Cryptoassets Regulatory Intelligence

Australia Crypto & Digital Asset Regulation

AU schema crypto-v2.0.0 trajectory: not yet assessed in transition overlaps: Sentinel (AML/CFT), World Payments

Last updated · 8 categories · 69 sourced findings · 83 sources in the cumulative register

Evidence re-verified: ·Position last changed: ·
Record history & provenance ▾

Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

Framework postureIn transition7 of 9 modules populated · AI-synthesised · Tier-1/2 verified
Lead supervisory authorityASICPrimary statutory & supervisory perimeter
Next milestone (> 2026-10-26)2026-10-28CARF crypto tax-reporting exposure draft consultation closes
Module coverage & confidence7 / 9 modules assessed0 Confirmed · 7 Probable · 0 Uncertain · 2 Not yet assessed

Jurisdiction lead brief

Latest update · 4 November 2026

Lead Signal

The most consequential movement sits in how Australia intends to see into crypto-asset transactions for tax purposes rather than in how it licenses platforms. A draft bill to require crypto service providers to report Australian residents' transactions to the Australian Taxation Office completed its public consultation on 28 October 2026. The proposal aligns Australia's domestic reporting regime with the OECD's Crypto-Asset Reporting Framework, extending to digital assets a transparency architecture that Australia first adopted for conventional financial accounts a decade ago. Reporting Crypto-Asset Service Providers are expected to begin collecting transaction information from the 2027 calendar year, with the first reports due to the Taxation Office in 2028. The obligation is not yet law: it remains a proposal that has cleared consultation, and the ministerial rules that would set firm commencement dates and administrative penalties have not been published. For any business handling Australian-resident crypto transactions, the direction of travel is now clear even where the mechanics are not: systematic, cross-border-style information reporting is coming to the sector on broadly the same multilateral template already applied to banks and custodians.

Key regulatory facts for Australia
Regulatory DimensionAustralia Standing Position
JurisdictionAustralia (AU)
Regulatory ScopeCrypto & Digital Asset Regulation (8 modules, 69 sourced findings)
Crypto LicensingAustralia is mid-transition from a 'financial product by function' regime administered under existing Corporations Act licensing (AFSL) to a bespoke statutory framework.
Token ClassificationASIC applies a functional, technology-neutral test under the Corporations Act 2001 rather than bespoke crypto categories: whether a digital asset is a 'financial product' turns on its substantive features.
On-Chain Activity RegimeASIC's INFO 225 distinguishes native proof-of-stake staking from 'staking-as-a-service' / managed staking arrangements, with the latter more likely to constitute a financial product, and the Reserve Bank of...
Stablecoin RegimeStablecoins are currently regulated in Australia indirectly through ASIC's financial-product classification (typically as a non-cash payment facility), requiring issuers to hold an AFSL, with class relief granted to...
Primary Instruments CitedASIC, ASIC, ASIC, ASIC, Corporations Amendment (Digital Assets Framework) Act 2026
Last Confirmed / Updated2026-11-04 (83 sources in cumulative register)

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Australia is mid-transition from a 'financial product by function' regime administered under existing Corporations Act licensing (AFSL) to a bespoke statutory framework. The Corporations Amendment (Digital Assets Framework) Act 2026 (DAF Act) passed Parliament 1 April 2026 and received Royal Assent 8 April 2026, creating two new regulated categories — Digital Asset Platforms (DAPs) and Tokenised Custody Platforms (TCPs) — both requiring an Australian Financial Services Licence (AFSL) from ASIC, but the Act does not commence until 9 April 2027 (an 18-month implementation runway). In the interim, ASIC has extended a sector-wide no-action position (originally to 30 June 2026, now to 30 September 2026) under updated INFO 225 guidance, requiring firms to lodge AFSL applications (or notify ASIC of intent for Market/CS facility licences) by that date to avoid enforcement exposure for operating without a required existing licence.

