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description: "There is no single digital assets law in Australia and no single regulator. The same token can sit inside several regimes at once. This hub maps which regimes touch what you do, as at June 2026."
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# Digital Assets in Australia

![Digital Assets in Australia - Astris Law Brisbane commercial law firm](/assets/crypto-blockchain-D8gPizEH.jpg)

## Digital Assets Law in Australia: The Regulatory Map

By Jamie Nuich, Legal Practitioner Director. Positions stated as at June 2026.

There is no single digital assets law in Australia and no single regulator. The same token can sit inside several regimes at once, and they were not designed to work together. A business can be compliant with one and in breach of another without realising it. This page maps which regimes touch what you do. It does not resolve any of them for your matter, because that turns on detail, and getting it wrong is the expensive part.

If you want the position for your specific token, platform or business, that is what we advise on. [Call us](/contact).

[Home](/)› Digital Assets in Australia 

Where the regime stands right now 

## The 30 June 2026 lodgement window has closed. The regime commences 9 April 2027.

The deadline to lodge a complete AFSL application under ASIC's no-action position passed on 30 June 2026. Businesses that lodged in time now face the assessment gauntlet before the new regime commences on 9 April 2027. Businesses that missed it are operating without that protection, and what to do about it depends on the facts. Either way, do not wait for April to find out where you stand. [Contact Astris Law](/contact) on (07) 3519 5616.

## Currency, or something more: the contested question people get wrong

It is often said that a token used purely as a means of payment, bitcoin being the usual example, is not itself a financial product. ASIC has long taken that view of pure payment tokens. People hear it and assume they are outside the system. That is the trap, and the position is more contested than the headline suggests.

The characterisation of bitcoin and assets like it is genuinely unsettled at the edges. ASIC's stated positions on how the existing law applies to digital assets have been tested in court and have not always held, and whether a given token is a financial product turns on the rights it carries rather than the label it wears. A token that gives the holder a claim, a return, a share of a pool or a redemption right can be a financial product under the _Corporations Act 2001_ (Cth) whatever it is called. And even where the token itself sits outside, the services around it, holding, trading, arranging, advising, operating the platform, can be regulated in their own right.

Where a particular token and business fall on that line is the single most important question in this area, it is genuinely arguable in many cases, and it is the one most often answered wrongly by people relying on a forum post. It is not a question to resolve from a website. It needs advice on the specific token and facts, which is what we do.

## The regimes that can apply to you

Each of the following can apply at the same time. The point of this section is to show you how many doors there are, not to walk you through any of them.

### Corporations Act and the licensing regime

If your token is a financial product, or you operate a platform that holds tokens for others, the Australian financial services licence regime under Chapter 7 of the _Corporations Act 2001_ (Cth) is in play. The _Corporations Amendment (Digital Assets Framework) Act 2026_ (Cth) received Royal Assent on 8 April 2026 and commences on 9 April 2027. It brings the platform layer, holding and tokenised custody, into the financial product list. Operating without the right authorisation once it applies is an offence under s 911A of the _Corporations Act 2001_ (Cth), with significant civil and criminal exposure.

Whether you need your own licence, can rely on an exemption or should operate another way is the question everyone asks here. See the exemptions section below, and then speak to us, because the answer is matter-specific.

### Anti-money laundering

Businesses that exchange, transfer or hold digital assets for others have obligations under the _Anti-Money Laundering and Counter-Terrorism Financing Act 2006_ (Cth). The perimeter widened on 31 March 2026 to capture crypto-to-crypto exchange, custody and token facilitation, not just turning crypto into dollars, and further transfer obligations follow on 1 July 2026. These obligations sit separately from anything ASIC requires.

### Tax

The Australian Taxation Office treats a digital asset as a capital gains tax asset, which follows from it being property rather than money. Gains on disposal are taxable, the discount can apply where the asset is held more than twelve months, and rewards such as staking and airdrops are generally income when received. Changes proposed in the May 2026 Budget are not law.

### Stablecoins and payments

Stablecoins are heading into a dedicated regime. The stored-value facility framework released for consultation in March 2026 would require issuers to be licensed and, above a threshold, prudentially supervised, with full backing held in reserve. Under current law ASIC already treats many stablecoins as financial products.

