title: Australia Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/australia/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Australia AU schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 59 sourced findings · 269 sources in the cumulative register 14 Modules baseline.modules[] 59 Findings modules[].findings[] 119 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Australia's payments regulatory perimeter is expanding on three fronts simultaneously this cycle: licensing and market access, merchant-acquiring cost structure, and consumer scam protection. The Reserve Bank of Australia published its Summary of Submissions to the Review of Payments System Regulation Issues Paper on 6 October 2026, with 75 stakeholders having responded. From October 2026 the RBA moves from consultation into evidence assessment, with a regulatory-priorities list expected by the end of 2026. This review sits alongside the Treasury Laws Amendment (Payments System Modernisation) Regulations 2026, whose Tranche 1 exposure draft, released 12 March 2026, would bring stored-value facilities, payment instruments, digital wallets and merchant-acquiring-adjacent services into an Australian Financial Services Licence perimeter, with APRA gaining prudential-standard-setting power over major stored-value-facility providers holding over AU$200 million in aggregate customer funds or reserves. Taken together with the merchant-acquiring and consumer-protection reforms below, this is a multi-domain tightening cycle rather than an isolated regulatory adjustment. #### Other Developments **Merchant-acquiring costs have been restructured.** The RBA's Review of Merchant Card Payment Costs and Surcharging took effect 1 October 2026. No-surcharge rules now apply across eftpos, Mastercard and Visa designated systems for debit, prepaid and credit cards. Domestic debit and prepaid interchange is capped at 8 cents per transaction or 0.16 percent ad valorem, and consumer credit interchange is capped at 0.3 percent, down from 0.8 percent. The weighted-average interchange benchmark has been abolished. A foreign-card interchange cap and further cost-transparency changes have been deferred to 1 April 2027 to allow implementation time. Acquirers must also publish a measure of interchange pass-through quarterly for the first four quarters from 1 October 2026, with the first publication due by 30 January 2027, and issuer net-compensation rules now capture all Australian issuers, including foreign-sponsored ones, closing a prior circumvention route. **A new stored-value-facility sub-category targets stablecoins.** The Tranche 1 exposure draft defines a "Tokenised Stored Value Facility" as a specific stored-value-facility sub-type intended to capture fiat-backed stablecoin arrangements where redemption is linked to a digital token. Separately, the RBA's March 2026 risk assessment of decommissioning the Bulk Electronic Clearing System concluded that PayTo has yet to demonstrate its maturity as a direct-debit replacement, with growth to date coming mostly from new payment agreements rather than migration of existing direct debits. **Scam-prevention obligations are phasing in with substantial penalties attached.** The Scams Prevention Framework Rules commenced 1 September 2026. Entities in the banking, telecommunications and digital-platform sectors were required to be Australian Financial Complaints Authority members by that date. The more substantive prevent, detect, disrupt, report and respond obligations, together with compliance-statement and record-keeping duties, commence 31 March 2027, backed by civil penalties of up to AU$50 million per contravention. The framework is enforced by ASIC for banks, ACMA for telecommunications providers, and the ACCC for digital platforms and as general regulator, with a private right of action for damages and AFCA as the sole external dispute-resolution body. #### Cross-Monitor Connections The Tokenised Stored Value Facility category and the broader stablecoin-adjacent provisions of the Payments System Modernisation reform connect directly to crypto-asset regulatory developments being tracked separately, including parallel capital, custody and trading-standard consultations for digital asset platforms. Illicit-finance use of any payment instrument, including stored-value facilities or stablecoins, is a financial-integrity cross-reference rather than a world-payments conclusion, and AML/CFT intelligence for Australia's payments sector continues to be subscribed from that monitor rather than independently assessed here. #### Outlook The RBA's regulatory-priorities list, expected by the end of 2026, will indicate which elements of the Review of Payments System Regulation move toward binding rules, with further consultation expected from mid-2027. The foreign-card interchange cap and additional transparency changes take effect 1 April 2027, and the first quarterly interchange pass-through publication is due 30 January 2027. On the consumer-protection side, 31 March 2027 is the date by which the Scams Prevention Framework's substantive obligations, and the instrument authorising AFCA as sole external dispute-resolution scheme, are expected to be in place. Taken together, the first half of 2027 is when most of this cycle's still-prospective reforms convert into binding operational requirements for payment-system participants. _6 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Australia has entered the most concentrated payments-regulation reform wave in its modern history, and this cycle establishes the first full standing baseline across all fourteen modules of the World Payments Monitor spine. At the centre sits Treasury's Payments System Modernisation program, which replaces the Corporations Act's "non-cash payment facility" concept with a technology-neutral, activity-based licensing regime, creating new payment financial products (payment instruments, stored value facilities including tokenised SVFs) and new financial services (payment facilitation, payment initiation, payment technology/enablement) that generally require an Australian Financial Services Licence. A Tranche 1a exposure draft was released on 9 October 2025, with commencement expected around 2027, twelve months after Royal Assent. The architecture is twin-peaks: the Australian Securities and Investments Commission holds conduct and AFSL authority while the Australian Prudential Regulation Authority takes a new non-ADI prudential lane for major stored-value-facility providers holding more than A$200 million in group-aggregate stored value. Separately, a Bill modernising the Payment Systems (Regulation) Act 1998 received Royal Assent on 19 September 2025, broadening the Reserve Bank of Australia's designation and oversight remit by widening the statutory definitions of "payment system" and "participant", effective December 2025. The licensing overhaul is paired with a parallel safeguarding regime. Tranche 1b establishes customer-fund protection modelled on the Corporations Act client-money regime but adapted for payments: the primary safeguarding method is segregation of payment-related money in a separate trust account with an Australian ADI, with insurance or other prescribed methods available as alternatives, and removes the sophisticated-investor exemption for stored-value facilities, payment instruments and payment services. Treasury's draft also reclassifies payment stablecoins - stable-value instruments fully backed by cash or cash-equivalents - as "payment stablecoin SVFs", treating them more readily as electronic cash rather than under ASIC's prior non-cash-payment-facility treatment set out in Consultation Paper 381 of December 2024, with tokenised SVF providers facing monthly reserve disclosures, guaranteed redemption rights and adverse-event disclosure. Collectively, this single reform program draws merchant acquirers, remitters, prepaid and e-money operators, payment facilitators, point-of-sale technology providers and stablecoin issuers into a unified AFSL perimeter for the first time, reshaping market-access economics for every non-bank payment service provider operating in Australia. #### Other Developments APRA's Prudential Standard CPS 230 Operational Risk Management commenced on 1 July 2025, replacing the former outsourcing and business-continuity standards, and requires regulated entities to manage operational risk, keep critical operations within impact tolerances through severe disruptions, and formally manage material service-provider risk via a register and agreements; requirements for pre-existing service-provider contracts apply from the earlier of contract renewal or 1 July 2026, with payments expected to be classified a critical operation. On 30 April 2026 APRA finalised targeted amendments introducing a limited exemption from specific contractual requirements for arrangements with non-traditional service providers such as central banks, clearing and settlement facilities, payment systems and financial messaging infrastructures. Following its Review of Merchant Card Payment Costs and Surcharging, the Reserve Bank decided to remove surcharging on designated debit, prepaid and credit networks, lower interchange caps - including a new foreign-interchange cap and transparency requirements - and proposed lowering the domestic credit interchange cap to 0.3%, in a market that uniquely combines weighted-average benchmarks with individual caps. Independent estimates suggest roughly 16% of merchants surcharge designated network card payments, with about A$1.6 billion paid by consumers and A$0.2 billion by businesses. The same reform brings merchant acquirers, payment facilitators and point-of-sale technology providers into the AFSL regime as Payment Facilitation Service providers and requires large acquirers to publish their fees. The Payments System Board's annual review found high compliance with existing interchange, surcharging and access standards in 2024/25 and expects industry to migrate card payments to the Advanced Encryption Standard by December 2030. The RBA's Project Acacia concluded that interoperable private tokenised money - stablecoins or tokenised commercial bank deposits - can support asset tokenisation, while central bank money retains a foundational role and many benefits can already be realised using existing Exchange Settlement Account balances. Its Final Report, published 19 May 2026, tested 24 use cases across stablecoins, bank deposit tokens and pilot wholesale CBDC, and issued a world-first pilot wholesale CBDC directly onto third-party distributed-ledger platforms - total issuance of A$4.4 million - under ASIC regulatory relief, launching follow-on work including a possible regulatory sandbox and a Deposit Token Working Group. From 10 June 2025, buy-now-pay-later providers must hold a credit licence under the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024, including responsible-lending obligations and Australian Financial Complaints Authority membership. The RBA's February 2026 Bulletin found that transferring A$1,000 via major banks' international money-transfer services cost around 4% to advanced countries and 6% to developing countries in September 2025 - above the G20's 3% and 5% ceilings - while non-bank transfers to developing countries, at around 2%, beat the target; Australia remains well below the G20's speed target of settling 75% of transfers within an hour, partly for timezone reasons. Remittance corridors from Australia to Pacific Island countries face fragile connectivity and concentration risk, with a single bank in some cases providing correspondent services to several money-transfer operators amid reduced bank risk appetite and rising AML/CFT compliance costs. Australia is also among the initial corridors in SWIFT's new retail cross-border payments framework, with more than 25 banks - including ANZ, Commonwealth Bank, NAB and Westpac - going live by end-June 2026. The market structure underneath these reforms remains bank-dominated at the rails layer, with four major banks sitting alongside a vibrant fintech and non-bank layer of more than 150 active firms; domestic shared infrastructure is consolidated under Australian Payments Plus, which operates the New Payments Platform, eftpos and BPAY, with NPP volumes exceeding 100 million transactions a month. The Federal Court ordered HSBC Australia to pay A$35 million on 18 June 2026 for scam-protection failures the judge found systemic and widespread, including an average scam-report investigation time of 144 days. FIIG Securities was ordered on 9 February 2026 to pay A$2.5 million, the first time the Federal Court has imposed civil penalties for cyber-security failures under general AFS licensee obligations, following