What is the deadline for digital asset businesses to apply for an AFS licence?

Digital asset businesses must apply for an Australian Financial Services (AFS) licence — or a variation to an existing AFS licence — by 30 June 2026. This is when ASIC's sector-wide no-action position expires. Operating without the appropriate licence after that date constitutes unlicensed conduct.

Which digital asset products does ASIC consider to be financial products under INFO 225?

ASIC has confirmed that stablecoins, wrapped tokens, tokenised securities, and digital asset wallets are considered financial products under Information Sheet 225 (INFO 225). Businesses dealing in these products are providing a financial service and must hold appropriate licensing.

How does the June 2026 AFS licensing deadline relate to the new DAF Act regime commencing in April 2027?

The 30 June 2026 AFS licensing deadline under INFO 225 is a separate, earlier obligation from the Corporations Amendment (Digital Assets Framework) Act 2026, which commences on 9 April 2027. Businesses must meet the June 2026 deadline now and may also need additional DAP or TCP authorisations once the DAF Act takes effect.

Digital Asset Businesses: June 2026 Licensing Deadline

Digital asset businesses face June 2026 licensing deadline as ASIC's no-action relief expires

Digital asset businesses that provide financial services involving digital asset financial products must apply for an Australian Financial Services (AFS) licence — or a variation to an existing AFS licence — by 30 June 2026, when ASIC's sector-wide no-action position expires. Firms that miss this deadline risk breaching financial services laws and facing serious civil and criminal penalties.

Why this deadline matters

ASIC's no-action position has given digital asset businesses a window to assess whether their activities require licensing under existing financial services laws. That window closes on 30 June 2026. Once it expires, operating without the appropriate licence (or authorisation) is unlicensed conduct — and the consequences are significant.

Penalties for unlicensed conduct can include fines of up to 10% of annual turnover. This applies to businesses that should have a licence but fail to apply in time.

The deadline applies alongside the Government's broader digital asset law reform. The Corporations Amendment (Digital Assets Framework) Act 2026 (DAF Act) passed Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and will commence on 9 April 2027. That legislation will bring digital asset platforms (DAPs) and tokenised custody platforms (TCPs) under a new licensing regime. However, the June 2026 deadline under INFO 225 is a separate, earlier obligation that businesses must meet now.

Who is affected?

ASIC's updated Information Sheet 225 (Digital assets: Financial products and services — INFO 225) covers a broad range of businesses. Affected parties include:

Existing financial services and financial markets businesses exploring blockchain technology or tokenisation of real-world assets
Digital asset-focused businesses
Brokers and intermediaries dealing in digital assets
Professional advisers to any of the above

ASIC has confirmed that digital asset products considered to be financial products include stablecoins, wrapped tokens, tokenised securities, and digital asset wallets.

Plain-English worked example

Consider Digital Asset Business A, a crypto exchange that allows Australian retail clients to trade tokenised securities. Under INFO 225, tokenised securities are financial products. This means Business A is providing a financial service and needs an AFS licence.

If Business A has not yet applied for a licence, it must do so before 30 June 2026. If it misses that date, it will be operating unlicensed — exposing its directors and the business itself to civil and criminal penalties, including fines calculated at up to 10% of annual turnover.

Alternatively, if Business A does not want to hold its own AFS licence, it may instead become an authorised representative of an existing AFS licensee by 30 June 2026 — provided that arrangement covers the services it offers.

Later, once the DAF Act commences on 9 April 2027, Business A will likely also need to add DAP or TCP authorisations to its licence under the new regime.

Special rules for market and clearing licences

Businesses that require an Australian Market Licence or a Clearing and Settlement (CS) facility licence face an additional step. These firms must:

Notify ASIC in writing of their intention to apply, and
Hold a pre-meeting with ASIC

Both steps must be completed by 30 June 2026. Simply lodging a licence application is not sufficient for these categories.

Checklist for affected firms

Use this checklist to assess your position before the deadline:

Determine whether your business deals in digital asset products that ASIC considers financial products (refer to INFO 225 for the full list, including stablecoins, wrapped tokens, tokenised securities, and digital asset wallets)
Identify whether you need a new AFS licence, a variation to an existing AFS licence, or whether becoming an authorised representative of an AFS licensee is appropriate for your business model
If you require an Australian Market Licence or CS facility licence, notify ASIC in writing of your intention to apply and schedule a pre-meeting — both by 30 June 2026
Review the relief instruments for distribution of certain stablecoins and wrapped tokens, which remain in place as part of the transition to the new regime
Begin preparing your licence application now — do not wait until late June
Consider what additional authorisations (DAP or TCP) you may need once the DAF Act commences on 9 April 2027
Seek legal or compliance advice if you are uncertain whether your products or services are caught by INFO 225

What you should do next

Review ASIC's updated INFO 225 to confirm whether your products and services are classified as financial products under the current guidance
If licensing is required, begin your AFS licence application (or variation) immediately — the 30 June 2026 deadline leaves limited time for preparation and ASIC processing
If you need an Australian Market Licence or CS facility licence, contact ASIC now to arrange the required written notification and pre-meeting
If you are a professional adviser to digital asset businesses, alert your clients to this deadline and assist them in assessing their licensing obligations
Monitor ASIC's implementation roadmap for the DAF Act to understand what further obligations will apply from April 2027 onwards

Sources

Quick facts

ASIC's no-action position for digital asset businesses expires on 30 June 2026. After that date, operating without an appropriate Australian Financial Services licence constitutes unlicensed conduct. Penalties can include fines of up to 10% of annual turnover, as well as civil and criminal liability for the business and its directors.

ASIC's Information Sheet 225 (INFO 225) identifies stablecoins, wrapped tokens, tokenised securities, and digital asset wallets as financial products. Businesses that deal in these products — including crypto exchanges, brokers, intermediaries, and tokenisation platforms — are providing a financial service and must hold an AFS licence or become an authorised representative of an AFS licensee by 30 June 2026.

Businesses requiring an Australian Market Licence or a Clearing and Settlement facility licence face additional obligations beyond lodging a licence application. They must notify ASIC in writing of their intention to apply and hold a pre-meeting with ASIC — both steps must be completed by 30 June 2026.

The Corporations Amendment (Digital Assets Framework) Act 2026 (DAF Act) passed Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and will commence on 9 April 2027. This legislation introduces licensing for digital asset platforms and tokenised custody platforms, but is a separate obligation from the earlier 30 June 2026 AFS licensing deadline under INFO 225.