Non-passporting licence routeVASP licence / registrationNo passporting

Australia VASP Registration

Australia is a high-reputation, no-passporting route for crypto exchange and remittance models that can fit an AML registration-led operating model. It is not a shortcut around AFSL analysis, and AUSTRAC registration should not be treated as covering every crypto activity by itself.

Processing time
From 3 months
Service price
21 600 EUR
Required share capital
Not required
State fee
No state fee
Annual supervision fee
No annual fee
Banking difficulty
Medium
RegulatorAustralian Securities and Investments Commission (ASIC)
Market access
No passporting

Regulatory status should be confirmed by local counsel before relying on this route.

What is the Australia VASP route?

Australia is best treated as a registration-led route for selected crypto exchange and remittance models, with a separate boundary analysis for activities that may require an Australian Financial Services Licence. AUSTRAC is the AML anchor, while AFSL-sensitive activities must be analysed separately rather than folded into one generic regulator story.

VASP
Jurisdiction
Australia
Regulator
Australian Securities and Investments Commission (ASIC)
Regime
VASP
Legal basis
The route is no-passporting and does not create EU, EEA or regional market access rights.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity scope for exchange, remittance and crypto services

Australia should not be sold as one generic VASP permission covering every virtual asset service. The activity map should separate spot exchange or remittance-style flows from custody, brokerage, advisory, staking and structured product features.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Licensed

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Not covered

    EU passporting not available from this route.

  • Startups

    Licensed

    Lower complexity makes this accessible for smaller teams.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Operating model, obligations and application file

A credible Australia file should show the proposed activity scope, responsible management, AML program, customer due diligence, sanctions screening, transaction monitoring, incident handling and banking narrative before launch.

  • Processing is shown as from 3 months, but this should be treated as an indicative registration and readiness timeline, not a guaranteed business launch date.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • No share capital, local staff, physical office, audit, state fee or annual fee is shown in the CSV snapshot, keeping setup and maintenance relatively light.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Low maintenance does not remove the need for documented AML governance, recordkeeping, reporting processes and ongoing risk review.

    Operational control area that should be covered in the applicant's governance and compliance model.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Australia onshore reputation vs passporting routes

Australia offers high regulatory reputation with low to medium setup complexity, but it does not solve passporting or AFSL-sensitive activity scope. It works best when the business wants an Australian-facing exchange or remittance profile rather than cross-border licence leverage.

  • Regulatory reputation

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Lower recognition

  • Banking access

    Onshore (this jurisdiction)

    Challenging

    Offshore comparison

    Often restricted

  • Compliance burden

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Variable

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

When Australia is not suitable

Australia is not the right route when the project needs a full financial services permission, EU passporting, a complex investment product or a licence label that can be marketed as covering every crypto activity.

  • The business model includes derivatives, investment advice, managed investment schemes, yield products or tokenised securities.

  • The commercial plan depends on EU/EEA passporting or a regional passporting right.

  • The project needs a regulator-issued full VASP licence rather than a registration-led AML route.

  • The team cannot evidence AML governance, customer due diligence, transaction monitoring and banking readiness.

Consider instead

  • Canada (MSB) MSB — Comparable registration-led route with a shorter indicative processing time
  • Dubai (VASP) VASP — Stronger fit for teams needing a dedicated onshore VASP licence route
  • Malta (MiCA) MICA — Better if EU/EEA passporting is the core commercial requirement

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Suitable

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Not suitable

EU passporting not available from this route.

Startups
Suitable

Lower complexity makes this accessible for smaller teams.

Not sure if your model fits? Request a licensing assessment

Business model fit — Australia

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
6/6
Poor fit
0/6

Australia may not cover your primary activities

Consider an alternative route that better matches your activity profile.

Is Australia VASP authorisation right for your project?

Best for

  • AUSTRAC registration-led exchange or remittance models

Not suitable for

  • Activities requiring financial services licensing without AFSL

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalNot required
Not required
Local staffNot required
Not required
Physical officeNot required
Not required
AuditNot required
Not required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local presence and substance

The CSV snapshot lists local staff, physical office, share capital and audit as not required. That makes Australia lighter than many onshore VASP routes, but the operating file still needs accountable governance and a realistic compliance function.

Local staff

Not required

Not required

Review local person requirements before setup.