a 2023 attack that exfiltrated about 385 gigabytes of client data. BPS Financial, operator of the Qoin crypto-token product, faced A$14 million in penalties after ASIC's Full Court appeal win of 30 May 2025. The Scams Prevention Framework, a principles-based whole-of-ecosystem regime spanning banks, telecommunications carriers and digital platforms, commenced 21 February 2025 and carries civil penalties of up to A$50 million per contravention; unlike the UK's reimbursement model, it did not originally mandate reimbursement, relying instead on dispute resolution and court action. On 28 May 2026 Treasury released draft rules proposing a reimbursement scheme with a A$3,000 threshold and an equal-liability apportionment model, with first sector obligations targeted from 1 July 2026. The reforms also introduce APRA-administered Common Access Requirements intended to open direct access to Australian payment systems for non-ADI payment service providers, while high-value and NPP settlement continues to run through the Reserve Bank's RITS system via Exchange Settlement Accounts. On the commercial side, Airwallex secured a US$300 million Series F round in May 2025 at a US$6.2 billion valuation. Banking Circle acquired the ADI-licensed Australian Settlements Limited in January 2025 to bolster real-time clearing capability, and ASX-listed Tyro agreed to acquire NAB-backed fintech Thriday, with completion expected in January 2026. #### Cross-Monitor Connections Two threads in this cycle carry significance beyond payments-instrument analysis and are flagged to the Financial Integrity Monitor rather than analysed as illicit-finance questions here. AUSTRAC's AML/CTF reforms under the Amendment Act 2024 - carried in this brief via the Sentinel.gi feed only - close gaps against international standards: customer-due-diligence changes for existing reporting entities began 31 March 2026, and Tranche 2 extends obligations to designated non-financial businesses and professions from 1 July 2026 across a regulated population of roughly 100,000 entities, alongside a new International Value Transfer Service report replacing the former International Funds Transfer Instruction report and a travel rule applying to virtual-asset transfers from 1 July 2026. Second, the fragile correspondent-banking connectivity on the Australia-Pacific remittance corridor has financial-inclusion and illicit-finance dimensions that warrant attention from the Financial Integrity Monitor beyond this brief's corridor-dynamics view. #### Outlook The next twelve months bring a dense sequence of commencement dates. Pre-existing service-provider contracts must meet CPS 230's full contractual requirements from the earlier of contract renewal or 1 July 2026. The Scams Prevention Framework's first sector obligations are targeted to take effect from 1 July 2026, alongside AUSTRAC's Tranche 2 DNFBP expansion and virtual-asset travel rule. SWIFT's retail cross-border framework is due to go live across its initial corridors, including Australia, by end-June 2026. Card issuers and acquirers face a longer runway to migrate to the Advanced Encryption Standard by December 2030, while the core AFSL licensing perimeter is not expected to commence until around 2027. Australia's payments industry, banks and non-banks alike, is moving through a rare period where licensing perimeter, safeguarding regime, scheme economics, scam liability and settlement access are all being reset within the same window, with the twin-peaks ASIC/APRA architecture as the structural throughline connecting each strand. trust tier: ai_unverified ###### Latest update · 6 October 2026 #### Regulatory Status Australia's payments-regulatory environment tightened across multiple tracks within a short window. ASIC's sector-wide no-action position for digital-asset businesses expired on 30 September 2026, requiring firms relying on it to have applied for or varied an AFS licence or risk operating in breach of financial services law. A card-scheme surcharge ban on Visa, Mastercard, American Express and eftpos cards took effect from 1 October 2026, enforced through scheme rules and merchant contracts rather than direct ACCC action. The Scams Prevention Framework's AFCA membership requirement for designated banking, telecommunications and digital-platform entities came into force on 1 September 2026, with the bulk of substantive SPF obligations deferred to 31 March 2027 while the underlying codes and rules remain under development. Separately, ASIC reported record court-ordered civil penalties across two consecutive half-years, totalling A$830 million for 2025-26. On the commercial side, Swift's shared cross-border payments framework activated with major Australian banks among its listed participants, and Tyro Payments completed its acquisition of Thriday. #### Outlook The near-term trajectory is one of continued regulatory tightening on a pre-set schedule: the Scams Prevention Framework's substantive obligations commence 31 March 2027, contingent on finalisation of the draft banking-sector code and first set of SPF rules currently in consultation, with further obligations expected by end-2027. Enforcement intensity from ASIC shows no sign of easing given two consecutive record half-years. The consistency of card-scheme surcharge-ban enforcement across the merchant base, given it runs through contractual scheme rules rather than direct regulatory action, is a further point to monitor. _4 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Australia's payments regulatory perimeter is in the midst of its most concentrated reform wave in modern history, spanning all fourteen World Payments Monitor modules. The centrepiece is Treasury's Payments System Modernisation program, which replaces the Corporations Act's "non-cash payment facility" concept with activity-based AFSL licensing (Tranche 1a exposure draft 9 October 2025, commencement ~2027) under a twin-peaks ASIC/APRA architecture, paired with a Tranche 1b safeguarding regime built on trust-account segregation and removal of the sophisticated-investor exemption. Payment stablecoins are being folded into this same framework as tokenised SVFs. Operational resilience is already in force: APRA's CPS 230 commenced 1 July 2025, with April 2026 targeted amendments for non-traditional service providers and a 1 July 2026 deadline for pre-existing service-provider contracts. Card-scheme economics are being reset following the RBA's Conclusions Paper of March 2026, which decided to remove surcharging on designated networks and lower interchange caps while bringing acquirers into the AFSL perimeter. Consumer protection has a distinctive multi-regulator architecture in the Scams Prevention Framework (commenced 21 February 2025, A$50 million per-contravention penalties, first sector obligations from 1 July 2026, draft A$3,000 reimbursement threshold released 28 May 2026). AML/CFT reform (Sentinel-fed) proceeds on a parallel track via AUSTRAC's Amendment Act 2024, with Tranche 2 DNFBP obligations and a virtual-asset travel rule from 1 July 2026. Settlement access is being opened to non-bank PSPs through APRA-administered Common Access Requirements, against a market structure that remains bank-dominated at the rails layer (four major banks) with a vibrant non-bank PSP layer of 150+ firms and consolidated shared infrastructure under Australian Payments Plus. Record ASIC enforcement (A$349.8 million in H2 2025 penalties, including the HSBC Australia A$35 million scam-controls judgment, the FIIG Securities A$2.5 million cyber-security penalty, and the BPS Financial/Qoin A$14 million crypto judgment) is setting conduct expectations ahead of the new licensing perimeter taking effect. Commercial activity remains active, with Airwallex's US$300 million Series F, Banking Circle's acquisition of Australian Settlements Limited, and Tyro's agreed acquisition of Thriday all recorded in this cycle. The regulatory layer throughout is federal/Commonwealth, with no material state-level divergence identified for the payments perimeter. #### Outlook The next eighteen months bring a dense, overlapping commencement calendar: CPS 230's pre-existing-contract deadline and the Scams Prevention Framework's first sector obligations both target 1 July 2026, alongside AUSTRAC's Tranche 2/travel-rule commencement and SWIFT's retail cross-border framework go-live by end-June 2026; the core AFSL licensing perimeter itself is not expected to commence until around 2027, with card-scheme AES migration a longer-horizon marker for December 2030. Australia's risk profile is assessed as elevated and escalating, reflecting the sheer concentration of concurrent reform across licensing, safeguarding, scheme economics, scam liability, operational resilience and settlement access, compounded by record enforcement activity that is already setting de facto conduct standards ahead of the formal perimeter's commencement. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-06-24 Businesses relying on ASIC's sector-wide no-action position for digital assets were required to apply for or vary an Australian Financial Services licence by 30 September 2026, or risk operating in breach of financial services law. Movement — CHANGED RBA moved to evidence-assessment phase following 6 Oct 2026 Summary of Submissions._RBA published Summary of Submissions and announced shift in review phase._ Horizon · 2026-Q4 (±quarter) RBA to publish regulatory-priorities list (Review of Payments System Regulation)_consultation · TT1_ Horizon · 2027-Q2 (±half_year) RBA further consultation on prioritised payments-system-regulation issues_proposed · TT1_ Horizon · 2026-09-30 (±quarter) ASIC digital-asset no-action position expiry / AFS licensing deadline_in_force_pending · TT2_ Horizon · 2027-04-09 (±quarter) Corporations Amendment (Digital Assets Framework) Act 2026 full commencement_adopted · TT1_ Horizon · 2026-10-01 (±quarter) Civil/criminal penalty exposure begins for non-compliant digital-asset firms_in_force_pending · TT2_ Horizon · 2027 (±year) Payments System Modernisation activity-based AFSL licensing commencement_consultation · T1_ Standing sub-brief · as of 5 July 2026 297 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Australia's payments-licensing perimeter is being rebuilt from the ground up. Treasury's Payments System Modernisation program replaces the Corporations Act's "non-cash payment facility" concept with a technology-neutral, activity-based licensing regime that creates new payment financial products - payment instruments and stored value facilities, including tokenised SVFs - and new financial services covering payment facilitation, payment initiation, and payment technology/enablement, generally requiring an Australian Financial Services Licence. A Tranche 1a exposure draft was released on 9 October 2025, with commencement expected around 2027, twelve months after Royal Assent. The architecture is twin-peaks: the Australian Securities and Investments Commission holds conduct and AFSL authority while the Australian Prudential Regulation Authority takes a new non-ADI prudential lane for major stored-value-facility providers holding more than A$200 million in group-aggregate stored value. Separately, a Bill modernising the Payment Systems (Regulation) Act 1998 received Royal Assent on 19 September 2025, broadening the Reserve Bank's designation and oversight remit by widening the statutory definitions of "payment system" and "participant", effective December 2025 - a distinct expansion of RBA reach that runs alongside, rather than inside, the Corporations Act licensing tranche. For non-bank PSPs specifically, the reform is existential: merchant acquirers, remitters, prepaid operators, payment facilitators and point-of-sale technology providers that previously sat outside, or ambiguously within, the NCPF framework will require an AFSL for the first time. Bank-affiliated PSPs face a comparatively lighter incremental burden given existing ADI/AFSL infrastructure, sharpening the bank/non-bank asymmetry this module tracks. #### Outlook Commencement is not expected until roughly 2027, but the exposure-draft stage means affected firms already face a multi-year authorisation planning horizon. Watch for a Tranche 1a final bill, further guidance on the A$200 million SVF prudential threshold, and how APRA and ASIC coordinate dual oversight of stored-value-facility providers that cross into both regimes. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access The Reserve Bank of Australia published its Summary of Submissions to the Review of Payments System Regulation Issues Paper on 6 October 2026, recording responses from 75 stakeholders. From October 2026 the RBA moves out of the consultation phase and into evidence assessment, with a regulatory-priorities list expected by the end of 2026 and further consultation on the substantive review anticipated from mid-2027. This procedural milestone is significant because it marks the point at which the review's direction becomes concrete rather than exploratory. Running in parallel is the Treasury Laws Amendment (Payments System Modernisation) Regulations 2026, whose Tranche 1 exposure draft was released 12 March 2026. The draft would bring stored-value facilities, payment instruments, digital wallets and merchant-acquiring-adjacent services into an Australian Financial Services Licence perimeter. A significant structural feature of the draft is that APRA would gain prudential-standard-setting power over major stored-value-facility providers holding more than AU$200 million in aggregate customer funds or reserves, without those providers thereby being treated as authorised deposit-taking institutions. This creates a distinct prudential tier for large non-bank payment providers, sitting below full banking-style regulation but above the current unregulated or lightly regulated position for most stored-value facilities. Together, these two workstreams indicate Australia's payments licensing perimeter is being substantially redrawn, with the RBA's systemic review and Treasury's instrument-level exposure draft converging on an expanded, risk-tiered licensing and prudential framework for non-bank payment service providers. #### Outlook The RBA's regulatory-priorities list, expected by the end of 2026, will be the next concrete signal of which elements of the systemic review move toward binding rules, with further consultation expected from mid-2027. Separately, the Payments System Modernisation Regulations' progression from exposure draft toward enactment, and the specific commencement date for the AU$200 million APRA prudential threshold, remain the key items to watch for stored-value-facility and digital-wallet providers assessing their licensing obligations. **5 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### 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. Periodic update · new data 2026-09-28 #### 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. Periodic update · new data 2026-09-21 #### 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. Periodic update · new data 2026-09-03 #### 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. Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (5)** 1. T1 [https://treasury.gov.au/policy-topics/banking-and-finance/payments-licensing-reforms](https://treasury.gov.au/policy-topics/banking-and-finance/payments-licensing-reforms) retrieved 2026-06-24 2. T3 [https://www.allens.com.au/insights-news/insights/2025/10/first-tranche-of-payments-licensing-reforms-what-you-need-to-know/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.allens.com.au/insights-news/insights/2025/10/first-tranche-of-payments-licensing-reforms-what-you-need-to-know/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 3. T3 [https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 4. T3 [https://www.ashurst.com/en/insights/treasurys-payments-modernisation-reforms-what-payment-service-providers-must-do-now/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.ashurst.com/en/insights/treasurys-payments-modernisation-reforms-what-payment-service-providers-must-do-now/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 5. T3 [https://www.gtlaw.com.au/insights/key-topics/regulation-in-motion/regulation-of-payment-services-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.gtlaw.com.au/insights/key-topics/regulation-in-motion/regulation-of-payment-services-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-06-24 Australia's Corporations Amendment (Digital Assets Framework) Bill 2025 has received Royal Assent, extending the AFSL licensing perimeter to digital asset platforms and tokenised custody platforms, running alongside the Treasury Laws Amendment (Payments System Modernisation) Bill 2025 which brings BNPL, digital-wallet passthrough and stablecoin payment facilitators within the payments-system regulatory perimeter. Standing sub-brief · as of 5 July 2026 220 words · last cycle 2026-08-03 #### Conduct, Safeguarding & Promotions Tranche 1b of the payments modernisation reform delivers the customer-protection detail underneath the new licensing perimeter. Safeguarding is modelled on the Corporations Act client-money regime, adjusted for payments: the primary method is segregation of payment-related money in a separate trust account with an Australian ADI, with insurance or other prescribed methods available as alternatives, and ASIC-regulated and APRA-regulated entities will operate under separate safeguarding frameworks. A significant conduct change accompanies this: the sophisticated-investor exemption is removed for stored-value facilities, payment instruments and payment services, meaning internal- and external-dispute-resolution obligations (including AFCA membership) now extend even to wholesale dealings that were previously exempt. Tranche 1b also delivers an unclaimed-monies framework, new APRA supervisory powers, and a rule-making power to mandate a revised ePayments Code - the instrument already central to this cycle's HSBC Australia scam-liability judgment (see Legal & Litigation). For non-bank PIs and EMIs, the trust-account segregation requirement is a direct capital and operational-structure determinant, since it fixes how customer funds must be held relative to a bank counterparty rather than leaving safeguarding to commercial discretion. #### Outlook Expect Tranche 1b detail to firm up alongside Tranche 1a commencement planning; the mandatory-ePayments-Code rule-making power is the item most likely to generate near-term secondary consultation, given its direct link to the scam-liability standard already being set through enforcement. Periodic update · new data 2026-07-08 #### Conduct, Safeguarding & Financial Promotions The conduct and safeguarding layer of the Australian payments-reform cycle is as active as the licensing layer, with three distinct developments converging in the 2026–2027 window. The most operationally immediate is the safeguarding requirement introduced under the Payments Systems Modernisation reforms. Non-bank PSPs will be required to segregate payment-related customer money in a trust account held with an Australian ADI. A mandatory, revised ePayments Code will be introduced via a new rule-making power. The trust-account requirement is analytically significant beyond its face value as a consumer-protection measure: it creates a structural dependency of non-bank PSPs on ADIs. To satisfy a statutory safeguarding obligation, a non-bank PSP must maintain or establish a banking relationship with an ADI. In a market where de-risking dynamics have historically constrained non-bank PSPs' access to banking services, this requirement could function as an indirect market-access barrier for smaller or higher-risk entrants. This dynamic will be tested as the licensing reforms come into force and as the RBA's ESA access review (W12) progresses. The digital-asset conduct framework is advancing on a parallel track. The Corporations Amendment (Digital Assets Framework) Act 2025 received royal assent in April 2026 and is scheduled to commence on 8 April 2027. The Act embeds digital-asset licensing concepts within the AFSL framework, meaning that entities providing financial services in relation to digital assets will need to hold or vary an AFSL from that date. ASIC's transitional no-action position for unlicensed digital-asset financial-product services required that an AFSL application or variation be lodged by 30 June 2026 to remain operative. This deadline has passed or is passing at the time of this cycle; entities that did not lodge by that date are no longer covered by the no-action position and face enforcement exposure. The AML/CTF dimension of the digital-asset conduct framework is provided by AUSTRAC's FATF-aligned virtual-asset service provider regime, which commenced on 31 March 2026. The regime requires AUSTRAC registration and an AML/CTF programme for virtual-asset and value-transfer designated services. This finding was surfaced via the W1b licensing lens rather than through a direct Sentinel W11 feed, which was not available for Australia this cycle. The AML/CFT surface for Australian virtual-asset operators should therefore be understood as potentially broader than what this cycle's coverage reflects; a cross-monitor flag has been raised to the Financial Intelligence Monitor. Financial-promotion enforcement — specifically ASIC-specific actions on surcharging or BNPL promotion — was not directly queried this cycle and represents a standing gap. The bank versus non-bank distinction runs through all three developments. The safeguarding trust-account requirement applies to non-bank PSPs, not to ADIs, which are already subject to prudential requirements that address customer-money protection. The digital-asset AFSL and AUSTRAC VASP registration requirements apply to non-bank entities operating in the digital-asset space; ADIs providing digital-asset services will engage with these frameworks differently, typically through existing AFSL and AML/CTF programme structures. #### Outlook The 30 June 2026 ASIC no-action deadline is the most immediate conduct-layer milestone. The Digital Assets Framework Act commences 8 April 2027, giving entities that have lodged AFSL applications a transition window to obtain authorisation before the Act is in force. The safeguarding trust-account requirement will come into force as part of the Tranche 1 licensing package, timing contingent on Parliament. The AUSTRAC VASP regime is already live. The combination of these four developments means that non-bank PSPs operating in or adjacent to the digital-asset space face a compressed multi-front compliance timeline across 2026 and 2027. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://www.gtlaw.com.au/insights/key-topics/regulation-in-motion/regulation-of-payment-services-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.gtlaw.com.au/insights/key-topics/regulation-in-motion/regulation-of-payment-services-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 2. T3 [https://hallandwilcox.com.au/news/treasury-proposes-overhaul-of-payment-system-regulation-what-you-need-to-know/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://hallandwilcox.com.au/news/treasury-proposes-overhaul-of-payment-system-regulation-what-you-need-to-know/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 3. T3 [https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 4. T1 [https://ministers.treasury.gov.au/ministers/daniel-mulino-2025/media-releases/new-legislation-modernise-regulation-payment-service](https://ministers.treasury.gov.au/ministers/daniel-mulino-2025/media-releases/new-legislation-modernise-regulation-payment-service) retrieved 2026-06-24 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-06-24 Australia is moving payment stablecoins into the SVF/digital-money framework rather than a bespoke EMT/ART regime. Under Treasury's draft, payment stablecoins (stable value vs fiat, fully backed by cash/cash-equivalents) are to be regulated as 'payment stablecoin SVFs' / tokenised SVFs, more readily treated as electronic cash, departing from ASIC's prior treatment of stablecoins as NCPFs (ASIC CP 381, Dec 2024). Tokenised SVF providers face additional requirements: monthly reserve disclosures, guaranteed redemption rights, and disclosure of adverse changes/events. Yield-bearing stablecoins remain financial products under separate treatment. A parallel digital-asset/tokenised-custody-platform exposure draft (released 25 Sep 2025) interlocks via shared 'digital token' definitions. The RBA's research (Project Acacia) tested stablecoins, bank deposit tokens and pilot wholesale CBDC as settlement assets. Rules for e-money institutions and payment institutions · from [Cryptoassets.gi](https://cryptoassets.gi) · verified 2026-10-18 - ** Treasury Laws Amendment (Payments System Modernisation) Regulations 2026 (exposure draft) — APRA SVF prudential threshold** — SVF providers (incl. payment stablecoin issuers) become subject to APRA registration and prudential standards where aggregate customer funds/reserves exceed AU$200m. _(consultation; expected 2026-12-31)_ [source, 2026-10-18](https://www.gtlaw.com.au/insights/key-topics/regulation-in-motion/payments-system-modernisation-reforms) _ Not yet covered by Cryptoassets.gi for this jurisdiction: how a fiat-referenced token is classified (e-money, stablecoin, e-money token or asset-referenced token) and the tests that decide it; when a firm issues a stablecoin in the