Horizon · 2027-04-08 (± a quarter)Corporations Amendment (Digital Assets Framework) Act 2026 commencesAdopted · Tier 3 source
Horizon · 2027-04-09 (± a quarter)Digital Assets Framework Act 2026 commencesAdopted · Tier 3 source
Horizon · 2027-04-08 (± a quarter)Digital Assets Framework Act 2026 operative commencementAdopted · Tier 1 source
Horizon · 2026-11-27 (± a quarter)ASIC CP 392 consultation closesConsultation · Tier 1 source
Horizon · 2027-04-08 (± a quarter)Digital asset platform / tokenised custody platform regime commencesAdopted · Tier 1 source
Horizon · 2027-04-09 (not yet assessed)Digital Assets Framework Act 2026 commencementAdopted · Tier 1 source
Horizon · 2027-04-08 (± a quarter)Digital Assets Framework Act new-licence applications openAdopted · Tier 3 source
Horizon · 2027-10-07 (± a quarter)Digital Assets Framework Act existing-operator application deadlineAdopted · Tier 3 source
Horizon · 2026-11-27 (± a quarter)ASIC CP392 feedback period closesConsultation · Tier 1 source
Standing sub-brief · as of 5 October 2026 556 words · last cycle 2026-11-03

Crypto Licensing

The defining event of this cycle is the expiry, on 30 September 2026, of ASIC's class no-action position for providers of digital-asset financial products and services. This administrative relief had allowed firms operating in the sector to continue operating without immediately holding a full Australian Financial Services licence while the broader regulatory settlement for digital assets was finalised. With its expiry, firms must now hold a current AFS licence or have an application actively in progress to continue lawfully operating. ASIC's final-call notice, issued 2 September 2026 ahead of the deadline, recorded over 45 licence applications logged, a rise from approximately 30 applications in late June 2026, suggesting that a meaningful share of the affected population applied only in the closing weeks before the no-action relief lapsed.

Periodic update · new data 2026-10-25

Crypto Licensing

The Corporations Amendment (Digital Assets Framework) Act 2026 establishes a licensing requirement for operators of digital asset platforms and tokenised custody platforms, requiring them to hold or vary an Australian financial services licence covering that activity from 8 April 2027. Existing operators are given until 7 October 2027 to submit a new application or variation, giving incumbents a six-month transitional window beyond the commencement date itself. The Australian Securities and Investments Commission opened the implementation phase of this regime on 15 October 2026 with Consultation Paper 392, seeking feedback on a regulatory guide, draft ASIC Corporations instruments and financial requirements covering licensing, custody, trading and settlement, and disclosure for both platform types; this consultation closes 27 November 2026.

Within that consultation, the regulator has floated a streamlined licensing pathway for firms that already hold an Australian financial services licence and are seeking a digital-asset-platform or tokenised-custody-platform authorisation, as well as for firms that previously applied under the regulator's prior no-action position, a cohort reported at over one hundred and forty applications recorded between October 2025 and September 2026. On the prudential side, a draft financial requirements instrument proposes that platform operators without a qualifying third-party custodian hold net tangible assets of at least seven million or fourteen million Australian dollars, with one proposed model tying the higher figure to ten percent of average revenue where that produces a larger number. These capital models remain proposals within an open consultation and have not been finalised; final instruments are expected around March 2027, ahead of the April 2027 commencement.

Outlook

The consultation closing 27 November 2026 is the next point at which the proposed capital models and streamlined transition pathway will firm up. Operators should expect final instruments around March 2027, with the licensing regime itself commencing 8 April 2027 and the extended deadline for existing operators to apply or vary falling 7 October 2027.

2 earlier distinct update(s)
Periodic update · new data 2026-10-18

Crypto Licensing

The Corporations Amendment (Digital Assets Framework) Act 2026 (Act No. 38 of 2026) received Royal Assent on 8 April 2026 and is enacted but not yet operative: the operative commencement of its Australian Financial Services Licence obligations for digital asset platform and tokenised custody platform operators is targeted for 8 April 2027. Once operative, operators of a 'digital asset platform' or a 'tokenised custody platform' must hold an AFSL.

