How should the licensing and preparation requirements for this business be confirmed?
Select according to issuing, advice, dealing and arranging activities; remittance or digital asset exchange requires a separate assessment of AUSTRAC designated services. Payment accounts are not automatically bank deposits, and AFSL does not confer deposit-taking powers.
RGYS provides support with organising materials, assessing pathways and coordinating with professionals; we are not a licensing or approval authority. Approval, registration status and operating restrictions are subject to official decisions and the actual licence.
Business scope and applicable boundaries
Select according to issuing, advice, dealing and arranging activities; remittance or digital asset exchange requires a separate assessment of AUSTRAC designated services. Payment accounts are not automatically bank deposits, and AFSL does not confer deposit-taking powers.
Application eligibility and required information
Prepare user agreements, stored value and redemption, merchant settlement, ownership of funds, payment limits, and fraud and complaints controls; consider applicable disclosure, DDO or exemptions individually, with reasons; Singapore MPI capital and PSA terminology cannot be applied.
Requirements for shareholders, directors and compliance personnel
Shareholders and directors should explain funding support and merchant relationships; RM must have payment infrastructure and operational funding capability, with security, settlement, anti-fraud, compliance and applicable AML personnel in place.
Capital and financial resource requirements
There is no general AFSL payments share-capital threshold; calculate requirements under the basic, client money and principal liability rules, and separately assess any applicable APRA stored-value facility prudential pathway or specific exemption. Proposed payments reform amounts are not current requirements.
Registered address and actual operating arrangements
Register the platform’s genuine business and customer service locations, listing merchant, bank and cloud-service addresses separately; outsourced settlement must ensure that refunds and regulatory information remain accessible.
Application and business preparation process
- Classify facilities, issuers, funds and exemption conditions.
- Establish user, merchant, settlement, redemption and AML procedures.
- Apply for the relevant NCP authorisation and complete any other necessary registrations.
- Validate payments, refunds and exit arrangements once licensing and banking partnerships are in place.
Time required and review uncertainty
ASIC 150 / 240-day targets; payment system preparation takes 3–6 months; banking and multiple regulatory matters may extend the overall process beyond 12 months.
Changes to shareholders or directors, acquisitions and transfers
An acquisition should focus on verifying outstanding balances, amounts payable to merchants, fraud and ownership of funds. Adding stablecoins, yield or deposit-taking features requires reassessment of the activity's classification.
Ongoing compliance, renewal and maintenance
Maintain payment and fund reconciliation, fraud and complaints management, redemptions and specified-service reporting on an ongoing basis; AUSTRAC registration does not replace the NCP licence. Evidence:INFO225 Payment facility analysis。
Frequently Asked Questions
Are there ten different licences for AFSL?
No. The ten items in this guide are financial services activities listed by ASIC. A single AFSL can combine several, subject to restrictions by product, client, advice and transaction subcategory. The fifteen product categories are a reading-based summary, not an official exhaustive total.
Do all applications require two RM and an independent compliance officer?
No. The number and duties of RM depend on the complexity of the business, the coverage of the manager's capabilities, available time and key-person risk. Effective compliance arrangements are required, but there is no fixed rule requiring all licensees to have two RM and a separate compliance officer.
Can a business serving only wholesale clients be exempt from AFSL?
Wholesale status alone does not exempt an entity from licensing. Wholesale-client qualification may affect disclosure and retail-protection obligations, but licensing, organisational capability, integrity and applicable capital requirements still need to be met; any specific statutory exemption must be separately substantiated.
Does registered share capital of AUD 150,000 satisfy the capital requirement?
Not necessarily. Share capital, NTA, SLF, ASLF and cash requirements differ. Pure advice may not have a fixed NTA; funds, custody, OTC and margin lending have different formulas, and client funds must not be treated as own capital.
Does an AFSL application still need to submit the core evidence for FS01 and A5／B1?
From 16 June 2025, use structured transactions in the Regulatory Portal and submit People Proofs and the requested information through the system. Former forms and fixed Core/Non-core Proofs lists no longer describe the current process; the corresponding business and compliance evidence must still be prepared.
Does ASIC guarantee approval within six months?
No guarantee is given. The official targets are to decide 70% of complete applications within 150 days and 90% within 240 days; applications may be approved, refused or referred for further assessment. Preparation, recruitment, banking, systems and other regulatory approvals are not included in these targets.
Can a new business be conducted immediately after buying a licensed company?
No. Verify the legal entity, actual licence conditions and authorisations, maintain personnel and capital, and complete change-of-control and other change procedures. New products, retail business, issuance or market making will generally require a licence variation first. AFSL cannot be transferred as a standalone asset.
Does every 20% change in shareholding require prior approval from ASIC?
No. This is not a general rule. Control is assessed under s910B, including majority ownership and the ability to exercise actual control; ASIC's website requires notification no later than 30 business days after control begins or ceases. Specific licence conditions, APRA or other investment approval regimes may impose additional requirements.