jurisdiction, group and intermediary carve-outs, offer exceptions and local-establishment expectations; e-money token issuance and offer: who may issue, white-paper and reserve requirements, third-country issuer treatment and transitional periods; systemic stablecoin regimes: recognition, backing-asset rules and the joint central bank and conduct regulator regime; cross-border market access for stablecoin and e-money activity between neighbouring regimes and its expiry; what an EMI or PI needs in addition to its licence to offer crypto conversion or stablecoin services, including payment-services treatment of token transfers._ Standing sub-brief · as of 5 July 2026 208 words · last cycle 2026-09-08 #### Stablecoins & Digital Money Australia is charting a distinctive path for payment stablecoins: rather than a bespoke EMT/ART-style regime, Treasury's draft regulates them as "payment stablecoin SVFs" - tokenised stored-value facilities - provided they maintain stable value against fiat and are fully backed by cash or cash-equivalents, more readily treating them as electronic cash than under ASIC's prior non-cash-payment-facility approach set out in Consultation Paper 381 of December 2024. Tokenised SVF providers will face monthly reserve disclosures, guaranteed redemption rights and adverse-event disclosure; yield-bearing stablecoins remain financial products under the existing regime, preserving a bright line between payment-use and investment-use tokens. On the wholesale side, the RBA's Project Acacia concluded that interoperable private tokenised money - stablecoins or tokenised commercial bank deposits - can support asset tokenisation, while central bank money retains a foundational role and many benefits can already be realised using existing Exchange Settlement Account balances, tempering expectations that a general-purpose wholesale CBDC is required to unlock tokenised-asset settlement. #### Outlook Watch for how the tokenised-SVF stablecoin framework interacts with the separate digital-asset and tokenised-custody-platform exposure draft, and for Project Acacia follow-on work (a possible regulatory sandbox, tokenised government bond initiative and Deposit Token Working Group) to further define the settlement-asset landscape for tokenised money in Australia. Periodic update · new data 2026-09-21 #### Stablecoins & Digital Money The RBA published "Retail Central Bank Digital Currency in the Australian Context: An Update" in September 2026, finding no evidence of high domestic adoption of tokenised private money such as stablecoins and reaffirming a broader work programme on tokenised money, assets and payments infrastructure. The same update noted growing interest in stablecoin issuance in Australia as ASIC's new licensing framework comes into view, building on Project Acacia findings that stablecoins and tokenised bank deposits were used as settlement assets in wholesale pilots. Both findings apply across bank and non-bank participants in the tokenised-money ecosystem, consistent with the module's standing convention of tracking bank and non-bank issuance pathways separately. #### Outlook The RBA's tokenised-money work programme continues on a standing basis rather than a dated milestone this cycle, with the growing stablecoin-issuance-interest finding positioned as the operative reference point for issuer and licensing conversations as ASIC's digital-asset licensing framework advances toward its 30 September 2026 and 9 April 2027 milestones tracked under the licensing module. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-07-08 #### Prudential Standards & Capital Requirements No material W2-specific prudential standards or capital-requirements developments were identified for Australia this cycle beyond the APRA SVF oversight threshold noted under W1a. The APRA streamlined registration pathway for SVF operators crossing approximately A$200 million in aggregate stored value is the primary prudential-layer development this cycle and is covered in full under W1a. #### Outlook APRA's detailed prudential standards for registered SVF operators and designated payment-facilitation-service providers will be a key second-order development once the Tranche 1 licensing package passes Parliament. No timeline for APRA consultation on those standards has been confirmed this cycle. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://piperalderman.com.au/insight/australias-payments-system-to-be-overhauled/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 2. T3 [https://afslhouse.com.au/insights/australian-payments-system-modernisation-afsl-guide/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://afslhouse.com.au/insights/australian-payments-system-modernisation-afsl-guide/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 3. T3 [https://www.tglaw.com.au/insights/treasury-releases-draft-legislation-for-the-regulation-of-payment-service-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.tglaw.com.au/insights/treasury-releases-draft-legislation-for-the-regulation-of-payment-service-providers [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) 4. T1 [https://www.rba.gov.au/payments-and-infrastructure/central-bank-digital-currency/wholesale-central-bank-digital-currency/project-acacia/](https://www.rba.gov.au/payments-and-infrastructure/central-bank-digital-currency/wholesale-central-bank-digital-currency/project-acacia/) retrieved 2026-06-24 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-06-24 APRA is to gain new prudential-standard-setting powers over major SVF providers (>AUD 200m aggregate stored value) under the Payment Entities (Prudential Regulation) Bill 2026 exposure draft. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/australia/) Horizon · 2026-07 (±quarter) CPS 230 pre-existing service-provider contract requirements apply_in_force_pending · T1_ Standing sub-brief · as of 5 July 2026 186 words · last cycle 2026-09-28 #### Operational Resilience & Critical Infrastructure APRA's Prudential Standard CPS 230 Operational Risk Management commenced 1 July 2025, replacing the former outsourcing standard (CPS 231) and business-continuity standard (CPS 232). It requires APRA-regulated entities - including ADIs/banks providing payments - to manage operational risks, maintain critical operations within impact tolerances through severe disruptions, and manage material service-provider risk through a formal register and agreements. For pre-existing service-provider contracts, the full requirements apply from the earlier of the contract's next renewal or 1 July 2026, and payments are expected to be classified a "critical" operation, making this a bank-side resilience obligation with direct payments relevance. On 30 April 2026, APRA finalised targeted amendments to CPS 230 introducing a limited exemption from specific contractual requirements for material arrangements with non-traditional service providers - central banks, clearing and settlement facilities, payment systems/schemes and financial messaging infrastructures - recognising that standard commercial-contract terms are often unworkable with such counterparties. #### Outlook The 1 July 2026 deadline for pre-existing contracts is the near-term compliance event to watch; expect continued clarification of how the non-traditional-service-provider exemption applies in practice to payment-system and FMI relationships. Periodic update · new data 2026-09-28 #### Operational Resilience & Critical Infrastructure A new prudential dimension is being introduced into Australia's payments regulatory architecture through the Payment Entities (Prudential Regulation) Bill 2026 exposure draft. Under this proposal, the Australian Prudential Regulation Authority will gain new prudential-standard-setting powers over major stored-value-facility providers, specifically those whose aggregate group credit exceeds AUD 200 million. This creates a genuinely new regulatory tier: these major providers will be required to register with APRA and become subject to prudential standards, but they will not be treated as authorised deposit-taking institutions, meaning they sit outside the full banking-prudential regime while still being subject to a bespoke, non-bank prudential overlay. This bank-PSP versus non-bank distinction is the analytical spine of this development. Australia is not extending full ADI status to large stored-value-facility providers, which would bring the full weight of banking capital, liquidity and governance requirements; instead, it is constructing a parallel, purpose-built prudential regime calibrated to the specific risk profile of stored-value-facility business at scale. This reflects a considered judgment that systemic risk from large non-bank payment providers warrants supervisory attention distinct from, rather than identical to, banking supervision. The AUD 200 million aggregate-group-credit threshold is the operative boundary determining which providers fall within this new prudential perimeter. Providers below that threshold will remain within the conduct-focused AFSL licensing framework being developed under the parallel Tranche 1 reforms, without the additional prudential-standard-setting overlay that APRA will apply to providers above it. #### Outlook The Payment Entities (Prudential Regulation) Bill 2026 remains at exposure-draft stage. Stored-value-facility providers operating at or near the AUD 200 million aggregate-group-credit threshold should monitor the Bill's progression closely, as its finalisation will determine whether they fall within APRA's new prudential perimeter or remain solely within the AFSL conduct framework. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### 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. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-07-08 #### Consumer Protection & Dispute Resolution No standalone W3 consumer-protection or dispute-resolution developments were identified for Australia this cycle. The mandatory revised ePayments Code, which will be introduced via a new rule-making power under the Payments Systems Modernisation reforms, has a consumer-protection dimension and is noted under W1b. The card-surcharge ban (W8) also carries a direct consumer-benefit rationale. #### Outlook The revised ePayments Code will be a W3-relevant development once its content is consulted on and finalised. The RBA's mid-2026 consultation on mobile wallets, BNPL, and e-commerce platforms (W9) may also surface consumer-protection questions relevant to this module. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T1 [https://www.apra.gov.au/operational-risk-management](https://www.apra.gov.au/operational-risk-management) retrieved 2026-06-24 2. T1 [https://handbook.apra.gov.au/standard/cps-230](https://handbook.apra.gov.au/standard/cps-230) retrieved 2026-06-24 3. T1 [https://www.apra.gov.au/final-targeted-amendments-to-cps-230-operational-risk-management](https://www.apra.gov.au/final-targeted-amendments-to-cps-230-operational-risk-management) retrieved 2026-06-24 4. T3 [https://www.twobirds.com/en/insights/2023/australia/apras-cps-230-takes-effect [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]](https://www.twobirds.com/en/insights/2023/australia/apras-cps-230-takes-effect [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]) ### W4 Scheme & Network Compliance Confirmed confirmed 2026-06-24 From 1 October 2026, Visa, Mastercard, American Express and eftpos scheme rules prohibit Australian businesses from surcharging credit, debit and prepaid card payments; merchants may instead recover acceptance costs via overall pricing. Enforcement of the prohibition sits with the card networks and merchant contracts, not the ACCC. Horizon · 2030-12 (±year) Card payments migration to Advanced Encryption Standard (AES)_proposed · T1_ Standing sub-brief · as of 5 July 2026 218 words · last cycle 2026-10-06 #### Scheme & Network Compliance The Reserve Bank's Review of Merchant Card Payment Costs and Surcharging - Issues Paper October 2024, Consultation July 2025, Conclusions Paper March 2026 - has produced the most significant card-scheme rule change in years: a decision to remove surcharging on designated debit, prepaid and credit networks, lower interchange caps (including a new foreign-interchange cap and transparency requirements), and a proposal to lower the domestic credit interchange cap to 0.3%. Australia is unusual in applying both weighted-average benchmarks and individual caps simultaneously (a 0.5% benchmark and 0.8% cap for credit today). These are set under the Payment Systems (Regulation) Act via designated card schemes and RBA Standards; American Express, as a non-designated scheme, operates instead under a voluntary no-surcharge agreement. Separately, the