Regulatory Recap | Week commencing 27 April 2026

On the pulse

• ASIC updates two information sheets – see ASIC Regulatory tracker.
• ASIC's roadmap for digital assets law reform implementation – see media release.
• ASIC consults on regulatory guide updates to implement financial market infrastructure reforms – see media release.
• ASIC updates FAQs for AFS licence applications – see ASIC Regulatory tracker.
• ASIC updates three information sheets in relation to AFS licensees – see ASIC Regulatory tracker.
• ASIC updates multiple regulatory guides and information sheets following reissue of RG 181 – see ASIC Regulatory tracker.
• AUSTRAC: Banks step up to disrupt illicit tobacco profits – see media release.
• AUSTRAC: Unacceptable blind spot: low reporting in wealth management sector – see media release.
• ATO: Super funds and CIVs required to lodge RTP schedule for TT26 – see media release.
• G+T Insight – ICANN’s New gTLD Program 2026 round: what you need to know.
• G+T Insight – The Competitive Edge with Gilbert + Tobin.
• G+T Insight – Hybridisation is no longer optional – it’s the new baseline.
• G+T Insight – ASIC publishes implementation roadmap for digital asset regulation.
• G+T Insight – Why Australia's biggest energy risk isn't electricity – it’s fuel.
• G+T Insight – How Mythos-class AI is changing cyber security risk.
• G+T Insight – Mythos AI: autonomous cyber threats and why boards must act now.
• G+T Insight –Authorisation after iiNet: power, indifference and the future of intermediary liability.
• G+T Insight – Social sector spotlight – April 2026.
• G+T Insight – From goodwill to payroll: navigating the volunteer employee distinction for charities.
• G+T Insight – Proposed overhaul of foreign resident capital gains tax rules.
• G+T Insight – Navigating Australia’s foreign investment regime.
• G+T Insight – Takeovers and schemes review 2026.
• G+T Insight – Treasury consults to regulate super platform investment governance and switching risks.

ASIC

ASIC's roadmap for digital assets law reform implementation

On 20 April 2026, ASIC published its roadmap for implementing new laws that bring digital asset platforms (DAPs) and tokenised custody platforms (TCPs) under the financial services licensing regime from April 2027. The Corporations Amendment (Digital Assets Framework) Act 2026, which will commence on 9 April 2027, provides for an 18-month implementation timeline. The roadmap is as follows:

• Months 1–6:
  • Conduct stakeholder roundtables and establish an industry advisory group.
  • Consult with industry on standards and guidance to be set out in legislative instruments.
  • Information Sheet 225: class no-action position will expire in June. Entities must comply with existing licensing requirements throughout the implementation of the law reforms.
• Months 6–12:
  • Release a new regulatory guide for DAPs and TCPs, covering how the new law operates and who is likely to require a licence under the regime.
  • Make regulatory instruments setting standards for the operators of DAPs and TCPs, including asset-holding standards, transactional and settlement standards, and financial requirements.
• Months 12–18:
  • DAP and TCP operators can lodge financial services licence applications and operate under regulatory relief until their applications are processed.
• Month 18 onwards:
  • Full implementation of the new regime, including ASIC supervision and enforcement.

ASIC consults on regulatory guide updates to implement financial market infrastructure reforms

On 20 April 2026, ASIC announced it had opened consultation on proposed updates to three regulatory guides to support implementation of the government’s financial market infrastructure reforms. The proposed updates respond to legislative changes introduced by the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024, which received Royal Assent in September 2024. ASIC is seeking feedback on proposed updates to:

• Regulatory Guide 172 Financial markets: Domestic and overseas operators (RG 172).
• Regulatory Guide 249 Derivative trade repositories (RG 249).
• Regulatory Guide 268 Licensing regime for financial benchmark administrators (RG 268).

Submissions for feedback close 25 May 2026.

ASIC states that the updates will help to align its guidance with the strengthened and streamlined regulatory framework established by the financial market infrastructure (FMI) reforms to reflect, among other things:

• ASIC's enhanced licensing, supervisory and enforcement powers.
• The reallocation of certain powers between the Minister and ASIC.
• ASIC's expanded oversight of foreign entities operating FMIs with a significant Australian nexus.

ASIC updates FAQs for AFS licence applications

On 20 April 2026, ASIC updated Information Sheet 294 FAQs: AFS licence applications (INFO 294) to include a new requirement for AFS licensees to submit and maintain their official website URL so it is published on ASIC registers, improving transparency and helping the public verify legitimate licensee websites.

