Probably yes, if you hold client assets. AUSTRAC registration is an anti-money-laundering registration, not a financial services licence. You may need an AFS licence (AFSL) already: ASIC treats some digital assets as financial products under existing law, and its interim no-action position on licensing expired on 30 June 2026. From 9 April 2027 the new digital asset platform and tokenised custody platform categories add further authorisations.
The four numbers that decide it
Most operators arrive here already registered with AUSTRAC and reasonably assuming that was the licence. It was not, and the gap between the two regimes is now legislated, not theoretical. If you are still choosing a jurisdiction, start at choosing a licence and the jurisdictions overview. This page answers the ASIC side - whether you need a licence, and when - not what AUSTRAC registration itself obliges you to do.
Key takeaways
- Two regulators, two separate permissions: AUSTRAC under the AML/CTF Act, ASIC under the Corporations Act.
- The trigger for the ASIC side is custody, not your label; size only matters for the small-platform exemption.
- The exemption has two limbs and you need both; failing either one puts you back in scope.
- No adviser can promise approval or a regulator's timing. Both are the regulator's to decide.
On this page9 sections
Does AUSTRAC registration cover you?
It covers the AML/CTF side and nothing else. In the current compilation of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Part 6A is titled the Virtual Asset Service Provider Register, and section 76A reads "Unregistered persons must not provide certain virtual asset services".
The statutory vocabulary has moved from digital currency exchange to virtual asset service provider, while ASIC's own guidance still uses the older phrasing when it asks fund managers to confirm an exchange "is a digital currency exchange (DCE) provider registered with AUSTRAC, if required". That drift in vocabulary is part of why so much of the published advice reads as though these are one process.
The financial-services side is ASIC's, under the Corporations Act. Information Sheet 225 draws the boundary itself: it states that it does not cover legislation administered by other regulators who oversee digital asset service providers, and names AUSTRAC alongside APRA, the ATO, the ACCC and the RBA. The regulator does not treat the two as consecutive steps, and neither should your compliance plan.
What changed in April 2026, and what changes on 9 April 2027?
The Corporations Amendment (Digital Assets Framework) Act 2026 passed Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and commences on 9 April 2027. Its Schedule 1 is headed "Digital asset platforms and tokenised custody platforms"; the Act provides for an 18-month implementation timeline, with ASIC licensing and supervising the platforms.
What changed in April 2026, and what changes on 9 April 2027
| Date | What happened | What it means for you |
|---|---|---|
| 8 April 2026 | Royal Assent | The rules are fixed but not yet in force |
| 30 June 2026 | ASIC's class no-action position expired | No bridge left; existing licensing law applies in full |
| Months 12 to 18 of ASIC's roadmap (no calendar date set) | Applications open for the new authorisations | You can lodge and operate under relief while it is assessed |
| 9 April 2027 | The Act commences | Six-month transition for anyone who has already lodged |
The awkward part is the middle. The bridge is gone, the new regime's own application window has not opened, and in between the only thing that applies is the law as it already stands.
Does your platform need an AFSL? DAP and TCP
Both new categories turn on who holds the asset. A digital asset platform (DAP) is a facility under which the operator holds digital tokens on behalf of clients and records clients' interests in an account. A tokenised custody platform (TCP) is one under which the operator holds real-world assets - commodities, securities or other property - and issues a digital token representing the client's right to redeem or take delivery.
The exclusions are as useful as the definitions. Businesses that do not hold digital assets on clients' behalf are generally not captured, and open-source software or hardware used to transmit or record tokens on a public blockchain is excluded from the regime entirely. So the first question is not whether you are an exchange but whether you hold client assets and record client interests. For the custody line specifically, see when a wallet needs a custody licence; for the model-by-model view across jurisdictions, which licence a crypto exchange needs.
Are you exempt? Both limbs or neither
The small-platform exemption, as Dentons summarises it, is narrow and arithmetical: operators are exempt if they hold less than AU$5,000 per client across all relevant platforms and process less than AU$10 million in total transactions per year. Both tests have to hold. Run those two numbers before you do anything else on this page - they decide whether the rest of it is your problem at all.
We missed 30 June 2026. Where does that leave us?
ASIC's class no-action letter said that firms needing a licence or a variation had to apply by that date, or in some cases become an authorised representative of an existing AFS licensee by then. Its roadmap is blunt about what follows: entities will need to comply with existing licensing requirements throughout the implementation of the law reforms.
So the buffer is gone and the underlying law did not soften. In the same announcement ASIC says firms that needed to apply and did not "risk being in breach of financial services laws", and that unlicensed conduct carries penalties that could reach up to 10% of annual turnover. The useful move now is a scope assessment and a lodged application, in that order - not a wait for the next concession.
Does an offshore structure keep you out of it?
No. The test is where the customers are and where the service is provided, not where the company was incorporated. ASIC closes that door explicitly in INFO 225:
Australian laws apply where the digital asset is promoted or sold, or services are provided in relation to them, in Australia, including from offshore.
The use of offshore or decentralised structures does not mean that key obligations under Australian laws do not apply or can be ignored.
If you are checking whether a provider's own licence is what they say it is, see how to check a crypto licence is real.
What does the licence oblige you to do afterwards?
The Act does not build a parallel regime; it embeds digital asset regulation into the existing Corporations Act architecture, so a licensee carries the full suite of licence obligations. Those include acting efficiently, honestly and fairly, managing conflicts of interest, maintaining adequate dispute resolution arrangements including AFCA membership, and meeting disclosure requirements written for the digital asset context. Retail clients receive a DAP/TCP Guide specific to the platform rather than a traditional product disclosure statement.
Two things are easy to miss. Firms that licensed early under INFO 225 will still need to add DAP and TCP authorisations to their licence once the regime commences. And ASIC has said it will set standards for operators covering asset holding, transactions and settlement, and financial requirements - the detail of which is still to be published. For what has to exist locally either way, see local substance requirements, and the glossary for the terms.
Frequently asked questions
Is an AUSTRAC registration the same thing as an Australian crypto licence?
No. AUSTRAC registration sits under Part 6A of the AML/CTF Act and covers anti-money-laundering obligations. Financial product regulation is ASIC's, under the Corporations Act, and INFO 225 states that it does not cover legislation administered by AUSTRAC.
Can we keep operating after 9 April 2027 while our application is assessed?
There is a six-month transition from commencement for providers that do not yet hold an AFSL but have lodged an application with ASIC. Providers that have not lodged are expected to comply with the licensing requirements from commencement.
Did ASIC confirm that Bitcoin itself is not a financial product?
Yes. In its 29 October 2025 update to INFO 225 ASIC confirmed that fiat-backed stablecoins and wrapped tokens are financial products and that Bitcoin is not. That is a product classification; it does not change anything on the AUSTRAC side.
Where to start
This page describes published legislation and regulatory material and is not legal advice. Australia is one of the 10+ jurisdictions CryptoLicense (CL GLOBAL SDN BHD, 1421939-T) covers, and we have run this assessment for 100+ companies; the entity record is on our entity proof page. No application can be guaranteed - authorisation and timing are entirely the regulator's discretion. Bring the business model, where your paying customers sit, and who holds the assets, and we will tell you which side of the line you are on.
Part of a series: the full guide is at choosing a licence.