Does using a third-party custodian necessarily exempt you from custody authorisation and NTA?
Not necessarily. Whether custody services are provided depends on the contract, the law and beneficial interests; NTA relief for incidental custody services that do not involve physical holding is available only if all conditions are met. External custody arrangements in MDA where clients contract directly are subject to specific rules, which cannot be applied to all funds.
Must every AFSL company open a client trust account?
No. A pure advisory firm that does not receive client funds has no equivalent need. Where client money, insurance premiums, fund property or custodial assets are actually handled, the relevant legal arrangements apply separately to each.
MDA Is this an additional standalone licence?
No. MDA requires a specific issuing authorisation limited to MDA services, together with the underlying transaction, advice and custody authorisations required, and compliance with the 2026/720 conditions. It cannot be covered merely by a general fund manager or IDPS designation.
Has the 2026 increase to fund NTA already taken effect?
The relevant 2026/708 instrument has been published. The corresponding increases for responsible entities, IDPS and retail CCIV take effect from 1 July 2027. Current calculations and future budgets must be kept separate; future minimum thresholds must not be treated as rules already in force in 2026.
Are digital asset platforms already fully subject to the new DAP／TCP capital requirements?
As at 5 November 2026, no. The new framework Act has been passed and is due to commence in April 2027; CP392 standards remain under consultation. Existing digital asset services involving securities, funds, derivatives and payments remain subject to current law; parts of the reform for additional designated services AML are already in force.
Does being licensed mean that ASIC endorses a product or guarantees account opening?
No. A licence assesses the entity’s capacity and compliance arrangements at the time; it does not guarantee investment performance, product quality, profitability or acceptance by banks. Do not use ASIC branding to imply endorsement, or present AUSTRAC registration as certification of an investment product.
Does annual maintenance only require an annual company review?
No. Company annual review, AFSL financial and audit requirements, applicable industry levies, supervision of managers and representatives, capital, complaints, insurance, reportable situations, fund and AML filings are separate matters. Ceasing business also requires client assets, complaints and exit arrangements to be dealt with before the licence is cancelled.
Official sources and verification notes
Information verified: 5 November 2026. Business classifications do not replace legal definitions; use the latest versions of official webpages and legislation where they are updated.
- User-owned source: RGYS Australian AFSL guide; extracted in full and saved as afsl-source.md, with regulatory facts updated
- ASIC: Check if you need an AFS licence; ten activities and no endorsement
- ASIC INFO294: current application portal, People Proofs and transaction sub-classes
- ASIC application transaction records: product and sub-product options
- ASIC Service charter: targets of 70% within 150 days and 90% within 240 days for complete applications; tables read and verified via HTML
- ASIC RG105: number of responsible managers, five knowledge and experience pathways, and organisational competence; 2025 updated attachment
- ASIC RG166: financial requirements; attachment dated 21 October 2026, body text read using pdftotext
- ASIC: 2026/708 capital amending instrument and commencement in July 2027
- ASIC: company directors and secretaries, public companies and CSF shareholder rules for proprietary companies
- ASIC／ABRS director ID obligations: pre-appointment application and 2027 company lodgement obligations are separate
- ASIC: company addresses; registered office and principal place of business
- ASIC: updates to licensing information and website registration
- ASIC: definition of control and 30-business-day notification
- ASIC: annual financial statements, audits and lodgement deadlines for different entities
- ASIC RG271: current internal dispute resolution and IDR data
- ASIC INFO281: advisers' professional standards, relevant products and the experienced provider pathway; 2026 update
- ASIC: CCIV structure, corporate directors, external directors and sub-fund reporting
- ASIC INFO86: dual licensing and resource assessment boundaries for RSE and AFSL
- ASIC INFO253: claims handling and settlement licensing; 2025 update
- ASIC RG262: scope and ongoing requirements for crowd-sourced funding intermediaries
- ASIC INFO251: trustee of an unregistered scheme; the website states that it is being revised following the BPS appeal, so the old exemption interpretation should not be applied mechanically
- ASIC RG179: new MDA attachment dated 30 September 2026; the webpage title still shows the old date, and the body has been checked against the new attachment
- ASIC: MDA instrument 2026/720 replacing the old instrument and changes to maintenance requirements
- ASIC INFO156: boundaries of changes to ACCU, EIEU, SMC and existing custody authorisations
- ASIC INFO225: current classification of digital assets as financial products; descriptions of future consultation should be updated in light of the latest announcements in 2026
- ASIC 2026-10-15: new digital assets law, CP392 consultation and current applications; do not present future capital requirements as current
- ASIC April 2026 implementation roadmap: future DAP／TCP framework; the one-day difference between the date and the October announcement has been recorded
- ASIC 2026-10-12: consultation remains open on the extension and amendment of CFD intervention orders
- AUSTRAC: AML/CTF reform implementation dates, expanded designated services and transition
- APRA: FAR designated applicable entities and implementation from 2024/2025
- ASIC RG255: licensing and algorithmic advice governance for robo-advisers; to be read together with current adviser professional standards
- ATO: financial supplies, GST and input tax credit boundaries
Notes on corrections to historical information in this guide
Explain the ten financial services activities as combinable authorisations on one AFSL, not as ten separate licences; the fifteen product classes are a summary in this guide, and applications must still select the official products and subcategories.