The practical substance of that licensing requirement is being built out through consultation in the intervening year. ASIC opened Consultation Paper 392 on 15 October 2026, proposing capital, custody and trading standards for licensed digital-asset platforms, with consultation closing 27 November 2026. At the time the consultation opened, more than 140 AFSL applications for digital-asset financial services had already been lodged, a substantial pipeline given that the underlying obligation is not yet binding. This suggests the industry is treating the 8 April 2027 commencement date as a genuine deadline and seeking to be licence-ready well in advance, rather than waiting for the standards to be finalised.

The detail of CP 392's proposed capital, custody and trading standards beyond the fact of its opening was not independently retrieved this cycle, and the final text of the enacted Act was not independently re-verified against the earlier draft Bill's penalty provisions.

Outlook

The consultation closing 27 November 2026 will produce the finalised capital, custody and trading standards that give operative content to the AFSL requirement. The period between that closure and the Act's 8 April 2027 commencement is the window in which the roughly 140-plus lodged applications, and any further applications, will need to be assessed against the finalised standards.

Periodic update · new data 2026-10-06

Crypto Licensing

ASIC's sector-wide no-action position for digital-asset businesses expired on 30 September 2026. Businesses that had been relying on that position to continue operating without an Australian Financial Services licence were required to have applied for, or varied, an AFS licence by that date; firms that did not do so now risk operating in breach of financial services law. The no-action position had served as a transitional mechanism permitting certain digital-asset businesses to continue operating while bringing their licensing position into compliance with standard AFS licensing requirements, and the 30 September deadline marks the end of that transitional accommodation.

No figures on the number of businesses that applied for or varied a licence ahead of the deadline, and no record of enforcement action taken against businesses that continued operating without doing so, were available in the evidence supplied this cycle.

Outlook

The near-term signal to watch is whether ASIC pursues visible enforcement against firms that continued operating in reliance on the now-expired no-action position without having applied for or varied an AFS licence. A separate, asserted Schedule 6 VASP-registration deadline of 29 July 2026 remains unverified from an accessible AUSTRAC or Federal Register source and is not addressed further here pending that confirmation.