Payments System Board's annual review found a high level of compliance with the RBA's interchange, surcharging and access standards in 2024/25, and expects industry to migrate card payments to the Advanced Encryption Standard by December 2030 - the AU scheme-technical standard item this cycle, distinct from the globally-applicable PCI DSS standard, which applies in Australia via scheme/acquirer contract rather than a bespoke domestic instrument. #### Outlook Implementation of the surcharging ban and revised interchange caps is the item to track through 2026-27; the AES migration deadline of December 2030 is a longer-horizon scheme-technical marker. Periodic update · new data 2026-10-06 #### Scheme & Network Compliance From 1 October 2026, scheme rules prohibit Australian businesses from adding surcharges to payments made using Visa, Mastercard, American Express or eftpos credit, debit and prepaid cards. Merchants retain the ability to recover card-acceptance costs by building them into overall prices, but a separate line-item surcharge on these card types is no longer permitted. The prohibition is set and implemented through each card network's own scheme rules and merchant contracts rather than through a government-enforced statute: the card networks and payment service providers are responsible for enforcing the no-surcharge rule, not the Australian Competition and Consumer Commission. This distinguishes the mechanism of this reform from typical consumer-protection regulation — compliance depends on scheme-level contractual enforcement against merchants and acquirers rather than on a regulator bringing cases directly. The ACCC's role is confined to the pricing-transparency space it already occupies around surcharging more broadly, not to policing this specific scheme-rule prohibition. #### Outlook Because enforcement runs through scheme rules and merchant contracts, the practical test of this reform will be how consistently card networks and acquirers apply it across the merchant base, particularly smaller merchants who may be less familiar with scheme-rule obligations than with ACCC-administered law. Divergence in enforcement intensity between large acquirers and smaller payment facilitators is the main variable to watch over the coming months. **1 earlier distinct update(s)** Periodic update · new data 2026-10-04 #### 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. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-07-08 #### Cross-Border Payments & Remittance No material W4-specific cross-border payments or remittance developments were identified for Australia this cycle. The new foreign-card interchange cap of 1% (down from as high as 2.4%), commencing 1 April 2027, has a cross-border dimension insofar as it applies to foreign-issued cards used in Australia, and is covered in full under W8. #### Outlook The AUSTRAC VASP regime (W1b) has cross-border value-transfer implications for remittance operators using virtual-asset rails. The W4 surface for Australia remains under-indexed this cycle. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (5)** 1. T1 RBA — Review of Merchant Card Payment Costs & Surcharging, Conclusions Paper Mar 2026 (rba.gov.au) 2. T1 [https://www.rba.gov.au/media-releases/2025/mr-25-19.html](https://www.rba.gov.au/media-releases/2025/mr-25-19.html) retrieved 2026-06-24 3. T1 [https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/introduction.html](https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/introduction.html) retrieved 2026-06-24 4. T1 [https://www.rba.gov.au/media-releases/2025/mr-25-32.html](https://www.rba.gov.au/media-releases/2025/mr-25-32.html) retrieved 2026-06-24 5. T1 [https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/pdf/conclusions-paper.pdf](https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/pdf/conclusions-paper.pdf) retrieved 2026-06-24 ### W5 Payment Corridor Dynamics Confirmed confirmed 2026-06-24 RBA's card-surcharging and interchange-fee reforms (Conclusions Paper, 31 March 2026) took effect from 1 October 2026: no-surcharge rules on designated eftpos/Mastercard/Visa networks, lower domestic interchange caps, and new merchant fee-transparency duties. Foreign-card interchange caps (1.0%) follow from 1 April 2027. Horizon · 2026-06 (±quarter) SWIFT retail cross-border framework go-live (Australia among initial corridors)_in_force_pending · T2_ Standing sub-brief · as of 5 July 2026 213 words · last cycle 2026-10-12 #### Payment Corridor Dynamics Per the RBA's February 2026 Bulletin, transferring A$1,000 via major banks' international money-transfer services cost around 4% to advanced countries and 6% to developing countries in September 2025 - above the G20 ceilings of 3% and 5% respectively - while non-bank IMT costs to developing countries, at around 2%, beat the target. Australia also remains well below the G20's speed target of settling 75% of transfers within one hour, partly attributable to timezone factors; banks are working to enhance domestic legs, including 24/7 capability and leveraging the New Payments Platform. The Australia-Pacific remittance corridor illustrates an under-covered inclusion risk: fragile connectivity and concentration risk, with a single bank in some cases providing correspondent services to several money-transfer operators, driven by reduced bank risk appetite and rising AML/CFT compliance costs, per IMF and AUSTRAC analysis. Australia is among the initial corridors in SWIFT's new retail cross-border payments framework, with more than 25 banks - including ANZ, Commonwealth Bank, NAB and Westpac - going live by end-June 2026 to deliver cost certainty, full-value delivery and traceability. #### Outlook Watch for the SWIFT retail framework go-live by end-June 2026 and for whether bank IMT pricing to developing countries narrows toward the G20 ceiling; the Pacific corridor's concentration risk remains a standing fragility to monitor. Periodic update · new data 2026-10-12 #### Payment Corridor Dynamics The Reserve Bank of Australia's no-surcharge rules and new domestic interchange caps took legal effect from 1 October 2026 under amended RBA Standards Nos 1-3, which were registered 14 April 2026. Domestic debit and prepaid interchange is now capped at 8 cents or 0.16 percent ad valorem, and domestic consumer-credit interchange at 0.3 percent. Foreign-card interchange caps of 1.0 percent follow from 1 April 2027, giving card schemes and acquirers a staged transition rather than a single cutover. This reform crystallises a multi-year RBA review process into binding law and directly reshapes the cost structure merchants and acquirers face on card transactions in Australia. Alongside the interchange and surcharge reforms taking effect, the RBA published on 6 October 2026 its Summary of Submissions to the Review of Payments System Regulation Issues Paper, a broader and ongoing review distinct from the interchange reforms already in force. Stakeholder submissions summarised in that paper flagged concern that premature RBA intervention in account-to-account payments may be unwarranted, and separately surfaced new fraud and security risk concerns specific to agentic payments, an emerging category tied to automated or AI-driven payment initiation. Submissions also flagged PayTo fragmentation, referring to inconsistent implementation of Australia's account-to-account PayTo payment initiation service, as an unresolved issue requiring further regulatory attention. Separately, federal political scrutiny continued into this cycle over the scope of the surcharge reforms, with debate over whether the RBA or government made the decision to also ban credit-card payments to the Australian Taxation Office, and a Labor minister reported pressing the RBA to go further on the card-surcharge ban. #### Outlook The foreign-card interchange cap taking effect 1 April 2027 is the next scheduled milestone in this corridor. More open-ended is the RBA's ongoing Review of Payments System Regulation, which will need to resolve the account-to-account intervention question, the PayTo fragmentation issue, and the newly surfaced agentic-payment fraud and security risk concerns raised in the submissions summary. Continued political scrutiny of the surcharge ban's scope indicates the reform package's precise boundaries may remain contested even after its legal effect. **2 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### 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. Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T1 [https://www.rba.gov.au/publications/bulletin/2026/feb/on-the-road-to-better-cross-border-payments-how-is-australia-travelling.html](https://www.rba.gov.au/publications/bulletin/2026/feb/on-the-road-to-better-cross-border-payments-how-is-australia-travelling.html) retrieved 2026-06-24 2. T1 [https://www.rba.gov.au/publications/bulletin/2026/feb/pdf/bulletin-2026-02.pdf](https://www.rba.gov.au/publications/bulletin/2026/feb/pdf/bulletin-2026-02.pdf) retrieved 2026-06-24 3. T1 [https://imf.org/-/media/Files/Publications/CR/2025/English/1wsmea2025002-print-pdf.ashx](https://imf.org/-/media/Files/Publications/CR/2025/English/1wsmea2025002-print-pdf.ashx) retrieved 2026-06-24 4. T2 [https://www.swift.com/news-events/press-releases/swift-accelerates-transformation-consumer-payments-banks-roll-out-new-framework-retail-transactions](https://www.swift.com/news-events/press-releases/swift-accelerates-transformation-consumer-payments-banks-roll-out-new-framework-retail-transactions) retrieved 2026-06-24 ### W6 Industry Structure & Commercial limited signal Probable confirmed 2026-06-24 Australia's payments market is bank-dominated at the rails layer (four major banks: ANZ, CBA, NAB, Westpac) but with a vibrant fintech/non-bank PSP layer. Payments is the most mature fintech segment (~150+ active firms, ~20% of the fintech landscape). Domestic shared infrastructure is consolidated under Australian Payments Plus (AP+), which operates the NPP, eftpos and BPAY. Key non-bank/listed players include Tyro (ASX:TYR), Cuscal (ASX:CCL), Zip, EML Payments, Change Financial and Novatti; private/scale-ups include Airwallex (US$6.2bn valuation) and Zeller (100k+ merchants). Block's 2022 takeover of Afterpay illustrated global appetite for domestic distribution. Consolidation among payment specialists is accelerating (e.g., Banking Circle's January 2025 acquisition of Australian Settlements Limited for real-time clearing). NPP volumes exceed 100 million/month with roughly one in three account transfers riding the network. Standing sub-brief · as of 5 July 2026 151 words · last cycle 2026-09-28 #### Industry Structure & Commercial Australia's payments market is bank-dominated at the rails layer - ANZ, Commonwealth Bank, NAB and Westpac remain the four major banks - alongside a vibrant fintech and non-bank PSP layer of more than 150 active firms, representing roughly a fifth of the broader fintech landscape. Domestic shared infrastructure is consolidated under Australian Payments Plus, which operates the New Payments Platform, eftpos and BPAY; NPP volumes exceed 100 million transactions a month, about one in three account transfers. Key listed and scaled non-bank players include Tyro, Cuscal, Zip, EML Payments, Change Financial and Novatti, alongside private scale-ups such as Airwallex and Zeller. #### Outlook The structural picture - bank-controlled rails, non-bank innovation layer, consolidated shared infrastructure - forms the backdrop against which the AFSL licensing perimeter, Common Access Requirements and surcharging reforms will play out; consolidation among listed and private non-bank PSPs is likely to continue (see Commercial Intelligence). Periodic update · new data 2026-09-28 #### Industry Structure & Commercial Dynamics Treasury has signalled directional interest in a later-2026 review of the ePayments Code and in common-access-regime work, indicating that Australia's payments-industry structural reform agenda extends beyond the Tranche 1 licensing and prudential reforms already in exposure-draft form. Specifically, Treasury has indicated it will consider common access requirements and the establishment of an industry standard-setting body, though this remains a directional signal without a confirmed timeline or committed legislative vehicle at this stage. Separately, the Reserve Bank of Australia's position on merchant surcharging remains open and unresolved. No development in the material available this cycle clarified the RBA's likely direction on this question, and it should be tracked as a distinct, unsettled thread from the Treasury-led licensing and prudential reforms. Taken together, these signals suggest that Australia's payments-industry structural reform agenda for 2026 has at least three separate