, a variation to an existing AFSL, or an SVF authorisation. The APRA SVF threshold of approximately A$200 million will be a key sizing question for larger stored-value operators. Tranche 2 — covering access regimes and industry standards — will define the longer-run competitive structure of the market and is worth tracking as a second-order horizon item.

Operational Resilience & Critical Infrastructure

Mastercard card payments were temporarily declined for some Australian customers on 15 August 2026 due to a global technical issue; Mastercard confirmed the disruption was resolved the same day. This is a dated, single-day incident carried at dashboard tier rather than a standing structural finding, monitored for recurrence and for cross-reference to scheme-compliance and acquiring-side impact in future cycles.

Outlook

No further action items are outstanding on this incident; it is closed as resolved and will be revisited only if a recurrence or related scheme disclosure surfaces in a future cycle.

Scheme & Network Compliance

The Reserve Bank of Australia's card-surcharge ban and interchange-fee reform package reached full effect on 1 October 2026, closing an 18-month review process concluded in the RBA's 31 March 2026 Conclusions Paper. From that date, businesses may no longer apply a surcharge to card payments made using eftpos, Mastercard, Visa, American Express or UnionPay debit, prepaid or credit cards, regardless of whether the card is domestically or foreign-issued, and regardless of channel, covering both in-store and online transactions. This is a comprehensive ban in scope: it reaches every major scheme operating in the Australian market and both card-present and card-not-present transaction types.

Accompanying the surcharge ban, lower domestic interchange-fee caps for Australian-issued cards also took effect on 1 October 2026. The reform is structured in two stages: caps on foreign-issued cards will follow on 1 April 2027, meaning the full interchange reform will not be complete until that later date. Acquirers additionally face new reporting requirements obliging them to publish the fees they charge, a transparency measure that gives merchants and the broader market visibility into acquiring costs previously disclosed less consistently across providers.

The mechanism chosen to enforce the surcharge ban is the most structurally distinctive feature of this reform. Rather than relying on direct statutory enforcement by the Australian Competition and Consumer Commission, compliance is driven contractually: the RBA directed card networks and, through them, acquirers and terminal providers, to remove surcharging functionality from their systems, so that the technical capability to surcharge is withdrawn at the infrastructure level rather than policed after the fact through complaint-driven investigation. The ACCC continues to enforce its pre-existing excessive-surcharging rules separately from this new blanket ban, meaning two enforcement tracks now operate in parallel: a contractual, scheme-level mechanism preventing surcharging from occurring at all for the newly banned categories, and a statutory, complaint-driven mechanism addressing excessive surcharging that falls outside the ban's scope or predates it.

This is an architecture choice with real consequences for how disputes will be resolved. A merchant that attempts to surcharge in breach of the ban faces action through its card-network merchant agreement rather than a regulatory enforcement notice in the first instance, which shifts the practical locus of enforcement from a public regulator to private commercial relationships governed by scheme rules. Whether this proves as robust as direct statutory enforcement will depend on how consistently the card networks apply their own contractual sanctions across the acquiring ecosystem.

Outlook

The second stage of the interchange reform, extending lower caps to foreign-issued card transactions, is scheduled for 1 April 2027, which will complete the RBA's two-stage interchange package roughly eighteen months after the review's conclusions were published. In the interim, the practical test of the surcharge ban will be whether contractual enforcement through merchant agreements successfully eliminates surcharging at scale, or whether gaps emerge that drive merchant complaints back toward the ACCC's parallel excessive-surcharging enforcement track. The new acquirer fee-transparency reporting requirement may also generate comparative data in coming periods that sheds light on whether the lower interchange caps are being passed through to merchants as intended.

Payment Corridor Dynamics

Swift's shared framework for cross-border payments reported that, over the month to 22 July 2026, 26 financial institutions had started processing payments under the new arrangement, activating 25 payment corridors around the world. Swift's own description characterises the minimum viable product for the scheme as having been delivered in the first half of 2026, laying groundwork for a transformed end-to-end cross-border payments experience. Major Australian banks were listed as participants in Swift's September participant listing, indicating Australian corridor activity is part of this global rollout, though the evidence does not establish that every listed bank went live on the identical date as the initial 22 July cohort.

