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Australia’s A$14 million figure is a proposed capital floor, not a final universal requirement. The Australian Securities and Investments Commission (ASIC) is consulting on three ways to set financial-reserve requirements for crypto platforms. Under one option, a platform without qualifying independent custody would need net tangible assets of at least A$14 million or 10% of average revenue, whichever is higher.
The consultation sits alongside an enacted licensing framework that starts on 9 April 2027 and separate anti-money-laundering supervision by the Australian Transaction Reports and Analysis Centre (AUSTRAC). The rules are moving on two tracks: ASIC is addressing licensing, customer assets and market conduct, while AUSTRAC is enforcing registration and AML/CTF controls for virtual-asset businesses.
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What the proposed A$14 million rule would do
ASIC released its consultation package on 15 October 2026. The package covers customer-asset protection, trade execution, conflicts of interest and financial reserves. Its first capital model would require a platform that lacks a qualifying third-party custody concession to maintain net tangible assets of at least A$14 million or 10% of average revenue, with the higher figure applying.
That is a consultation proposal, not an enacted threshold. ASIC is considering different floors depending on custody arrangements, the assets a platform holds and the activities it performs. The eventual guidance and legislative instruments could therefore differ from the figures published for consultation.
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ASIC’s three capital models
| Model | Who it targets | Proposed calculation |
|---|---|---|
| Model 1: full platform model | Platforms without qualifying independent custody | At least A$14 million in net tangible assets or 10% of average revenue, whichever is greater |
| Model 1: custody-adjusted option | Platforms using qualifying independent custodians | The highest of A$200,000; 0.5% of average underlying asset value capped at A$7 million; or 10% of average revenue |
| Model 2: non-financial-product assets | Platforms holding only assets that are not financial products | A$7 million floor |
| Model 3: activity-based model | Platforms with different asset, revenue or operational profiles | A$2 million starting point, with additions based on assets, revenue and activities such as brokerage or operating a trading venue |
The models would make custody structure and business scale decisive. Independent custody could reduce the starting floor under Model 1, while holding more customer assets, generating more revenue or operating brokerage and venue functions could increase the amount under Models 1 or 3. ASIC has not selected a final model.
Capital is only one part of the consultation
The proposed package would also require more evidence that customer assets can be identified, reconciled and returned. Measures under consideration include:
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- Quarterly reporting of crypto-wallet arrangements and wallet addresses.
- Tighter reconciliation and segregation of customer assets from the platform’s own property.
- Customer authorisation before permitted use of underlying assets.
- Protections for customers if a platform becomes insolvent.
- Restrictions on counting certain related-party stablecoins as regulatory capital.
For trading, ASIC is considering best-execution duties for certain intermediaries, access to at least two adequate liquidity sources, limits on a platform trading as principal on its own venue and a ban on incentives that favour particular tokens. These are proposed conduct standards, not rules already in force.
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What is already law, and what is still pending?
Enacted licensing framework
The Corporations Amendment (Digital Assets Framework) Act 2026 received Royal Assent on 8 April 2026 and commences on 9 April 2027, according to ASIC. It brings digital-asset platforms and tokenised-custody platforms into the financial-services licensing regime, with ASIC responsible for licensing and supervision.
The framework creates two financial-product categories. The associated Australian financial services licence (AFSL) obligations cover efficient, honest and fair conduct; clear information about asset holding and customer rights; governance and risk controls; dispute resolution; and compensation arrangements.
Transition deadline
ASIC’s transition notice required firms that need a new or varied AFSL to apply by 30 June 2026. That date has passed. Firms that missed the application deadline could face the risk of conducting unlicensed business during the transition, depending on their circumstances and the permissions they hold.
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Consultation timetable
ASIC’s consultation submissions reportedly close on 27 November 2026. Final guidance and instruments are expected in March 2027, before the Act’s 9 April 2027 commencement. Both the capital numbers and detailed controls should therefore be treated as changeable until ASIC publishes the final material.
How ASIC’s work differs from AUSTRAC’s AML crackdown
| ASIC | AUSTRAC | |
|---|---|---|
| Primary role | Financial-services licensing, prudential expectations, custody and market conduct | AML/CTF registration, supervision and enforcement |
| Businesses in focus | Digital-asset and tokenised-custody platforms entering the AFSL regime | Virtual-asset service providers, including exchanges and crypto-to-cash or cash-to-crypto operators |
| Key obligations | Capital and reserves, segregation and reconciliation, disclosure, governance, execution and conflicts controls | Registration, customer and transaction-risk controls, AML/CTF programs and reporting |
| Timing in the current announcements | Consultation on 15 October 2026; Act commences 9 April 2027 | Supervisory campaigns launched 8 May 2026; expanded virtual-asset coverage announced 2 April 2026 |
AUSTRAC said on 8 May 2026 that it had launched campaigns involving 36 crypto businesses providing over-the-counter crypto-to-cash or cash-to-crypto services and 27 local exchanges. The reviews examine business models, service scale, governance and AML/CTF risk management. Chief Executive Brendan Thomas said, “AUSTRAC is checking how well crypto businesses in Australia are managing money-laundering risks, ahead of major new laws coming into force.”
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In its 2 April 2026 release, AUSTRAC said the AML/CTF laws had expanded to a broader virtual-asset sector and that Australia was replacing “digital currency exchange” with “virtual asset service provider.” AUSTRAC reviewed 128 inactive businesses on its register; 62 exited through registration action or voluntary withdrawal. The agency describes virtual assets as a high money-laundering-risk sector and says every business providing virtual-asset services must register and meet AML/CTF obligations.
Thomas called the terminology change “more than a name change,” saying it reflects how the sector has evolved. Home Affairs Minister Tony Burke said the reforms close gaps criminals used to move illicit funds while allowing legitimate innovation to continue safely. These statements concern AML/CTF supervision, not ASIC’s proposed capital formula.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Possible exemption for very small platforms
Treasury’s 26 November 2025 release described a proposed exemption for smaller platforms holding less than A$5,000 per customer and facilitating less than A$10 million in annual transactions. The exemption remains subject to the legislation and final rules; it should not be assumed to remove every licensing or AML/CTF obligation.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallTreasury also cited Digital Finance Cooperative Research Centre research estimating that Australia could capture as much as A$24 billion a year in productivity and cost savings from digital-finance innovation. That estimate explains the policy goal of supporting innovation while adding controls, but it does not change any platform’s capital calculation.
What Australian crypto customers should check
- Whether the platform has applied for, or will need, an AFSL under the digital-assets framework.
- Where customer assets and private-key custody are held, and whether an independent custodian is involved.
- How the platform segregates and reconciles customer assets and what happens if it becomes insolvent.
- Whether the service is registered with AUSTRAC as a virtual-asset service provider and maintains AML/CTF controls.
- Whether advertised trading arrangements explain execution, liquidity and conflicts rather than relying on token-specific incentives.
Until ASIC finishes the consultation and publishes its March 2027 instruments, the A$14 million number is best read as one possible benchmark for a particular business model. The binding milestones are the 9 April 2027 commencement of the licensing Act and the AML/CTF registration and supervision requirements that AUSTRAC is already enforcing.
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