### And several more, which is the point

Depending on what you do, the following can also apply, and each is its own body of law: the consumer protection provisions of the Australian Consumer Law in Schedule 2 to the _Competition and Consumer Act 2010_ (Cth), the credit licensing regime under the _National Consumer Credit Protection Act 2009_ (Cth) where credit or lending features are involved, gambling and gaming law where a product has a wager or chance element, sanctions law and privacy law. Custody and banking sit across several of these and are dealt with separately below.

We are not going to set each of these out here. The reason they are listed is so you can see how easily a digital asset business ends up inside three or four regimes at once. Which ones apply to you, and how they interact, is exactly the advice to get before you build.

## Custody: the most misunderstood area, and Australia is not the United States

Custody is the question we are asked about most, and the one where imported assumptions cause the most damage. The Australian position is not the United States position. There is no direct local equivalent of the US qualified custodian model, the new platform regime changes how holding tokens for others is treated, and banking access for digital asset businesses is a separate and unsolved problem regardless of how well you are licensed.

If your model involves holding tokens or assets for clients, custody is not a detail to leave to last. It is a structuring decision that touches the licence question, the new framework and your banking. We work through it with clients directly. It is not something to lift from an offshore template.

## The exemptions everyone searches for, and why the search is the wrong place to stop

Most enquiries in this area start with someone trying to find the exemption that keeps them outside the system. These are the ones people look up:

-   Whether their activity is a financial product or financial service at all.
-   The wholesale or sophisticated client carve-outs, and whether their customers qualify.
-   The small-scale offering exemption under s 708 of the Corporations Act 2001 (Cth), often searched as the twenty investors or two million dollar limit.
-   Operating under someone else's licence rather than holding your own.
-   The transitional relief and the 30 June 2026 deadline.

Each of these is real. Each has conditions that are narrower than they look, and each is routinely misapplied by people reading the headline and not the fine print. Relying on the wrong exemption is how businesses end up unlicensed without knowing it. That is an expensive way to find out.

We will tell you which, if any, apply to you. We are not going to set out how to qualify for them here, because that is the advice people pay for and getting it wrong has consequences we would rather you avoid.

## Read the detail

[

### Cryptocurrency Regulation in Australia: What the Law Actually Says in 2026 

The detailed companion to this hub. How the financial product question, the anti-money laundering perimeter and the tax treatment actually apply, with the dates and the moving parts.

](/article/cryptocurrency-regulation-australia-2026)[

### Crypto and Blockchain Industry 

How Astris Law and the wider group act for exchanges, token issuers, custody providers and digital asset founders across the regimes mapped on this page.

](/industry/crypto-blockchain)

## Frequently Asked Questions

### Is cryptocurrency legal in Australia?

Yes. Holding, using and trading digital assets is lawful. What is regulated is the activity around them, across several regimes at once. Which ones apply to you depends on what you do.

### Is a digital currency a financial product?

A token used purely as a means of payment is generally not itself a financial product, on ASIC's longstanding view. But many tokens carry other rights that change that, and the services around any token can be regulated regardless. Whether a particular token is caught is a matter for advice.

### Do I need my own licence, or can I use an exemption or someone else's?

That is the most common question in this area and the answer is specific to your business and your customers. There are exemptions and there are other ways to operate, each with conditions that are easy to misread. We assess which, if any, fit your situation.

### What about custody?

Custody is one of the most misunderstood areas and the Australian position is not the same as the United States. If you hold assets for others it is a core structuring decision, not a detail. We advise on it directly.

### What is the 30 June 2026 deadline?

It is the expiry of ASIC's transitional no-action position for existing digital asset businesses. If it might apply to you, the time to act is now.

## How Astris Law helps

We advise digital asset businesses on the questions this page raises: classifying a token and a platform under the _Corporations Act 2001_ (Cth), licence and authorisation strategy, anti-money laundering obligations, custody and banking structuring, stablecoins and the 30 June 2026 transition. We work across the Astris group, including HeadStart Counsel for founders and earlier stage operators. The sector is noisy and the free guidance is often wrong. The value is advice grounded in the law as it actually stands, applied to your facts.

Call (07) 3519 5616 or [contact us](/contact).

[Contact Us](/contact)

This page is general information, not legal advice. It states the position as at June 2026 and the regimes it describes are mid-transition, so some dates and rules will change. Obtain advice tailored to your circumstances before acting. Liability limited by a scheme approved under Professional Standards Legislation.

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