Outlook

The corridor count and participant list are both still expanding figures tied to an active rollout rather than a completed one; further participant additions and corridor activations are the expected trajectory as Swift's framework matures beyond its first-half-2026 minimum viable product. For Australian institutions, the relevant question going forward is the pace and completeness of individual banks' transition onto the new shared framework rather than whether the framework itself is operative, which this evidence already establishes.

Payment Corridor Dynamics

AusPayNet's Account-to-Account Roundtable was tracking a further update on New Payments Platform migration risks around March 2026, covering 24/7 real-time payments, confirmation of payee, and real-time payment verification. This item is at dashboard level this cycle — it signals ongoing industry-level engagement with NPP migration risks rather than a concluded regulatory or scheme-rule change. The confirmation-of-payee and real-time payment-verification components are the operationally significant elements, as they bear on fraud-risk management in the A2A migration context.

Outlook

The NPP migration risk assessment is a standing tracker item. Further updates from AusPayNet are expected as the migration progresses. The W5 surface for Australia is stable this cycle with no escalating developments.

Market Structure & Competition

No standalone W6 market-structure or competition developments were identified for Australia this cycle. The tripartite ASIC/APRA/RBA regulatory architecture established by the Tranche 1 reforms has structural market-competition implications — particularly the sequencing of licensing reform ahead of ESA access reform — but these are covered under W1a and W12 respectively.

Outlook

The RBA's mid-2026 consultation on mobile wallets, three-party card networks, BNPL, and e-commerce platforms (W9) will have market-structure implications if it leads to regulatory intervention in those segments. The ESA access review (W12) is the most significant structural market-access question on the horizon.

Merchant Acquiring & Risk

The RBA's Conclusions Paper on its Review of Merchant Card Payment Costs and Surcharging confirms two high-impact changes to card-payment economics in Australia, both of which carry direct operational implications for acquirers, payment facilitators, and merchants.

The first and most immediate change is the removal of surcharging on eftpos, Mastercard, and Visa debit, prepaid, and credit transactions from 1 October 2026. This is a hard operational deadline: from that date, merchants may not impose a surcharge on any of these card types. The enforcement mechanism is notable. The surcharge ban is implemented via card-network merchant-agreement rules rather than through direct RBA or ACCC enforcement action. The ACCC continues enforcing the existing cost-recovery framework — under which merchants may only surcharge up to their reasonable cost of acceptance — until 1 October 2026. After that date, the prohibition is embedded in scheme rules, meaning that acquirers and payment facilitators bear the primary compliance responsibility through their merchant agreements. Merchants that continue to surcharge after 1 October 2026 will be in breach of their merchant agreements with their acquirer, not directly in breach of a regulatory instrument.

This implementation architecture has several analytical implications. First, it places the compliance burden on the acquirer-merchant relationship rather than on a direct regulatory enforcement channel, which means acquirers and payment facilitators must update their merchant agreements, terminal configurations, and merchant-facing communications ahead of the deadline. Second, it means that enforcement will initially be scheme-driven rather than regulator-driven, which may affect the speed and consistency of compliance across the merchant base. Third, it creates a potential gap between the formal prohibition date and the practical elimination of surcharging, particularly for merchants using legacy point-of-sale systems that require software updates.

The second change is the reduction of the domestic interchange fee cap from 0.8% to 0.3%, accompanied by a new foreign-card interchange cap of 1% — down from as high as 2.4% — and additional cost-transparency measures, all commencing 1 April 2027. The domestic cap reduction is a significant compression of the interchange economics that underpin card-issuer revenue and, indirectly, rewards programmes. The foreign-card cap is a new instrument targeting the premium interchange rates that international card schemes have historically charged for foreign-issued cards used in Australia; the reduction from up to 2.4% to 1% is a substantial cut that will affect the economics of inbound tourism and cross-border e-commerce transactions.

The RBA estimates that the combined package will deliver up to A$1.8 billion per year in total consumer and business savings, including approximately A$910 million in reduced merchant service fees. These are assessed estimates rather than confirmed outcomes, and the distribution of savings between consumers and businesses will depend on how merchants pass through the reduced acceptance costs.

The bank versus non-bank distinction is relevant here primarily at the acquirer level. Both bank-owned acquirers and non-bank payment institutions operating as acquirers or payment facilitators are subject to the scheme-rule changes. The interchange-cap changes affect card issuers — predominantly ADIs — more directly than acquirers.

