AFSL Crypto Requirements and ASIC's Info Sheet 225
by Dario Sabljak | 10 April 2026
Towards the end of 2025, ASIC released its updated Information Sheet 225 (INFO 225), following Consultation Paper 381 (CP 381). The guidance provides an enhanced suite of worked examples to outline how existing financial services concepts apply to digital assets and sets out ASIC’s operational expectations for Australian financial services licensees (AFS Licensees). The worked examples reinforce that financial product classification outcomes turn on the bundle of rights, benefits, expectations and product features that are associated with a particular digital asset or product involving digital assets.
In this guide, we break down the latest INFO 225 updates and the critical June 30, 2026 “No-Action” deadline.
ASIC INFO 225: The Regulatory Playbook
With INFO 225, ASIC has provided 18 examples showing how ASIC applies existing financial product definitions to a range of digital asset scenarios. These examples cover exchange tokens, yield-bearing and non-interest-bearing stablecoins, tokenised securities, tokenised bonds, derivatives referencing digital assets and non-cash payment facilities such as digital wallets.
Examples ASIC considers likely to be financial products:
- Staking and yield products: Services that allow users to earn returns through pooled or managed staking are generally treated as managed investment schemes or financial investments. ASIC’s view is that where users contribute assets that are used collectively to generate a return, the arrangement falls within the existing regime.
- Yield-bearing stablecoins and asset-linked tokens: Stablecoins or other digital assets that offer a financial return or are backed by pooled assets are likely to be securities or interests in a managed investment scheme.
- Wrapped tokens: ASIC continues to treat wrapped tokens as derivatives where the value of the wrapped token depends on, or tracks, another digital asset.
- Custodial wallets and payment facilities: Wallet providers that hold or control client assets, or facilitate payments between users, are likely to be providing a non-cash payment facility and therefore a financial service.
Examples less likely to be financial products:
- Bitcoin and similar native tokens: ASIC reiterates that Bitcoin is unlikely to be a financial product because it is not issued by an identifiable entity, does not create any enforceable rights or returns, and operates as a decentralised network token. Some comparable non-yield, widely traded tokens may also fall outside the framework, depending on how they are used.
- Game coins: Tokens issued and used within a closed gaming environment, where they function purely as a medium of exchange for in-game items or services, are generally not financial products. Their purpose is transactional rather than investment-based.
- Tokenised tickets: Tokens representing access to an event, such as a movie or concert, are unlikely to be financial products where they operate solely as digital proof of purchase or admission, even if their resale value increases.
Further, ASIC confirms that digital assets must be individually assessed to determine whether they constitute financial products. This means DCEs will need to undertake a comprehensive legal analysis of each digital asset they issue or support.
The June 30, 2026 “No-Action” Deadline
To assist digital asset financial service providers with transitioning to licensing, ASIC proposes that it will not take enforcement action for certain contraventions of the Corporations Act 2001 (Cth) provided businesses meet the below requirements and deadlines:
Have Commenced Operations: You must have been active in Australia on or before December 31, 2025.
Lodge by the Deadline: You must submit a complete AFSL application or variation to ASIC by June 30, 2026.
AFCA Membership: If providing services to retail clients, be an AFCA member before lodging the application and remain a member for at least 1 year after ceasing those services.
OR
Cessation of Services: You notify ASIC in writing of your intention to cease provision of financial services by a specified date that is (i) no later than 30 June 2026 and (ii) no later than three months after the date of the notice and the notice describes the digital assets and financial services.
Warning: The “No-Action” position does not apply to crypto-lending, “Earn” products, or high-risk derivatives. These must be licensed immediately or ceased.
How We Can Help
The Australian crypto market is maturing and the competitive advantage lies with compliant platforms. Businesses that miss the June 30, 2026 lodgement window risk immediate ASIC intervention and loss of market access.
Adria Group are experts in financial services laws and regulations, particularly in how they relate to digital assets, and can assist digital asset businesses in ensuring they efficiently transition to meeting the AFSL requirement, where it is applicable, and maintaining compliance with the evolving and stringent laws and regulations.
Contact us today for a free consultation on 1800 955 816 or [email protected].
Useful Reading
- Corporations Act 2001 – Federal Register of Legislation
- Digital assets: Financial products and services | ASIC
- Corporations Amendment (Digital Assets Framework) Bill 2025 – Parliament of Australia
- Digital currency exchange providers | AUSTRAC
- CP 381 Updates to INFO 225: Digital assets: Financial products and services | ASIC