Sources and findings (21)
  1. T1ASIC — The Corporations Amendment (Digital Assets Framework) Act 2026 requires operators of digital asset platforms and tokenised custody platforms to obtain an Australian Financial Services Licence from ASIC. retrieved M5 binding enacted not yet effective
  2. T1ASIC — ASIC extended its sector-wide no-action position for digital asset businesses providing financial services to 30 September 2026, giving firms additional time to apply for or vary an AFS licence before enforcement risk applies. retrieved M4 binding in force
  3. T1ASIC — Under current law, providers of financial services involving digital asset financial products must hold an AFS licence (or variation to an existing licence) and were directed to apply by 30 June 2026 before the original no-action position expired. retrieved M4 binding in force
  4. T1ASIC — Businesses that require an Australian Market Licence or Clearing and Settlement facility licence must notify ASIC in writing of their intention to apply and hold a pre-meeting with ASIC by the no-action deadline (extended to 30 September 2026). retrieved M3 binding in force
  5. T3ASIC — ASIC's class no-action position for digital-asset financial-product/service providers expired 30 September 2026; firms must now hold a current AFS licence or have an application in progress; over 45 licence applications logged by the 2 September 2026 final-call notice, up from ~30 in late June 2026. retrieved M5 binding in force new
  6. T3Corporations Amendment (Digital Assets Framework) Act 2026 — Act No. 38 of 2026 received Royal Assent 8 April 2026; the whole Act commences 8 April 2027, with a 6-month transition period for AFSL application/variation mechanics beginning at commencement. retrieved M5 binding enacted not yet effective
  7. T1ASIC sector-wide no-action position for digital assets — Businesses relying on ASIC's sector-wide no-action position for digital assets had until 30 September 2026 to apply for or vary an Australian Financial Services (AFS) licence or risk operating in breach of financial services law. retrieved M4 binding in force new
  8. T3Digital asset platforms and tokenised custody platforms — AFSL authorisation; new applications open 8 April 2027, existing operators must apply by 7 October 2027 retrieved M4 binding enacted not yet effective
  9. T4ASIC — ASIC Consultation Paper 392 (opened 15 October 2026, closing 27 November 2026) proposes capital, custody and trading standards for licensed digital-asset platforms; over 140 AFSL applications for digital-asset financial services had been lodged as at the consultation's opening. retrieved M4 non-binding new
  10. T1Corporations Amendment (Digital Assets Framework) Act 2026 (Cth) — Operators of digital asset platforms and tokenised custody platforms must hold or vary an Australian financial services licence from 8 April 2027; existing operators must apply or vary by 7 October 2027. retrieved M5 binding enacted not yet effective new
  11. T3ASIC Consultation Paper 392 — A streamlined licensing process for existing AFS licensees seeking digital-asset-platform or tokenised-custody-platform authorisations, and for prior Information Sheet 225 no-action applicants (over 140 applications recorded Oct 2025-Sept 2026). retrieved M2 non-binding new
  12. T3ASIC Consultation Paper 392 (draft Financial Requirements Instrument) — Digital asset platform / tokenised custody platform operators without a qualifying third-party custodian would need net tangible assets of at least A$7 million or A$14 million (one option tying the figure to 10% of average revenue if greater). retrieved M3 non-binding new
  13. T1ASIC Consultation Paper 392 — Proposed regulatory guide, draft ASIC Corporations instruments and financial requirements to implement the Corporations Amendment (Digital Assets Framework) Act 2026, covering licensing, custody, trading/settlement and disclosure for DAPs and TCPs; consultation closes 27 November 2026. retrieved M4 non-binding new
  14. T3 · TRM LabsCorporations Amendment (Digital Assets Framework) Act 2026 — 2027-04-09
  15. T3 · Chartered Accountants Australia and New ZealandCorporations Act 2001 (Cth) s911A — person carrying on a financial services business involving a crypto-asset financial product
  16. T1 · Australian Securities and Investments Commission (ASIC)Corporations Amendment (Digital Assets Framework) Act 2026 (Cth) — 2027-04-09
  17. T3 · CryptoSlateAML/CTF Act 2006 (Cth) Part 6A — virtual asset service providers (formerly digital currency exchange providers)
  18. T3 · Click LegalAML/CTF Act 2006 (Cth) Travel Rule — 2026-07-01
  19. T1 · ASICBPS Financial Pty Ltd — BPS Financial Pty Ltd — 14000000
  20. T3 · ASICCorporations Amendment (Digital Assets Framework) Act 2026 — Act No. 38 of 2026, enacted (Royal Assent 8 April 2026); operative commencement for digital asset platform and tokenised custody platform AFSL obligations targeted for 8 April 2027. retrieved M5 binding enacted not yet effective
  21. T1ASIC — Operators of a 'digital asset platform' or 'tokenised custody platform' must hold an AFSL once the regime commences. retrieved M5 binding enacted not yet effective

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ASIC applies a functional, technology-neutral test under the Corporations Act 2001 rather than bespoke crypto categories: whether a digital asset is a 'financial product' turns on its substantive features. Updated INFO 225 (2025/2026) explicitly treats many stablecoins, wrapped tokens, tokenised securities and digital asset wallets as financial products, while noting that classification of DeFi arrangements and many utility-style tokens depends on individual facts and is not addressed definitively by the guidance.

C2 · Token Classification — Full Module Record0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

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ASIC's INFO 225 distinguishes native proof-of-stake staking from 'staking-as-a-service' / managed staking arrangements, with the latter more likely to constitute a financial product, and the Reserve Bank of Australia's Project Acacia has facilitated regulatory relief for wholesale tokenisation testing. DeFi lending/borrowing classification remains fact-dependent and unaddressed definitively by the regulator. No dedicated Australian regime specifically targets crypto mining, standalone node operation, validator services, or DEX operation as distinct categories; these are assessed, if at all, under the same functional financial-product test.

