TLDR:
ASIC’s no-action period ended September 30, 2026, leaving unlicensed digital asset firms exposed.
Penalties for unlicensed conduct include civil and criminal action, with fines up to 10% of turnover.
The DAP and TCP licensing regime under the Digital Assets Framework Act starts on April 9, 2027.
AUSTRAC’s expanded AML/CTF rules took effect March 31, 2026, with wallet reporting due in 2029.
The ASIC no-action period for digital asset firms in Australia ended on September 30, 2026. Firms offering in-scope services without a license application now face possible enforcement action from October 1.
The regulator had extended the original June 30 deadline to give the industry more time. Separately, Australia’s digital asset rules are moving along two other tracks.
These include a new platform licensing regime and expanded anti-money laundering requirements from AUSTRAC.
INFO 225 Licensing Applies Now
TRM Labs outlined the changes in a post on X. The firm said “ASIC’s no-action period has ended” and that it “breaks down Australia’s three digital asset tracks.”
The first track covers Information Sheet 225, known as INFO 225. It explains how existing financial services law applies to digital assets.
@ASIC 's no-action period has ended. TRM breaks down Australia's three digital asset tracks: INFO 225 licensing now, the new DAP/TCP regime from April 9, 2027, and @AUSTRAC's expanded AML/CTF rules.
Read more 
https://t.co/VrxUWcScvd pic.twitter.com/FHhYwVjx3B
— TRM Labs (@trmlabs) October 7, 2026
ASIC clarified the sheet in December 2025, following Consultation Paper 381. The guidance says certain stablecoins, wrapped tokens, and staking arrangements can be financial products under the Corporations Act 2001.
Businesses that deal in, advise on, or hold these products generally need an Australian Financial Services License (AFSL).
The requirement also reaches offshore businesses that promote or provide these services to people in Australia. ASIC’s worked examples list yield-bearing stablecoins, managed staking, and wrapped tokens as likely financial products. Self-custody wallets, meme coins, and basic proof-of-stake rewards are listed as unlikely to qualify.
ASIC adopted the no-action position to support an orderly transition. Under the ASIC no-action period, the regulator would not act if a firm lodged an AFSL application by the deadline.
The date moved from June 30 to September 30, 2026. Unlicensed firms now face civil and criminal penalties, including fines of up to 10% of annual turnover. ASIC had recorded more than 45 license applications as of September 2.
New DAP and TCP Licensing Regime
The second track is the Corporations Amendment (Digital Assets Framework) Act 2026. It takes effect on April 9, 2027, after the ASIC no-action period.
The Act brings digital asset platforms (DAPs) and tokenized custody platforms (TCPs) into the AFSL framework. This applies even if the tokens they hold are not financial products.
A DAP is a facility where the operator holds digital tokens for clients and records their interests in an account. This captures most crypto exchanges, brokers, and custodians. A TCP covers operators that hold real-world assets and issue tokens representing a right to redeem or take delivery.
Platform operators must hold an AFSL and maintain platform rules. These rules cover eligibility, client obligations, settlement, fees, and how assets are deposited, redeemed, and delivered. Operators must also give retail consumers a DAP or TCP Guide before onboarding.
The Act includes carve-outs, such as a de minimis exemption for low-volume platforms. It also excludes public digital token infrastructure and certain custodial staking arrangements.
ASIC will set detailed standards by legislative instrument. It has released an 18-month roadmap that begins with stakeholder roundtables and consultation.
AUSTRAC Expands AML/CTF Obligations
Separate from the ASIC no-action period, AUSTRAC’s reformed AML/CTF regime has been in force since March 31, 2026. The reforms replace “digital currency” with “virtual asset” and widen the scope of regulated services.
Before the change, only exchanges between digital currency and fiat were covered. Virtual asset service providers (VASPs) now face broader obligations, whether or not they need an AFSL.
The regime now covers several services. These include exchanging virtual assets for money or for other virtual assets. Safekeeping of assets or private keys for customers is also covered. Transfers made on behalf of customers carry Travel Rule obligations.
AUSTRAC set different dates for specific obligations. Full obligations for exchanging virtual assets for money applied from March 31, 2026.
Customer due diligence and record-keeping for newly regulated services began on July 1, 2026. Reporting of transfers involving unverified self-hosted wallets starts on March 31, 2029.
The obligations apply where a service has a geographical link to Australia. Where a firm cannot yet meet an obligation, AUSTRAC expects a documented implementation plan. TRM noted that firms can end up “compliant on one track and exposed on another.”
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