Outlook

The 1 October 2026 surcharge-ban deadline is the immediate operational priority for acquirers and payment facilitators. The 1 April 2027 interchange and cost-transparency changes require a longer lead time for issuers to model the revenue impact and adjust product economics. The RBA's mid-2026 consultation on mobile wallets, three-party card networks, BNPL, and e-commerce platforms (W9) may extend the reform logic into adjacent acquiring and acceptance contexts.

Product Innovation & Market Development

The most consequential product-innovation development this cycle is the regulatory-design choice to route payment stablecoins into the payments-modernisation track rather than treating them as crypto-market financial products. Payment stablecoins are exempted from the Digital Assets Framework's digital-token financial-product treatment because they attach instead to a newly defined tokenised stored value facility regime, with issuers subject to monthly reserve-asset disclosure and guaranteed-redemption-right obligations. This is a deliberate boundary-drawing exercise: Australia is treating currency-referenced stablecoins as e-money-like payments infrastructure rather than as crypto tokens subject to token-classification rules, a divergence from a purely token-function-based classification approach.

This product-classification decision sits within the broader Tranche 1/1A product-definition work released by Treasury. The 9 October 2025 Tranche 1A consultation proposed the underlying financial-product categories — a stored value facility, including the tokenised SVF variant that now houses payment stablecoins, and a payment instrument — alongside a new payment-service financial service covering payment initiation, facilitation, and technology/enablement services. The stablecoin-to-SVF routing decision is therefore not a standalone stablecoin rule but an application of this broader new product taxonomy to a specific instrument type.

A related systemic-risk safeguard accompanies this product innovation: a major stored value facility prudential category is proposed for providers whose aggregate credit exceeds an indicative A$200 million threshold, which would bring large stablecoin-adjacent SVF issuers under Australian Prudential Regulation Authority prudential regulation. Additionally, the Minister retains a discretionary power to designate any payment service provider for prudential regulation on financial-stability grounds, extending potential prudential reach beyond the fixed threshold where warranted. For issuers of payment stablecoins operating at meaningful scale, this means the guaranteed-redemption and reserve-disclosure obligations attaching to the tokenised SVF classification could be supplemented by full prudential supervision once the A$200 million threshold is crossed.

The practical significance of this product-innovation choice for market participants is that stablecoin issuers targeting the Australian payments market face a materially different regulatory pathway than they would under a pure crypto-asset classification: monthly reserve disclosure and guaranteed redemption rights are payments-regulation-style consumer protections, not crypto-market disclosure requirements, and they come with the prospect of prudential oversight at scale rather than crypto-specific licensing obligations.

Outlook

The key development to watch is whether the tokenised SVF classification for payment stablecoins survives into enacted law in its current exposure-draft form, and whether the A$200 million major-SVF threshold is adjusted through the consultation process. As Tranche 1 legislation progresses toward an anticipated fourth-quarter 2026 commencement, market participants developing stablecoin-adjacent payment products should watch closely for confirmation of exactly which reserve-disclosure and redemption-right obligations attach at the point the tokenised SVF regime becomes operative law.

Product Innovation & Market Development

The Reserve Bank of Australia has flagged a mid-2026 public consultation to assess the public-interest case for regulating retail-payments areas outside the current review. The areas identified include mobile wallets, three-party card networks, BNPL services, and e-commerce platforms. This item is at dashboard level this cycle — it is a confirmed signal of regulatory intent rather than a concluded reform. The RBA's framing of the consultation as assessing the "public-interest case" for regulation suggests that the outcome is not predetermined; the consultation may conclude that some or all of these areas do not require regulatory intervention at this stage.

The significance of this item lies in its scope. Mobile wallets, three-party card networks, BNPL, and e-commerce platforms together cover a substantial portion of the non-bank payment-product landscape that has historically operated outside the formal payments-regulation perimeter. If the RBA concludes that regulation is warranted in any of these areas, the resulting reforms would extend the perimeter established by the Tranche 1 licensing package into product categories that are currently unregulated or lightly regulated.

Outlook

The mid-2026 consultation is expected to launch in Q3 2026. Given the RBA's stated uncertainty band of half a year, the consultation could slip into H2 2026. The outcome of the consultation will determine whether W9 becomes an escalating module in future cycles.