Use the description reflecting the current arrangements: from 16 June 2025, Regulatory Portal and People Proofs replaced the old eLicensing, FS01 and fixed Core／Non-core Proofs upload process. Annual financial reporting is also handled through transactions in the current portal.
Correct ‘Responsible Officer’ to ‘Responsible Manager’; remove unsupported general requirements for two RM, a universal RM university degree or Australian citizenship, or a fixed number of compliance officers. Advisers providing personal advice on relevant products to retail clients are subject to separate professional standards.
Distinguish minimum share capital, positive net assets, cash requirements, NTA, SLF and ASLF. There is no uniform requirement of 150,000 NTA for advice-only services; retail OTC, funds, custody, traditional trustee services, CSF and margin lending are subject to different financial regimes.
Although increases to the capital thresholds for fund responsible entities, IDPS and retail CCIV have been announced, they take effect only on 1 July 2027; do not present future requirements as current capital requirements for 2026.
Do not treat third-party custody as automatically exempting the business from a custody licence or NTA. Funds, IDPS, MDA, and core and incidental custody must be assessed according to their individual structures. MDA is not an eleventh independent activity or a uniform asset management licence for 150,000 NTA.
Update RG165 to the current RG271; distinguish complaint time limits for general, superannuation and other special procedures, and assess PI and AFCA according to the actual retail and exemption conditions.
Remove the promise of obtaining a licence in 4–6 months after supposed optimisation. ASIC's decision targets are 70% within 150 days and 90% within 240 days for complete applications; commercial preparation and the total timeframe should be separately labelled as non-binding estimates.
An acquisition is a transaction involving the shares or business of a licensed entity; a licence cannot be transferred independently. A change of control is not subject to a uniform 20% threshold or prior approval from ASIC. The website says notification is due no later than 30 business days after starting or ceasing to control. Other licence conditions and regulatory approvals must be checked separately.
Update the MDA requirements under 2026/720 and the 2026 edition of RG179; do not continue applying 2016/968, the old ten-day breach notification requirement or perpetual quarterly reporting. Electronic access to information arrangements have a transition period.
AUSTRAC Obligations for designated services are not determined automatically by the AFSL number; in 2026, AML/CTF reforms already in force must be distinguished from matters still in transition, and cannot all be described as future trends.
The 2026 digital asset framework legislation has passed, but DAP／TCP takes effect in April 2027, and CP392 remains under consultation as at the date of this guide; capital requirements already in force must not be invented. The April and October ASIC announcements differ between 8／9 April; the date is expressly subject to verification, with no commitment to a specific day.
The October 2026 CFD amendments, including extension to 2037, remain under consultation. The current intervention order is expected to run until 23 May 2027; FAR applies only to the specified banks, insurers and superannuation entities, not to all AFSL.
Correct the classification of SMC: it falls within the category of eligible international emissions units, EIEU. Not all carbon credits fall within ACCU／EIEU; existing custodial authorisation and capability requirements for additional carbon products must be analysed separately.
Remove keywords such as Singapore's Payment Services Act, MPI and DPT, and capital requirements, that are misplaced as general Australian AFSL requirements. Classify ordinary remittance, payments, spot exchange and foreign exchange contracts involving financial products separately.
Rules for shareholders, directors, addresses, tax and employees depend on the entity and business in question. Avoid generalised claims such as requiring a dedicated office in Sydney, requiring all data to be localised in Australia, or exempting all financial income from GST.
Retain author attribution and contact details for advice from its own sources; remove unverified claims about the number of licences obtained, success rates, regulatory certification, bank-friendliness and institutional partnership reputation. Do not falsely claim that the author is an Australian licensed lawyer, auditor or financial adviser.
The complete original text from the owned source has been saved as afsl-source.md. This extraction is available for checking regardless of future changes to the source webpage; the public guide has been reorganised against official materials rather than mechanically copied.
YOUR CONSULTATION PARTNER
Drew Tang （Mr Tang / Drew）
Business Manager · Rengangyongsheng (Hong Kong) Limited
Speak with Mr TangThis article was prepared by Rengangyongsheng (Hong Kong) Limited, with business explanations provided by Drew Tang ( Mr Tang) Business Manager. It is general information and does not replace advice on an individual matter from an Australian lawyer, tax adviser or regulator.