Lawyers are advising businesses to prepare early for a series of regulatory reforms that come into effect this year.
The reforms cover digital assets, payments modernisation and fresh obligations under Anti-Money Laundering and Counter-Terrorism Financing protections.
Lucy Adamson, a Partner at McCullough Robertson Lawyers, has published an overview for clients of the five major areas of regulatory change.
She says the reforms reflect an attempt by regulators to catch up with the technology that is reshaping financial services.
“Early engagement with regulators and close monitoring of ASIC, AUSTRAC, and RBA guidance will be critical, as transitional relief (such as ASIC’s no-action position until June 30, 2026) offers only a short window,” Ms Adamson says.
“Boards and senior management should be briefed on timelines and strategic implications to ensure readiness for 2026 and beyond.”
The full client advisory report can be found here
Below is a summary version of the areas covered.
RBA now has more regulatory power
The Treasury Laws Amendment (Payments System Modernisation) Act 2025 (Cth) took effect on December 19 2025, significantly expanding the Reserve Bank of Australia’s (RBA) regulatory reach under the Payment Systems (Regulation) Act 1998 (Cth). The Act broadened the definitions of “payment system” and “participant” to capture new and emerging service (including digital wallets, Buy Now, Pay Later (BNPL) providers, and stablecoin-based platforms) ensuring they fall within the RBA’s oversight.
Incoming amendments to the Corporations Act to capture certain digital assets
In an effort to modernise Australia’s financial payment system, the Treasury announced on October 9, 2025 that it would be focussing on two tranches of reform, including licensing requirements and obligations.
Corporations Amendment (Digital Assets Framework) Bill 2025 (Cth)
The Corporations Amendment (Digital Assets Framework) Bill 2025 (Cth) is set to extend the Australian Financial Services Licence (AFSL) regime in a major uplift to capture digital asset platforms, tokenised custody providers and related services.
INFO 225 and No Action by ASIC letter
On October 29, 2025, ASIC updated Information Sheet 225: Crypto-assets (INFO 225) and issued a class no-action letter to guide the transition to licensing for digital asset financial products.
The update clarifies ASIC’s approach to determining whether digital assets are financial products and sets expectations for providers preparing to comply with the new regime.
AUSTRAC is to receive new powers
The Minister for Home Affairs has announced plans to introduce legislation amending the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth). The proposed reforms would grant the Australian Transaction Reports and Analysis Centre (AUSTRAC)’s CEO new powers to restrict or prohibit, products, services and delivery channels identified as high-risk for money laundering and terrorism financing.
More information or help is available from McR, please contact Lucy Adamson