C3 · On-Chain Activity — Full Module Record0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

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Stablecoins are currently regulated in Australia indirectly through ASIC's financial-product classification (typically as a non-cash payment facility), requiring issuers to hold an AFSL, with class relief granted to secondary distributors of stablecoins issued by an AFSL-licensed issuer. A dedicated statutory framework for 'payment stablecoins' is still at the proposal stage: Treasury's Payments System Modernisation (Regulation of Payment Service Providers) Tranche 1a is draft legislation only and has not been enacted — CAUTION: treat reserve/redemption obligations under that reform as proposed, not settled law.

C4 · Stablecoins & EMTs — Full Module Record0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

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Consumer protection for crypto in Australia currently rests on general Corporations Act / ASIC Act misleading-conduct prohibitions (RG 234, updated June 2026), influencer-specific guidance (INFO 269), and ASIC's consumer-facing Moneysmart warnings, which highlight elevated Gen Z exposure to crypto 'finfluencer' marketing. The DAF Act (not yet in force) will add statutory custody-segregation, standardized disclosure and dispute-resolution/compensation requirements specific to digital asset platforms and tokenised custody platforms once it commences in April 2027.

Standing sub-brief · as of 25 October 2026 189 words · last cycle 2026-11-03

Consumer Protection

As part of the implementation consultation for the new digital asset platform and tokenised custody platform licensing regime, the Australian Securities and Investments Commission has proposed custody and segregation standards for platform operators. Under the draft published 15 October 2026, operators of digital asset platforms and tokenised custody platforms would be required to segregate client digital assets from the firm's own assets, reconcile client holdings, and enable client withdrawal. Notably, the draft does not require that client assets be held within Australia itself, meaning segregation and reconciliation duties would apply regardless of where the assets are technically custodied. These standards remain at the proposal stage, forming part of the same consultation package that covers licensing, trading and settlement, and disclosure, and are not yet finalised.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (10)
  1. T1ASIC — ASIC's updated Regulatory Guide 234 (June 2026) provides guidance to help promoters of financial products, including digital assets, comply with obligations not to make false or misleading statements or engage in misleading or deceptive conduct in advertising. retrieved M4 binding in force
  2. T1ASIC — ASIC's Information Sheet 269 sets out how financial services laws apply to social media influencers discussing financial products, including that receiving payment for crypto-related comments increases the likelihood of providing unlicensed financial product advice. retrieved M4 binding in force
  3. T1ASIC — ASIC research found that almost one in four Gen Z Australians own cryptocurrency and that 72% have seen social media advertising encouraging crypto investment in the past 12 months, prompting ASIC to publicly urge consumers to verify financial claims via Moneysmart. retrieved M3 non-binding
  4. T3CoinDesk — Operators of digital asset platforms and tokenised custody platforms under the DAF Act must safeguard client assets, including obligations aimed at reducing commingling, insolvency and misuse of customer assets. retrieved M5 binding enacted not yet effective
  5. T1ASIC — ASIC's no-action position for digital asset businesses is conditioned on the firm holding Australian Financial Complaints Authority (AFCA) membership, and the DAF Act requires AFSL holders to maintain dispute resolution and compensation systems. retrieved M4 binding in force
  6. T3ASIC — Minimum standards for client-asset holding/safeguarding and for transaction and settlement functions on digital asset platforms are to be set by ASIC once the Digital Assets Framework Act commences (8 April 2027); no such bespoke statutory custody standard currently exists. retrieved M4 binding enacted not yet effective
  7. T1 · ASICCorporations Amendment (Digital Assets Framework) Act 2026 — Digital asset platforms and tokenised custody platforms must, once the regime commences, give customers clear information about how assets are held and their rights, maintain strong governance and risk controls, and provide accessible dispute resolution and compensation. retrieved M4 binding enacted not yet effective
  8. T1ASIC Consultation Paper 392 — Digital asset platform / tokenised custody platform operators must segregate client digital assets from the firm's own assets, reconcile holdings, and enable client withdrawal; operators are not required to hold client assets within Australia. retrieved M3 non-binding new
  9. T1 · ASICASIC v BPS Financial Pty Ltd (Qoin) — ASIC v BPS Financial Pty Ltd (Qoin) — 14000000
  10. T1 · AFCAAFCA digital asset jurisdiction — 2026-10-01