Consumer Protection & APP Fraud

Australia's Scams Prevention Framework reached a first compliance milestone on 1 September 2026: entities in the banking, telecommunications and digital-platforms sectors that provide services designated under the Framework were required to be members of the Australian Financial Complaints Authority by that date. This membership obligation is now in force, but it is only the first tranche of a larger set of obligations. As at 20 August 2026, the substantive SPF codes and rules were still being developed by government, with Treasury having recently consulted on a draft banking-sector code and the first set of SPF rules. Most of the Framework's substantive obligations are scheduled to commence on 31 March 2027, with additional obligations expected to commence by the end of 2027.

No final reimbursement threshold or liability-allocation model under the Framework has been verified from the available evidence, and none is asserted here pending the finalisation of the underlying codes and rules.

Outlook

The period between now and 31 March 2027 is a construction phase for the Scams Prevention Framework: AFCA membership is a structural prerequisite now satisfied, but the substance of what banking, telecommunications and digital-platform entities will actually owe consumers under the Framework depends on codes and rules that were still in consultation as at August 2026. The draft banking-sector code is the most concrete document to track as it moves toward finalisation ahead of the March 2027 commencement date, with a further tranche of obligations expected to follow by the end of 2027.

Consumer Protection & APP Fraud

ASIC warned of a sharp rise in AI deepfake investment-scam networks impersonating Australian public figures in the 2026 financial year, reporting removal of over 19,400 online scams -- up 182% year-on-year -- and urging consumers to verify AFS licence numbers before investing. The finding is tagged as most relevant to non-bank payment institutions and e-money issuers within the module's bank/non-bank tracking convention, and is carried at dashboard tier as a dated warning rather than a standing structural finding.

Outlook

No dated regulatory action beyond the warning itself is scheduled this cycle; the module will track any escalation into formal enforcement or scam-reimbursement policy in future cycles.

AML/CFT & Financial Crime

This module is sourced from the Sentinel feed (sentinel.gi). No direct Sentinel W11 feed was available for Australia this cycle; the AML/CFT finding captured this cycle was surfaced via the W1b licensing lens and is reported there in full.

For the record: AUSTRAC's FATF-aligned virtual-asset service provider AML/CTF regime commenced 31 March 2026, requiring AUSTRAC registration and an AML/CTF programme for virtual-asset and value-transfer designated services. This finding has been cross-flagged to the Financial Intelligence Monitor. Readers tracking the AML/CFT surface for Australian virtual-asset operators should consult the Sentinel feed and the FIM directly for fuller coverage.

The absence of a direct Sentinel W11 feed for Australia this cycle means the AML/CFT surface is under-indexed. The VASP regime finding should be treated as a floor rather than a ceiling for AU AML/CTF regulatory activity.

Outlook

Future AU cycles should prioritise direct Sentinel W11 coverage to avoid continued licensing-domain overloading of AML/CFT findings. The AUSTRAC VASP regime is now live and will generate enforcement and compliance developments that are properly W11 material.

Commercial Intelligence & Fintech

Tyro Payments had completed its acquisition of Thriday by 25 August 2026. Tyro's own reporting describes the deal as broadening its accounting and financial-management offering, and links the acquisition to increasing multi-product adoption and customer value among its merchant base, with these customers also showing longer retention. The transaction's value was not publicly disclosed in the evidence available.

Outlook

The Thriday acquisition fits a pattern of merchant-acquiring PSPs expanding into adjacent accounting and financial-management services to increase product attachment per merchant. Further disclosure of integration progress or additional bolt-on acquisitions by Tyro would be the next markers to watch for this specific line of commercial activity.

Commercial Intelligence

No commercial events — M&A deals, investment or funding rounds, or product releases — were identified for Australian payment service providers this cycle. The gaps register records this as a standing under-indexed vector: private-company PSP funding and M&A signals were not surfaced for Australia in this run.

This gap is analytically significant given the material perimeter shift across W1a, W1b, and W8 this cycle. A new licensing perimeter for payment facilitation, payment initiation, and SVF services, combined with a mandatory safeguarding requirement and a card-surcharge ban, creates conditions in which commercial responses — consolidation, new investment, product repositioning — would be expected. The absence of W13 signal this cycle reflects a coverage gap rather than an absence of commercial activity.

Outlook

Future AU cycles should include targeted scraping for commercial events among Australian non-bank PSPs, particularly those that will be affected by the new AFSL licensing categories. M&A activity driven by licensing-cost economics, investment rounds targeting the new regulatory-compliant PSP category, and product launches responding to the surcharge ban are all plausible W13 developments that the current coverage architecture is not capturing.