Australia’s corporate regulator, the Australian Securities and Investments Commission, has told digital-asset businesses relying on its sector-wide no-action position to apply for, or vary, an Australian Financial Services (AFS) licence by September 30, 2026.
From October 1, businesses that do not satisfy the arrangement’s conditions may be exposed to civil and criminal penalties for breaches of financial-services law. ASIC said potential fines can reach 10% of annual turnover.
September 30 ends ASIC’s no-action position
As parts of the digital-asset sector work through whether their activities require an AFS licence under existing law, the regulator’s no-action position has provided a temporary bridge. It leaves the underlying licensing framework intact and instead sets the circumstances in which ASIC has said it would not take action during the transition.
That position now has a hard end date. ASIC’s September 7 notice framed the deadline as a final call for businesses that have used the relief to submit a new licence application or seek a variation to an existing licence.
For firms still relying on the position, the immediate issue is therefore compliance with the current financial-services regime, rather than the later start of Australia’s bespoke digital-assets legislation. Businesses that miss the requirements after September 30 risk losing the protection of the interim approach.
The extension added three months and broader interim pathways
ASIC originally set June 30, 2026 as the deadline, then extended the no-action position by three months to September 30. In its June announcement, the regulator also broadened the temporary coverage to include certain authorised-representative and intermediary arrangements involving licensed firms.
The extension gave affected businesses more time to map their services against licensing obligations and choose an interim route. But it was an extension of the transition window, not a permanent exemption from the rules.
ASIC’s June 26 update described the revised arrangements as part of its response to the evolving regulatory treatment of digital-asset businesses. The regulator has now set September 30 as the point at which those temporary settings cease to shield firms that have not fulfilled the stipulated conditions.
Licence applications rose from about 30 to more than 45
ASIC reported more than 45 relevant digital-asset licence applications after updating Information Sheet 225 in October 2025. That was up from approximately 30 applications when it announced the September extension in June.
The figures indicate additional applications were made during the extended window, though ASIC did not say that every business potentially affected by the no-action position had applied. Nor do the totals reveal the outcome of individual applications.
Information Sheet 225 is ASIC’s guidance on how the existing Australian financial-services laws may apply to digital-asset-related products and services. The agency’s reported application count is one measure of the sector’s engagement with that framework ahead of the deadline.
Infographic outlining Australia’s September 30, 2026 digital-asset licensing deadline, compliance pathways, October 1 enforcement exposure, exclusions, and ASIC’s reported 45-plus applications. — Source: CryptoSlate
Facility operators face a notice-and-meeting deadline
Businesses that require an Australian market licence or a clearing-and-settlement facility licence must notify ASIC of their intention to apply and hold a pre-application meeting by September 30, according to CryptoSlate.
Formal applications for those licences may then be lodged within 12 months.
The licensing push precedes the 2027 Digital Assets Framework Act
The licensing deadline falls before Australia’s new statutory framework for digital assets takes effect. The Corporations Amendment (Digital Assets Framework) Act 2026 passed Parliament on April 1, received Royal Assent on April 8 and is scheduled to commence on April 9, 2027, ASIC said in its roadmap for implementation.
That leaves a transition period of more than six months between the end of ASIC’s no-action position and the new Act’s commencement. Until then, ASIC’s September 30 deadline places existing AFS licensing obligations at the centre of the regulator’s approach to qualifying digital-asset businesses.
Disclaimer: This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

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