strands moving at different speeds: the advanced Tranche 1 AFSL-licensing exposure draft (consultation already closed), the parallel APRA prudential-regime exposure draft, and the earlier-stage, undated ePayments Code review and common-access-regime consideration. Market participants should not assume these three strands will move in lockstep or converge on a single implementation timeline. #### Outlook No committed timeline has been confirmed for either the ePayments Code review or the RBA's merchant-surcharging position. Both should be treated as slower-moving, earlier-stage threads relative to the Tranche 1 licensing reforms, and watched for further Treasury or RBA signalling in coming cycles. **1 earlier distinct update(s)** Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://paymentscmi.com/insights/australia-2025-analysis-payments-ecommerce-trends/](https://paymentscmi.com/insights/australia-2025-analysis-payments-ecommerce-trends/) retrieved 2026-06-24 2. T3 [https://www.mordorintelligence.com/industry-reports/australia-fintech-market](https://www.mordorintelligence.com/industry-reports/australia-fintech-market) retrieved 2026-06-24 3. T3 [https://stockhead.com.au/news/hot-money-monday-asx-fintechs-could-ride-tailwind-as-airwallex-soars-to-6bn-valuation/](https://stockhead.com.au/news/hot-money-monday-asx-fintechs-could-ride-tailwind-as-airwallex-soars-to-6bn-valuation/) retrieved 2026-06-24 4. T3 [https://cfotech.com.au/story/banking-circle-joins-ap-committee-to-boost-fintech-pay](https://cfotech.com.au/story/banking-circle-joins-ap-committee-to-boost-fintech-pay) retrieved 2026-06-24 ### W7 Legal & Litigation Confirmed confirmed 2026-06-24 ASIC secured A$349.8 million in court-ordered civil penalties for 1 July-31 December 2025 (its highest six-monthly total at that point) and a record A$830 million in court-ordered civil penalties for the 2025-26 financial year overall, including A$480 million for 1 January-30 June 2026. Standing sub-brief · as of 5 July 2026 229 words · last cycle 2026-10-06 #### Legal & Litigation The Federal Court ordered HSBC Australia to pay A$35 million on 18 June 2026 for scam-protection failures - one of the first such cases globally - with the judge finding its ePayments Code failures systemic and widespread and its average scam-report investigation time of 144 days inadequate; the judgment sets a "scam controls = licence-to-operate" expectation and forms part of ASIC's record A$349.8 million in penalties across the second half of 2025. FIIG Securities was ordered on 9 February 2026 to pay A$2.5 million - the first time the Federal Court has imposed civil penalties for cyber-security failures under general AFS licensee obligations (section 912A) - following a 2023 attack that exfiltrated approximately 385 gigabytes of client data, and follows the RI Advice case of 2022 and ongoing Fortnum Private Wealth proceedings filed in July 2025. BPS Financial, operator of the Qoin crypto-token product, faced A$14 million in penalties after ASIC's Full Court appeal win of 30 May 2025 - A$2 million for unlicensed conduct and A$12 million for misleading and deceptive conduct - with ASIC signalling continued focus on the digital-asset industry. #### Outlook Cyber resilience and scam controls are now established conduct obligations with direct financial consequence; expect continued enforcement activity as the ePayments Code, CPS 230 and the incoming AFSL perimeter combine to raise the compliance bar for both bank and non-bank payment providers. Periodic update · new data 2026-10-06 #### Legal & Litigation ASIC's enforcement record showed sustained intensity across two consecutive reporting periods. The regulator secured approximately A$349.8 million in court-ordered civil penalties for the second half of 2025, which it described as the highest six-monthly total in the agency's history. That pace continued into the following financial year: ASIC's results for 2025-26 show a full-year total of A$830 million in court-ordered civil penalties and orders, of which A$480 million was secured between January and June 2026, alongside A$644 million returned to Australians over the same financial year. #### Outlook The consecutive record totals across H2 2025 and FY2025-26 point to enforcement capacity that has been sustained rather than concentrated in a single reporting spike, and the first half of 2026 alone already matched a large share of the prior full-year record. Whether this pace is maintained into the next reporting period is the figure to watch, given it would confirm a structural increase in enforcement intensity rather than a one-off result. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-07-08 #### Digital Currency & Tokenisation No standalone W7 CBDC or tokenisation developments were identified for Australia this cycle. The Corporations Amendment (Digital Assets Framework) Act 2025 (W1b) is the primary digital-asset regulatory development this cycle; its commencement on 8 April 2027 will embed digital-asset licensing concepts within the AFSL framework, which has indirect relevance to tokenised-asset and stablecoin operators. #### Outlook The Digital Assets Framework Act commencement in April 2027 is the primary W7-adjacent horizon item. No RBA CBDC consultation or pilot development was identified this cycle. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://iclg.com/news/hsbc-australia-hit-with-hefty-penalty-over-scam-protection-failings/](https://iclg.com/news/hsbc-australia-hit-with-hefty-penalty-over-scam-protection-failings/) retrieved 2026-06-24 2. T1 [https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2026-releases/26-021mr-asic-action-sees-fiig-securities-ordered-to-pay-2-5-million-over-cyber-security-failures/](https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2026-releases/26-021mr-asic-action-sees-fiig-securities-ordered-to-pay-2-5-million-over-cyber-security-failures/) retrieved 2026-06-24 3. T3 [https://www.thelawyermag.com/au/practice-areas/banking-and-finance/federal-court-slaps-14m-penalty-on-company-behind-crypto-product-qoin/563826](https://www.thelawyermag.com/au/practice-areas/banking-and-finance/federal-court-slaps-14m-penalty-on-company-behind-crypto-product-qoin/563826) retrieved 2026-06-24 4. T1 [https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2026-releases/26-032mr-asic-secures-record-350-million-in-civil-penalties-and-583-million-back-to-australians-in-second-half-of-2025/](https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2026-releases/26-032mr-asic-secures-record-350-million-in-civil-penalties-and-583-million-back-to-australians-in-second-half-of-2025/) retrieved 2026-06-24 ### W8 Merchant Acquiring & Risk moved Probable confirmed 2026-06-24 Merchant acquiring in Australia operates through bank acquirers (CBA, NAB, Westpac, ANZ) and non-bank players (Tyro, Zeller, Square/Block, Stripe, Adyen, Worldpay). Acquirers are subject to RBA card-payments standards (interchange, surcharging, access regimes) and PCI DSS. Surcharging is currently permitted up to cost-of-acceptance (ACCC-enforced) but the RBA has decided to remove surcharging on designated networks; ~16% of merchants currently surcharge designated cards (~A$1.6bn paid by consumers, ~A$0.2bn by businesses). Acquiring/onboarding will be brought into the AFSL perimeter under the payments modernisation reforms (merchant acquirers explicitly named as Payment Facilitation Service providers requiring an AFSL or authorised-representative status). Pricing transparency reforms will require large acquirers to publish fees. Typical acquiring economics: e.g., Zeller charges ~1.4% per in-person tap/insert transaction. Movement — CHANGED No-surcharge and interchange-cap reforms took effect 1 October 2026._RBA merchant card payment cost reforms reached their effective date this cycle._ Standing sub-brief · as of 5 July 2026 135 words · last cycle 2026-10-18 #### Merchant Acquiring & Risk Independent estimates indicate roughly 16% of merchants surcharged designated network card payments, with about A$1.6 billion paid by consumers and A$0.2 billion by businesses; the RBA's decision to remove surcharging on designated networks redistributes this cost across the merchant-acquirer-scheme chain. At the same time, merchant acquirers, payment facilitators and point-of-sale technology providers will be brought into the AFSL regime as Payment Facilitation Service providers, and large acquirers will be required to publish their fees - a transparency reform that directly affects acquirer pricing and competitive positioning (illustratively, Zeller currently charges around 1.4% per in-person tap/insert transaction). #### Outlook The dual reset of surcharging economics and acquirer licensing status is likely to compress margins for smaller acquirers while favouring scaled, AFSL-ready platforms; fee-transparency obligations for large acquirers are the near-term item to track. Periodic update · new data 2026-10-18 #### Merchant Acquiring & Risk The Reserve Bank of Australia's Review of Merchant Card Payment Costs and Surcharging took effect 1 October 2026, materially restructuring the economics of card acceptance in Australia. No-surcharge rules now apply across eftpos, Mastercard and Visa designated systems for debit, prepaid and credit cards, removing merchants' ability to pass card-processing costs directly to customers at the point of sale for these schemes. Domestic debit and prepaid interchange is now capped at 8 cents per transaction or 0.16 percent ad valorem, whichever applies, while consumer credit interchange is capped at 0.3 percent, down substantially from the prior 0.8 percent. The RBA has also abolished the weighted-average interchange benchmark that previously governed scheme-level interchange settings. A foreign-card interchange cap and further cost-transparency changes were considered as part of the same package but have been deferred to 1 April 2027, giving the industry additional implementation time for the more technically complex cross-border elements of the reform. Two new transparency and anti-circumvention measures accompany the cap changes. Acquirers must publish a measure of interchange pass-through quarterly for the first four quarters from 1 October 2026, with the first publication due by 30 January 2027, giving merchants and regulators visibility into whether reduced interchange costs are actually being passed through to the merchant level. Separately, issuer net-compensation rules have been extended to capture all Australian issuers, including foreign-sponsored ones, closing a route by which issuers could previously structure compensation arrangements with schemes to circumvent the interchange caps. #### Outlook The foreign-card interchange cap and further cost-transparency changes take effect 1 April 2027, completing the second phase of this reform package. The first quarterly interchange pass-through publication is due 30 January 2027, which will be the first public test of whether the reduced interchange caps are translating into lower merchant costs. Acquirers, issuers and merchants should treat the next two quarters as the period in which the practical effect of the October 2026 changes becomes measurable. **1 earlier distinct update(s)** Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T1 [https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/pdf/conclusions-paper.pdf](https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/pdf/conclusions-paper.pdf) retrieved 2026-06-24 2. T3 [https://www.ashurst.com/en/insights/treasurys-payments-modernisation-reforms-what-payment-service-providers-must-do-now/](https://www.ashurst.com/en/insights/treasurys-payments-modernisation-reforms-what-payment-service-providers-must-do-now/) retrieved 2026-06-24 3. T1 [https://www.rba.gov.au/media-releases/2025/mr-25-19.html](https://www.rba.gov.au/media-releases/2025/mr-25-19.html) retrieved 2026-06-24 4. T3 [https://www.airwallex.com/en-au/blog/zeller-business-transaction-account-review](https://www.airwallex.com/en-au/blog/zeller-business-transaction-account-review) retrieved 2026-06-24 ### W9 Product Innovation & Market Development Confirmed confirmed 2026-06-24 Payment stablecoins routed into the tokenised SVF regime (monthly reserve disclosure, guaranteed redemption) rather than the Digital Assets Framework; major SVF prudential category proposed at A$200m aggregate-credit threshold. Standing sub-brief · as of 5 July 2026 180 words · last cycle 2026-10-18 #### Product Innovation & Market Development The RBA and Digital Finance Cooperative Research Centre's Project Acacia (Phase 2, 2025-26) tested 24 use cases spanning stablecoins, bank deposit tokens and pilot wholesale CBDC. Its Final Report, published 19 May 2026, issued a pilot wholesale