The grace period's up. On 30 September, ASIC's transitional relief for digital asset businesses wrapped up. From 1 October, any firm that needs a licence or variation but hasn't met the no-action conditions risks breaching financial services law, with civil and criminal penalties on the table.

How we got here

ASIC updated its digital assets guidance (INFO 225) in October 2025 and gave the industry a sector-wide breather while firms got their houses in order. The pause was originally due to end on 30 June, but it was pushed out to 30 September. ASIC says it's received more than 45 licence applications for digital asset financial services since the guidance changed.

To stay covered, firms had to lodge an AFS licence application or variation. The other option was getting an authorised representative or intermediary arrangement in place with an existing licence holder. Crypto lending and earn products, non-cash payment facilities (other than stablecoins) and most derivatives were never covered.

And there's more to come

This is only round one. The Digital Asset Framework passed Parliament in April and is slated to commence on 9 April 2027. It brings exchanges, custodians and certain token platforms into the existing AFSL framework. The language is shifting too, with "digital currency exchange provider" making way for "virtual asset service provider" (VASP).

The catch is that ASIC has flagged that firms licensed under INFO 225 may need to add Digital Asset Platform and Tokenised Custody Platform authorisations once the new regime kicks in. So plenty of businesses will be going through licensing twice in 18 months.

What this means for talent

Here's where I'm seeing the market move:

• Compliance and risk leaders. A licence needs people who can build and run a proper framework, not just tick boxes.
• Responsible Managers and Key Persons. Applicants have to show they've got credible, experienced people in these roles, and everyone's chasing the same small pool.
• AML/CTF specialists. The VASP change signals tighter obligations, and exchanges and custodians will want people who've done the hard yards before.
• Legal and regulatory affairs. Firms need someone who can handle ASIC now and be ready for the second round next year.
• Product and operations. If your products fall outside the relief, you need leaders who can restructure or wind down cleanly.