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The A$14 million figure is a proposed ASIC capital test, not a final rule that every Australian crypto exchange must meet. ASIC is consulting on three possible financial-reserve models as Australia prepares to bring digital-asset platforms into the Australian financial-services licensing system in 2027. The strictest model would require an operator without qualifying independent custody to hold net tangible assets of at least A$14 million or 10% of average revenue, whichever is higher.
The proposal sits alongside a separate AUSTRAC crackdown on anti-money-laundering and counter-terrorism-financing controls. ASIC would oversee licensing, custody, prudential resources and market conduct; AUSTRAC would continue registering and supervising virtual asset service providers for AML/CTF compliance.
What the proposed A$14 million rule would do
ASIC’s consultation package, released on 15 October 2026, covers customer-asset protection, trade execution, conflicts of interest and financial reserves. Under one capital model, a platform that does not use a qualifying third-party custody concession would need net tangible assets of at least A$14 million or 10% of its average revenue, whichever is greater.
That is a consultation option rather than an enacted universal threshold. The amount could change after submissions, and the final guidance and legislative instruments are expected in March 2027. ASIC says the framework is intended to reflect the growing role of digital assets and tokenisation in mainstream finance. Commissioner Alan Kirkland described the proposed guidance as acknowledging “the increasing role of digital assets and tokenization, including in traditional parts of the financial system.”
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ASIC’s three capital models
The consultation presents three approaches. The figures below are proposed tests, not settled law.
| Model | Proposed starting requirement | How the calculation changes |
|---|---|---|
| 1: custody-based | A$14 million for an operator without a qualifying third-party custody concession | Without the concession, the operator would also be tested against 10% of average revenue, with the higher amount applying. A platform using qualifying independent custodians could instead face the highest of A$200,000, 0.5% of average underlying asset value capped at A$7 million, or 10% of average revenue. |
| 2: non-financial-product assets | A$7 million floor | Designed for platforms holding only assets that are not financial products. The consultation does not establish a final universal formula beyond that proposed floor. |
| 3: activity-based | A$2 million starting floor | Additional capital would be added according to assets, revenue and activities such as brokerage or operating a trading venue. |
The practical distinction is risk and business design. Independent custody could reduce the starting requirement under Model 1, while holding larger customer balances or running more complex trading activities could increase the amount under any model that uses assets, revenue or activities as inputs. ASIC has not yet selected one approach.
Capital is only one part of the ASIC package
The consultation would impose operational controls intended to keep customer assets identifiable and available if a platform fails.
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- Wallet reporting: platforms would report crypto-wallet arrangements and addresses quarterly.
- Reconciliation and segregation: firms would face tighter requirements to reconcile customer holdings and keep them separate from the operator’s assets.
- Permitted use: customers would have to authorise any permitted use of their underlying assets.
- Insolvency protection: proposals would address how client assets are protected and returned if a platform becomes insolvent.
- Related-party capital: certain stablecoins issued or controlled by related parties could not be counted as regulatory capital.
For trading, ASIC is considering best-execution duties for certain intermediaries, access to at least two adequate liquidity sources, restrictions on a platform trading as principal on its own venue, and a ban on incentives that favour particular tokens. These measures target conflicts and execution quality rather than simply the size of a balance sheet.
When Australian crypto platforms enter the AFSL regime
The Corporations Amendment (Digital Assets Framework) Act 2026 received Royal Assent on 8 April 2026 and is scheduled to commence on 9 April 2027. It creates two financial-product categories—digital-asset platforms and tokenised-custody platforms—and places them under ASIC licensing and supervision.
ASIC’s transition notice required firms needing a new or varied Australian financial services licence to apply by 30 June 2026. That deadline has passed as of 15 October 2026; firms that missed it could risk conducting unlicensed business, depending on their activities and transition status.
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Under the framework described by Treasury on 26 November 2025, licence obligations would include efficient, honest and fair conduct; clear information about how assets are held and what rights customers have; governance and risk controls; dispute-resolution arrangements; and compensation mechanisms. Treasury proposed an exemption for smaller platforms that hold less than A$5,000 per customer and facilitate less than A$10 million in annual transactions. The exemption remains subject to the legislation and final rules, so a platform cannot assume it applies solely from those figures.
Treasury also cited Digital Finance Cooperative Research Centre research estimating that digital-finance innovation could generate as much as A$24 billion a year in Australian productivity and cost savings. That economic opportunity is part of the policy rationale, but it does not alter the proposed capital calculations.
AUSTRAC’s parallel AML/CTF crackdown
AUSTRAC’s work addresses a different risk. On 8 May 2026, it launched supervisory campaigns involving 36 crypto businesses providing over-the-counter crypto-to-cash or cash-to-crypto services and 27 local exchanges. Reviews focus on each business’s model, scale, governance and anti-money-laundering and counter-terrorism-financing risk management.
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“AUSTRAC is checking how well crypto businesses in Australia are managing money-laundering risks, ahead of major new laws coming into force,” Chief Executive Officer Brendan Thomas said.
In a 2 April 2026 update, AUSTRAC said AML/CTF laws had expanded to a broader virtual-asset sector and that Australia was replacing “digital currency exchange” with virtual asset service provider (VASP). AUSTRAC reviewed 128 inactive businesses on its register; 62 left the sector through registration action or voluntary withdrawal. All businesses providing virtual-asset services must register and comply with AML/CTF obligations.
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Thomas said the terminology change was “more than a name change” because it reflects how the sector has evolved. Home Affairs Minister Tony Burke said the reforms close gaps criminals have used to move illicit funds while allowing legitimate innovation to continue safely.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.ASIC and AUSTRAC: different regulators, overlapping transition
| Question | ASIC | AUSTRAC |
|---|---|---|
| Primary remit | Financial-services licensing and supervision, prudential resources, custody, conflicts and market conduct | AML/CTF registration, supervision and enforcement for virtual asset service providers |
| Key trigger | The Digital Assets Framework Act commencing 9 April 2027, plus ASIC’s licence transition | Expanded AML/CTF coverage and supervisory campaigns already under way in 2026 |
| What a platform must demonstrate | Capital or reserve resources, asset segregation, reconciliation, governance, disclosure, dispute resolution and fair execution under the final ASIC rules | Registration, risk-based AML/CTF programs, governance and controls for detecting and reporting illicit-finance risks |
| Does one approval replace the other? | No. An AFSL does not remove separate AML/CTF duties. | No. VASP registration does not satisfy ASIC’s financial-services licensing requirements. |
What happens next
- 27 November 2026: ASIC consultation submissions are reportedly due. The capital models and conduct proposals can still change.
- March 2027: ASIC is expected to issue final guidance and instruments, subject to the consultation outcome.
- 9 April 2027: The Digital Assets Framework Act is scheduled to commence, bringing covered platforms into the AFSL regime.
For exchanges and custodians, the immediate task is mapping customer assets, custody arrangements, revenue and activities against each proposed model while maintaining AUSTRAC registration and AML/CTF controls. Customers should treat any advertised “A$14 million requirement” as a description of a proposal until ASIC publishes the final rules.
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