Physical office

Not required

Not required

Physical office is not a stated requirement for this route.

Audit

Not required

Not required

Audit is not a stated requirement; internal controls still apply.

Planning notes

  • A lean setup is possible if the model is registration-led and does not require AFSL permissions.
  • Management responsibility, outsourcing oversight and compliance ownership should be documented even without a mandatory local office.
  • Banking partners may still ask for Australian nexus, customer base, directors, compliance officer details or operational evidence.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
21 600 EUR EURFixed
State fee
No state feeFrom
Annual supervision feeRecurring annual cost after authorisation.
No annual feeNot applicable
Required share capitalMust be held, not an expenditure.
Not requiredNot applicable
Medium ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Australia

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€21,600

Summary

One-off costs
€21,600
Annual (year 1)
€0
Total year 1
€21,600

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Australia — From 3 months.

Total timelineFrom 3 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Australia

    2–6 weeks

    Establish legal entity with required governance structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Australian Securities and Investments Commission

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 3 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP feasibility

Australia is marked as medium for banking and PSP availability. That is workable, but banks and payment providers will still examine source of funds, fiat corridors, customer geography, token policy, sanctions controls and whether the model creates AFSL concerns.

Banking difficulty
Medium

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare a banking pack before approaching providers: activity scope, AML program, transaction flow diagrams, risk assessment and management profiles.
  • Remittance and exchange flows should clearly explain fiat settlement, chargeback exposure, blockchain analytics and suspicious matter escalation.
  • Banking access should be treated as a parallel workstream, not an automatic result of registration.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 9 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Regulator profile

Regulatory authority · Australia

Australian Securities and Investments Commission (ASIC)

Regulatory reputation
High

Strong international recognition and established supervision track record.

Setup complexity
Medium

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Risk assessment

Main risk dimensions for the Australia route.

Regulatory reputation
High

Route risk rating — regulatory reputation: High.

Regulatory risk
Medium

Route risk rating — regulatory risk: Medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
Medium

Route risk rating — banking difficulty: Medium. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
Medium

Route risk rating — setup complexity: Low to medium.

Maintenance cost
Low

Route risk rating — maintenance cost: Low. Budget for ongoing compliance, fees and supervision separately.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Australia vs other VASP routes

Use Australia for a lean, reputable exchange or remittance route where AFSL risk is controlled. Compare Canada for a faster registration-led model, Dubai for a more formal VASP licence route, and Malta MiCA where EU passporting is required.

Current

Australia

VASP

Price
21 600 EUR
Timeline
From 3 months
Passporting
No passporting
Banking
Medium
Reputation
High

Canada (MSB)

MSB

Price
20 600 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Comparable registration-led route with a shorter indicative processing time

− Registration route only; not a full prudential or securities licence

View route

Dubai (VASP)

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Stronger fit for teams needing a dedicated onshore VASP licence route

− Higher substance, supervision and operating burden than Australia

View route

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ Better if EU/EEA passporting is the core commercial requirement

− Requires EU setup, MiCA compliance and local substance planning

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Australia vs other VASP jurisdictions

Compare key parameters across VASP-regulated jurisdictions.

Sort by:
AustraliaCurrent
Price21 600 EUR
TimelineFrom 3 months
BankingMedium
ReputationHigh
Canada
Price20 600 EUR
TimelineFrom 2 months
BankingMedium
ReputationHigh
Dubai
Price22 300 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh

Check your readiness for Australia VASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. Australia should be assessed activity by activity. Exchange or remittance-style models may fit a registration-led route, but custody, brokerage, advice, staking, derivatives, yield or investment product features may require separate AFSL analysis.

AML registration focuses on anti-money laundering controls, customer due diligence, reporting and transaction monitoring. AFSL analysis asks whether the business is providing regulated financial services or financial products. A project can be AML-ready and still need separate AFSL review.

The CSV estimate is 21 600 EUR with processing from 3 months. Treat this as an indicative registration and readiness timeline, not a guaranteed launch date or regulatory approval promise.

The CSV snapshot lists share capital, local staff, office and audit as not required. The company still needs accountable governance, AML procedures, recordkeeping and a credible operating model.

Banking and PSP availability are marked medium. Providers will still review the activity scope, fiat corridors, AML controls, customer geography and whether the model creates AFSL or higher-risk product issues.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

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