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The Australian Taxation Office treats cryptocurrency as property/a CGT asset rather than money or foreign currency, requiring capital gains/losses to be reported on disposal, with data-matching programs compelling exchanges to supply customer transaction data. A 2026-reported Budget proposal to replace the 50% CGT discount with an inflation-indexed model (which would affect crypto held over one year) had not been legislated as of the reported date — CAUTION: treat as a media-reported proposal, not enacted law.

Horizon · 2026-10-28 (± a quarter)CARF crypto tax-reporting exposure draft consultation closesConsultation · Tier 3 source
Horizon · 2026-10-28 (± a quarter)Crypto-Asset Reporting Framework consultation closesConsultation · Tier 2 source
Horizon · 2027-07-01 (± six months)Crypto-Asset Reporting Framework application beginsProposed · Tier 2 source
C6 · Tax Treatment — Full Module Record0 sub-modules · 180 words · 11 traced claims · Re-verified 2026-11-04

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

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Cross-border crypto activity in Australia is governed principally through AUSTRAC's registration and reporting regime for digital currency exchanges under the AML/CTF Act 2006, rather than a crypto-specific cross-border capital control. There is no blanket outbound restriction on Australians transacting with offshore crypto exchanges, though AUSTRAC has proposed (not yet enacted) new powers to restrict or prohibit high-risk products such as crypto ATMs, citing their use in cross-border money laundering. CAUTION: treat the proposed AUSTRAC product-restriction power as pending, not in force.

Horizon · 2028 (± more than a year)First international CARF taxpayer information exchangeProposed · Tier 3 source
C7 · Cross-Border & Travel Rule — Full Module Record0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

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No standing position recorded for this category.

Open gap — crypto-int-1No Standard Chartered or Zodia Custody primary press release was directly retrieved this cycle; deal value, completion date and AU-entity-specific regulatory implications remain unconfirmed.no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded in this cycle

Sources and findings (5)
  1. T4IG Group Holdings plc — IG Group completed its acquisition of a 70% stake in Independent Reserve on 30 January 2026 for an initial enterprise value of approximately US$117.1 million, following MAS approval M4 non-binding new
  2. T3Ripple — Ripple is acquiring Sydney-based BC Payments for an undisclosed amount, announced 11 March 2026, to obtain an Australian financial-services licence retrieved M3 non-binding new
  3. T3Standard Chartered; Zodia Custody Limited — Standard Chartered agreed to acquire 100% of Zodia Custody Limited, including an Australian regulated custody entity retrieved M2 non-binding new
  4. T4 · ASICIG Group Holdings plc — IG Group Holdings plc completed its acquisition of Sydney-headquartered exchange Independent Reserve on 30 January 2026, following MAS regulatory approval; deal first announced September 2025. retrieved M3 non-binding
  5. T3 · ASICSwyftx — Swyftx received an AFSL from ASIC on 8 July 2026 including non-cash payment facility authorisation (not spot-crypto authorisation). retrieved M3 non-binding
No categories match.

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Provenance and declared absence

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Suppressed by doctrine: derived risk score; per-module RAG traffic light. Not shown on this page.

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-11-04. A year-precision row is never promoted into a tighter band.

Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.

Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 69 finding(s), 83 source(s) in the cumulative register.

Audit trail

Machine checkChallenged on 3 Nov 2026: upheld (16 confirmed against the cited source; 9 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result.

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