CBDC directly onto third-party distributed-ledger platforms - a world-first, with total issuance of A$4.4 million - under ASIC regulatory relief, found strong tokenisation potential, and launched follow-on work including a possible regulatory sandbox, a tokenised government bond initiative and a Deposit Token Working Group. Australia's domestic real-time rail remains the NPP, via PayID and PayTo. Separately, from 10 June 2025, buy-now-pay-later providers must hold a credit licence under the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024, bringing BNPL inside the consumer-credit perimeter with responsible-lending obligations and AFCA membership. #### Outlook Project Acacia's follow-on initiatives - the possible sandbox, tokenised bond work and Deposit Token Working Group - are the items most likely to generate the next wave of product-innovation news; BNPL's credit-licensing regime is now a settled baseline rather than a live development. Periodic update · new data 2026-10-18 #### Product Innovation & Market Development The Treasury Laws Amendment (Payments System Modernisation) Tranche 1 exposure draft introduces a defined "Tokenised Stored Value Facility" category, a specific stored-value-facility sub-type intended to capture fiat-backed stablecoin arrangements where redemption is linked to a digital token. This is a structural product-classification development: rather than treating stablecoins as falling ambiguously within or outside existing payment-instrument categories, the draft would create a named regulatory product type for them within the broader stored-value-facility framework, bringing the APRA prudential threshold and AFSL licensing perimeter described elsewhere to bear specifically on tokenised, fiat-backed instruments. Separately, instant-payments infrastructure continues to show mixed adoption. The RBA's March 2026 risk assessment of decommissioning the Bulk Electronic Clearing System concluded that PayTo, the New Payments Platform's account-to-account payment-initiation service, has yet to demonstrate its maturity as a replacement for direct debit. Growth in PayTo usage has come mostly from new payment agreements being established on the platform rather than from migration of existing direct-debit arrangements away from the legacy system. This matters for market-development assessment because it indicates that, despite PayTo's availability, the network effects and switching behaviour needed to retire the older direct-debit infrastructure have not yet materialised at scale. #### Outlook The Tokenised Stored Value Facility category's progression from exposure draft toward enacted regulation is the key item to watch for stablecoin-adjacent product development in Australia. For instant payments, the RBA's continuing assessment of Bulk Electronic Clearing System decommissioning will depend on whether PayTo's migration-versus-new-agreement balance shifts toward genuine displacement of direct debit over the coming reporting periods. **2 earlier distinct update(s)** Periodic update · new data 2026-09-03 #### 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. Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T1 [https://www.rba.gov.au/payments-and-infrastructure/central-bank-digital-currency/wholesale-central-bank-digital-currency/project-acacia/](https://www.rba.gov.au/payments-and-infrastructure/central-bank-digital-currency/wholesale-central-bank-digital-currency/project-acacia/) retrieved 2026-06-24 2. T1 [https://www.rba.gov.au/media-releases/2025/mr-25-18.html](https://www.rba.gov.au/media-releases/2025/mr-25-18.html) retrieved 2026-06-24 3. T3 [https://genfinity.io/2026/05/26/project-acacia-final-report-rba-dfcrc-tokenised-finance/](https://genfinity.io/2026/05/26/project-acacia-final-report-rba-dfcrc-tokenised-finance/) retrieved 2026-06-24 4. T3 [https://www.assuredsupport.com.au/articles/australias-new-payments-licensing-and-compliance-framework-preparing-for-june-2025/](https://www.assuredsupport.com.au/articles/australias-new-payments-licensing-and-compliance-framework-preparing-for-june-2025/) retrieved 2026-06-24 ### W10 Consumer Protection & APP Fraud moved Confirmed confirmed 2026-06-24 Entities designated under the Scams Prevention Framework (banking, telecommunications, digital platforms) were required to be AFCA members by 1 September 2026. Most substantive SPF obligations are scheduled to commence 31 March 2027, with the remaining tranche expected by end-2027; SPF codes and rules remained under development by Government as of 20 August 2026. Movement — CHANGED SPF Rules commenced 1 September 2026; AFCA membership deadline met._SPF implementation milestone reached._ Horizon · 2026-07 (±quarter) Scams Prevention Framework first sector obligations take effect_in_force_pending · T3_ Standing sub-brief · as of 5 July 2026 204 words · last cycle 2026-10-18 #### Consumer Protection & APP Fraud The Scams Prevention Framework, established under Part IVF of the Competition and Consumer Act 2010 via the Scams Prevention Framework Act 2025 and commenced 21 February 2025, is a principles-based, whole-of-ecosystem regime - govern, prevent, detect, disrupt, respond, report - applying first to banks (regulated by ASIC), telecommunications carriers (ACMA) and digital platforms (ACCC), with civil penalties reaching A$50 million per contravention. Unlike the UK Payment Systems Regulator's reimbursement model, the SPF originally did not mandate reimbursement, with redress running through internal and external dispute resolution (AFCA) and court action; first sector obligations target effect from 1 July 2026. On 28 May 2026, Treasury released draft SPF rules and sector codes proposing a reimbursement scheme with a A$3,000 threshold and an equal-liability apportionment model - a shift toward automatic reimbursement below that threshold and a degree of convergence with the UK approach. Scam losses were around A$2 billion in 2025, down from a 2022 peak of A$3.1 billion, though the trend is reversing. #### Outlook The 1 July 2026 first-sector-obligation date and the finalisation of the A$3,000 reimbursement threshold are the two events to track; the multi-regulator structure (ASIC/ACMA/ACCC) means implementation coordination across sectors is itself a risk to monitor. Periodic update · new data 2026-10-18 #### Consumer Protection & APP Fraud The Scams Prevention Framework Rules commenced 1 September 2026, establishing a phased compliance timeline for entities in the banking, telecommunications and digital-platform sectors. By the 1 September 2026 commencement date, covered entities were required to be members of the Australian Financial Complaints Authority. The more substantive obligations — to prevent, detect, disrupt, report and respond to scams, together with compliance-statement and record-keeping duties — commence 31 March 2027. These substantive obligations are backed by civil penalties of up to AU$50 million per contravention, a substantial deterrent figure reflecting the framework's intent to drive genuine operational investment in scam prevention rather than nominal compliance. The framework's enforcement architecture is split across three regulators by sector: ASIC for banks, ACMA for telecommunications providers, and the ACCC for digital platforms and as the framework's general regulator. Affected consumers additionally gain a private right of action for damages, and AFCA is designated as the sole external dispute-resolution body for scam-related complaints across all three covered sectors, giving consumers a single point of recourse regardless of which sector failed to prevent, detect or respond to a scam. #### Outlook 31 March 2027 is the date by which the Scams Prevention Framework's substantive prevent, detect, disrupt, report and respond obligations, and the associated compliance-statement and record-keeping duties, take full effect, alongside the instrument expected to authorise AFCA as the sole external dispute-resolution scheme. Banking, telecommunications and digital-platform entities should treat the period between now and that date as the implementation window for building out the operational capability the civil-penalty regime is designed to incentivise. **2 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### 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. Periodic update · new data 2026-09-21 #### 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. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-07-08 #### Data, Privacy & Open Banking No material W10-specific data, privacy, or open-banking developments were identified for Australia this cycle. Australia's Consumer Data Right framework, which underpins open banking, was not the subject of any new regulatory development captured this cycle. #### Outlook The W10 surface for Australia remains stable this cycle. Future cycles should monitor CDR expansion to additional sectors and any interaction between the CDR framework and the new payment-initiation service category introduced under the Tranche 1 licensing reforms. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://www.corrs.com.au/insights/the-new-scams-prevention-framework-key-considerations-for-regulated-entities](https://www.corrs.com.au/insights/the-new-scams-prevention-framework-key-considerations-for-regulated-entities) retrieved 2026-06-24 2. T3 [https://www.gtlaw.com.au/insights/click-here-australias-scam-prevention-framework-takes-shape](https://www.gtlaw.com.au/insights/click-here-australias-scam-prevention-framework-takes-shape) retrieved 2026-06-24 3. T3 [https://amjid.au/insights/australias-scams-prevention-framework-operators-guide/](https://amjid.au/insights/australias-scams-prevention-framework-operators-guide/) retrieved 2026-06-24 4. T3 [https://www.gtlaw.com.au/insights/the-scams-prevention-framework-legislation-passes-parliament-time-to-get-your-house-in-order2](https://www.gtlaw.com.au/insights/the-scams-prevention-framework-legislation-passes-parliament-time-to-get-your-house-in-order2) retrieved 2026-06-24 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/australia/#sec-dom-D7) limited signal Confirmed confirmed 2026-06-24 [Sentinel.gi position, payments context only] Australia's AML/CTF regime is administered by AUSTRAC under the AML/CTF Act 2006. Tranche-1 reporting entities (banks, remittance providers, digital currency exchanges, casinos) are long-regulated. The AML/CTF Amendment Act 2024 delivers major reform: 'Tranche 2' extends obligations to DNFBPs (lawyers, accountants, real estate, dealers in precious metals/stones) from 1 July 2026, expanding the regulated population to ~100,000 entities; new virtual-asset services and CDD/program changes commenced 31 March 2026. The reforms streamline funds-transfer/remittance concepts into a single value-transfer chain, replace IFTI with International Value Transfer Service (IVTS) reports, and introduce a 'travel rule' for money, virtual-asset and property transfers (from 31 March 2026, with VA travel-rule from 1 July 2026). FTR Act repealed 7 January 2025; tipping-off offence reframed 31 March 2025. Transitional rules give phased CDD/compliance-officer timelines. Horizon · 2026-07 (±quarter) AML/CTF Tranche 2 DNFBP obligations + virtual-asset travel rule_in_force_pending · T1_ Standing sub-brief · as of 5 July 2026 181 words · last cycle 2026-10-04 #### AML/CFT & Financial Crime (Sentinel.gi-fed) This module is carried as a Sentinel.gi position only; no original illicit-finance analysis is performed here, and the underlying intelligence is routed to the Financial Integrity Monitor. Per Sentinel.gi, AUSTRAC's AML/CTF reforms under the Amendment Act 2024 close gaps against international standards: customer-due-diligence and reporting-entity program changes started 31 March 2026 unless deferred under transitional rules, the Financial Transaction Reports Act was repealed 7 January 2025, and Tranche 2 extends obligations to designated non-financial businesses and professions from 1 July 2026, across a regulated population of roughly 100,000 entities. Sentinel.gi also reports that the Amendment Act streamlines funds-transfer and designated-remittance concepts into a single value-transfer chain and introduces International Value Transfer Service reports replacing International Funds Transfer Instruction reports, with a travel rule applying to money and property from 31 March 2026 and to virtual-asset transfers from 1 July 2026; existing digital currency exchanges automatically transition to virtual-asset-service-provider status. #### Outlook Per Sentinel.gi, the 1 July 2026 Tranche 2/travel-rule commencement is the key date; for original illicit-finance analysis of these reforms, refer to the Financial Integrity Monitor. Periodic update · new data 2026-10-04 #### AML/CFT & Financial Crime AUSTRAC issued its first infringement notices to non-enrolled Tranche 2 businesses, spanning real estate, accounting and jewellery sectors, between 30 September and 2 October 2026. Penalties run up to AUD 21,840 per company, accruing daily, for failure to enrol under obligations that commenced 1 July 2026. This development is carried here as a subscribed item fed from financial-crime intelligence monitoring; it is presented without independent payments-sector analysis. The relevance to payments-sector participants is that several of the newly covered sectors, particularly real estate and professional-services firms handling large transactions, intersect with payment flows that non-bank payment service providers and acquirers may process. The enforcement wave signals that these obligations, which commenced three months prior to this infringement-notice action, are now being actively supervised rather than left to voluntary compliance. #### Outlook Further detail on the scope, trajectory and substantive implications of this enforcement development is tracked by the financial-crime monitoring function that supplies this item; no additional payments-sector-specific outlook is offered here beyond noting that the enforcement phase is active as of this period. **1 earlier distinct update(s)** Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (5)** 1. T3 sentinel://moodys.com/kyc/tranche-2-reforms-australia 2. T? FIM (sentinel.gi) per-JID baseline profile — Australia — AML/CTF Act 2006 supervised by AUSTRAC covers banks, remitters, gambling and bullion; DNFBPs (lawyers, accountants, real estate agents, TCSPs) remain outside obligations until Tranche 2 reforms commence 1 July 2026, alongside new VASP registration, transaction-monitoring and Travel Rule requirements. