AFSL Digital Assets Compliance Tool
AI + Live DataHelps digital asset platforms assess if they must obtain an Australian Financial Services Licence under the expanded AFSL regime starting 2026.
The Corporations Amendment (Digital Assets Framework) Bill 2025 (in force from April 2026) dramatically expands the Australian Financial Services Licence (AFSL) regime to include a broad range of digital asset businesses. If you run a crypto exchange, custody provider, token issuer, NFT marketplace, wallet service or operate any digital asset business in Australia or with Australian clients, you may now need an AFSL regardless of whether you offer traditional or crypto financial products. This tool instantly assesses your likely AFSL pathway, based on ASIC’s guidance (including INFO 225) and the new legislative definitions. Use it to understand if you need to apply, become an authorised representative, or upgrade your compliance systems.
Enter Your Details
Enter Your Details
Real-World Examples
Crypto Exchange Serving AU Retail Clients
A global token exchange lists multiple altcoins, with 40% of users from Australia. It does not yet hold an AFSL.
Since April 2026, direct marketing to AU users and facilitating trades in tokens/crypto assets means it is in-scope. They must apply for an AFSL or become an authorised representative, implement compliance/reporting, and disclose all risks to clients.
NFT Marketplace Only Targeting Overseas
An NFT marketplace excludes Australian IP addresses and restricts signups to non-AU countries.
If it has robust geo-blocking and does not knowingly have AU clients, likely OUT OF SCOPE. Exception: if Australians can intentionally bypass controls, may still face compliance risk. Legal review recommended.
Frequently Asked Questions
Glossary
How to Use
- 1Choose your business type and main crypto/asset service.
- 2Specify your operating region (Australia or global) and client base.
- 3Indicate your current licensing status and basic compliance systems.
- 4Review your result: does your platform require an AFSL, a new category, or are you likely exempt?
- 5See summary steps for next actions and compliance best practices.
Key Information
- As of April 2026, any crypto exchange, custody service, or asset manager targeting Australians must comply with the AFSL regime.
- A licence may be required even for some non-custodial wallet, settlement, or token issuance activities.
- AFSL requires robust compliance: risk frameworks, client onboarding, AML/CTF, ongoing reporting, and dispute resolution.
- Exemptions apply in narrow cases—seek legal advice if unsure.
- Severe penalties for operating without a licence once in-scope (civil and criminal).
Pro Tips
- Check INFO 225 (ASIC guidance) for digital asset financial products and detailed scope rules.
- Engage compliance/legal advisers before launching new products (licensing scope is evolving).
- Automate compliance reporting to reduce admin burden and avoid errors.
- Remember: Being an 'authorised representative' of a licensed entity may be a faster pathway for early-stage startups.
Avoid These Mistakes
- Assuming AFSL only applies to traditional financial products—tokenized and DAO-based models may also be in scope.
- Operating from overseas but serving Australian clients—this does NOT exempt you from AFSL.
- Failing to document decisions around licensing scope or compliance systems.
- Launching without a written risk/compliance framework or designated compliance officer.
Disclaimer: This tool is for general information only. Licencing is complex and legal advice is recommended.
Last updated: April 2026