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap 5. T3 FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-003) — ASIC Digital Assets Framework Act commencement ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-06-24 Settlement of high-value and NPP payments occurs through the RBA's Reserve Bank Information and Transfer System (RITS), with exchange settlement accounts (ESAs) held at the RBA; the NPP's Fast Settlement Service settles in real time on ESAs. Direct settlement/ESA access has historically been bank-centric, but the payments modernisation reforms introduce Common Access Requirements (CARs, APRA-administered under Tranche 2) intended to facilitate direct access to payment systems for non-ADI PSPs, promoting competition. Correspondent banking faces de-risking pressure, particularly on South Pacific remittance corridors where concentration and reduced bank risk-appetite create fragile AUD/NZD connectivity. Project Acacia tested settlement via ESAs, PayTo/NPP Fast Settlement Service and pilot wholesale CBDC for tokenised assets (e.g., Westpac demonstrated PayTo settling tokenised term-deposit transactions into RITS without wCBDC; Northern Trust settled tokenised carbon credits via SWIFT into RITS). The RBA is operationalising crisis-resolution powers for clearing and settlement facilities. Horizon · 2026-Q3 (±half_year) RBA Exchange Settlement Account access-policy review commences_proposed · TT1_ Standing sub-brief · as of 5 July 2026 171 words · last cycle 2026-08-03 #### Correspondent Banking, Settlement & Access This module's analytical spine is the bank/non-bank access asymmetry in Australian settlement infrastructure. Settlement of high-value and NPP payments runs through the Reserve Bank's RITS system via Exchange Settlement Accounts, with the NPP's Fast Settlement Service settling in real time on those accounts - access that has historically been bank-centric. The payments modernisation reforms introduce Common Access Requirements, APRA-administered under Tranche 2, intended to facilitate direct access to Australian payment systems for non-ADI PSPs and promote competition, opening a settlement layer non-bank providers have previously had to access only through bank sponsors. Separately, the Payments System Board welcomed progress operationalising powers to prevent or resolve a crisis at an Australian clearing and settlement facility, with guidance on the RBA's crisis-resolution powers expected in December 2025. #### Outlook The Common Access Requirements are the item most likely to reshape non-bank PSP competitive positioning, by reducing dependence on bank sponsors for direct settlement access; watch for APRA's Tranche 2 detail on eligibility and for the December 2025 crisis-resolution guidance. Periodic update · new data 2026-07-08 #### Correspondent Banking, Settlement & Access The analytical spine of W12 is the asymmetry between ADIs — which hold full prudential authorisation and direct Exchange Settlement Account access — and non-bank payment institutions, which access the payments system through ADI intermediaries. The Australian payments-reform cycle is now directly engaging with this asymmetry, though the resolution is deferred to a review that has not yet commenced. The Reserve Bank of Australia has confirmed it will review its Exchange Settlement Account access policy commencing H2 2026, contingent on the first tranche of PSP-licensing reforms having passed Parliament. The second phase of that review includes proposed common-access requirements under which APRA would set proportionate regulatory arrangements for non-bank PSPs seeking direct ESA access. This sequencing is significant: the licensing reforms that bring non-bank PSPs into the regulatory perimeter are intended to precede the access-policy review, on the logic that a non-bank PSP seeking direct central-bank settlement access should first be subject to a formal regulatory framework. The bank versus non-bank access asymmetry has a second dimension in the current reform cycle: the safeguarding trust-account requirement (W1b) mandates that non-bank PSPs hold customer money in a trust account with an Australian ADI. This creates a statutory dependency on ADI banking relationships that is distinct from, but related to, the ESA access question. A non-bank PSP that cannot obtain or maintain an ADI trust account cannot satisfy its safeguarding obligation; a non-bank PSP that cannot obtain direct ESA access must route payments through an ADI intermediary. Both constraints reinforce the structural position of ADIs as gatekeepers to the Australian payments system, even as the licensing reforms formally expand the regulatory perimeter to include non-bank PSPs. The W12 module has no new corridor-level or correspondent-banking-specific developments this cycle beyond the ESA access review announcement. The module's trajectory is established rather than escalating, reflecting the fact that the access question is on the regulatory agenda but not yet in active consultation. #### Outlook The ESA access review is expected to commence H2 2026, subject to the Tranche 1 licensing package having passed Parliament. The review's outcome will be the most consequential structural development for non-bank PSPs in the Australian market over the medium term. If the review results in a credible direct-access pathway for non-bank PSPs, it will materially alter the competitive dynamics between bank and non-bank payment providers. If it results in a more limited or conditional access framework, the ADI intermediation layer will remain the structural ceiling for non-bank PSPs. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://www.afslhouse.com.au/insights/australian-payments-system-modernisation-afsl-guide/](https://www.afslhouse.com.au/insights/australian-payments-system-modernisation-afsl-guide/) 2. T3 [https://genfinity.io/2026/05/26/project-acacia-final-report-rba-dfcrc-tokenised-finance/](https://genfinity.io/2026/05/26/project-acacia-final-report-rba-dfcrc-tokenised-finance/) retrieved 2026-06-24 3. T1 [https://imf.org/-/media/Files/Publications/CR/2025/English/1wsmea2025002-print-pdf.ashx](https://imf.org/-/media/Files/Publications/CR/2025/English/1wsmea2025002-print-pdf.ashx) retrieved 2026-06-24 4. T1 [https://www.rba.gov.au/media-releases/2025/mr-25-32.html](https://www.rba.gov.au/media-releases/2025/mr-25-32.html) retrieved 2026-06-24 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-06-24 Trailing-12-month AU commercial activity: Airwallex US$300m Series F (May 2025, US$6.2bn); Banking Circle acquired ADI-status Australian Settlements Limited (Jan 2025); Tyro agreed to acquire Thriday (completion Jan 2026). Standing sub-brief · as of 5 July 2026 138 words · last cycle 2026-10-12 #### Commercial Intelligence (M&A, Investment & Product) Airwallex secured a US$300 million Series F round in May 2025 at a US$6.2 billion valuation, taking total equity raised above US$1.2 billion, with the company crossing a US$900 million annualised revenue run-rate and US$200 billion in annualised transaction volume - lead investors Square Peg and DST Global, with participation from Lone Pine Capital, Blackbird and Airtree. Banking Circle acquired the ADI-licensed Australian Settlements Limited in January 2025 to bolster real-time clearing capability; deal terms were not publicly disclosed. ASX-listed Tyro agreed to acquire NAB-backed fintech Thriday, with deal terms not publicly disclosed and completion expected in January 2026. #### Outlook Continued capital flow to non-bank cross-border PSPs (Airwallex) and consolidation among listed and ADI-adjacent payments players (Banking Circle/Australian Settlements Limited, Tyro/Thriday) are the two commercial threads to track into the next cycle. Periodic update · new data 2026-10-12 #### Commercial Intelligence & Fintech Airwallex raised a AUD 460 million Series H funding round in June 2026 to fund development of autonomous-finance and agentic-commerce products. Combined with an earlier FY2026 funding round, the two rounds together totalled AUD 958 million, making them among the largest fintech funding events recorded in Australia for the year. The round size and its stated use, financing agentic-commerce product development, signal continued investor appetite for payments infrastructure positioned around automated and AI-driven commercial transactions. Separately, National Australia Bank announced in May 2026 the acquisition of London-founded payments fintech Banked, a pay-by-bank and account-to-account payment technology provider. The transaction's financial terms were not publicly disclosed. The acquisition expands NAB's account-to-account payment capability, bringing an established UK-founded pay-by-bank technology provider under the ownership of one of Australia's major banks and extending the bank's reach into account-to-account payment initiation technology. #### Outlook Both events point to continued commercial consolidation and investment activity around account-to-account and agentic-payment technology in the Australian market. Follow-up on Airwallex's agentic-commerce product roadmap and on how NAB integrates Banked's pay-by-bank technology into its existing payment offering would be the natural next markers for this module. **2 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### 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. Periodic update · new data 2026-07-08 #### 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. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T3 [https://www.fintechnews.au/119482/fintech/australias-top-5-most-well-funded-fintech-startups-in-2025/](https://www.fintechnews.au/119482/fintech/australias-top-5-most-well-funded-fintech-startups-in-2025/) 2. T3 [https://www.mordorintelligence.com/industry-reports/australia-fintech-market](https://www.mordorintelligence.com/industry-reports/australia-fintech-market) retrieved 2026-06-24 3. T3 [https://www.startupdaily.net/topic/business/asx-listed-payments-platform-tyro-is-buying-nab-backed-rising-star-fintech-thriday/](https://www.startupdaily.net/topic/business/asx-listed-payments-platform-tyro-is-buying-nab-backed-rising-star-fintech-thriday/) retrieved 2026-06-24 4. T3 [https://www.fintechnews.au/119482/fintech/australias-top-5-most-well-funded-fintech-startups-in-2025/](https://www.fintechnews.au/119482/fintech/australias-top-5-most-well-funded-fintech-startups-in-2025/) ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Australia| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"cards": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 59 finding(s), 269 source(s) in the cumulative register. **Audit trail** Machine check Challenged on 6 Oct 2026: not upheld (26 confirmed against the cited source; 2 contradicted by the cited source; 62 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result. Think something on this page is wrong? 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