ASIC updates three information sheets in relation to AFS licensees

On 21 April 2026, ASIC updated the following information sheets to clarify the scope of permitted activities, advice conduct and disclosure obligations, and ongoing financial and reporting requirements:

• INFO 227 What can limited AFS licensees do?
• INFO 228 Limited AFS licensees: Advice conduct and disclosure obligations
• INFO 229 Limited AFS licensees: Complying with your licensing obligations

ASIC updates multiple regulatory guides and information sheets following reissue of RG 181

On 21 April 2026, ASIC updated 12 regulatory guides and two information sheets. The following were updated to reflect consequential amendments to names, cross-references and minor technical content to align with the reissue of RG 181 AFS licensing: Managing conflicts of interest in December 2025:

• RG 1 Applying for and varying an AFS licence
• RG 79 Research report providers: Improving the quality of investment research
• RG 100 Court enforceable undertakings
• RG 112 Independence of experts
• RG 131 Funds management: Establishing and registering a fund
• RG 132 Funds management: Compliance and oversight
• RG 133 Funds management and custodial services: Holding assets
• RG 236 Do I need an AFS licence to participate in carbon markets?
• RG 237 Trustee companies: Transfer determinations by ASIC
• RG 246 Conflicted and other banned remuneration
• RG 262 Crowd-sourced funding: Guide for intermediaries
• RG 277 Consumer remediation
• INFO 134 Complying with your obligations if both credit licensee and AFS licensee
• INFO 225 Digital assets: Financial products and services.

AUSTRAC

Banks step up to disrupt illicit tobacco profits

On 14 April 2026, AUSTRAC announced that banks have taken decisive action to disrupt the financial flows underpinning Australia’s illicit tobacco trade, strengthening oversight to effectively cut off criminal cash flows. In late 2025, AUSTRAC and the Illicit Tobacco and E-Cigarette (ITEC) Commissioner wrote to the banking sector, warning of the growing risks linked to tobacco retailers and convenience stores using cash, private ATMs and EFTPOS terminals to move and disguise illicit tobacco proceeds. Since then, AUSTRAC has received 337 suspicious matter reports using that code, improving the intelligence available to law enforcement to disrupt criminal supply chains and money flows.

Unacceptable blind spot: low reporting in wealth management sector

On 15 April 2026, AUSTRAC announced it has written to businesses in the wealth management sector with concerns about alarmingly low suspicious matter reporting (SMR) and the risk that serious financial crime may be going undetected. The letter follows a supervisory campaign in which AUSTRAC found that 98% of wealth management businesses did not submit a single SMR in 2025, despite operating in a sector exposed to a wide range of money laundering risks, particularly via digital channels and stolen identities enabling cyber fraud. AUSTRAC is urging all wealth management businesses to review the letter and assess whether the information provided is relevant to their business and, where appropriate, to incorporate it into their money laundering and terrorism financing risk assessment.

Other bodies and regulators

ATO: Super funds and CIVs required to lodge RTP schedule for TT26

On 21 April 2026, the ATO announced that from 1 July 2026, reportable tax position (RTP) schedule obligations will apply to large APRA-regulated super funds and large collective investment vehicles (CIVs) that have:

• Total fund/business income exceeding $250 million.
• Meet the lodgment criteria set out in the relevant RTP schedule instructions.

G+T articles 

G+T Insight – ICANN’s New gTLD Program 2026 round: what you need to know – outlines ICANN's 2026 new gTLD application round, including key dates, fees, contention rules and brand protection strategies for trade mark owners – Lisa Lennon and Starrie Shi (22 April 2026).

G+T Insight – The Competitive Edge with Gilbert + Tobin – A competition law podcast titled ‘O, for Hormuz of Fire: Geoff Petersen on the regulatory response to the fuel shocks that are raising prices and causing shortages around the world’ – Moya Dodd and Matt Rubinstein (22 April 2026).

G+T Insight – Hybridisation is no longer optional – it’s the new baseline – discusses how across the National Electricity Market, hybridisation is rapidly becoming the default model for utility-scale renewables – Jamie Guthrie, Christopher Flynn and Clare Pope (22 April 2026).

G+T Insight – ASIC publishes implementation roadmap for digital asset regulation – summarises ASIC's 18-month phased roadmap for licensing and supervising digital asset and tokenised custody platforms under Australia's new Digital Assets Framework – Peter Reeves, Georgina Wilcock, Vince Battaglia, Emily Shen, Anthony Basa, Stephanie Choong, Amiinah Dulull, Maya Ruber and Billy Elsum (21 April 2026).

G+T Insight – Why Australia's biggest energy risk isn't electricity – it’s fuel – argues that Australia needs urgent policy action to develop domestic sustainable aviation fuel production to address its fuel security vulnerability – Jamie Guthrie, Christopher Flynn and Clare Pope (21 April 2026).

G+T Insight – How Mythos-class AI is changing cyber security risk– examines how Mythos-class AI systems are enabling sophisticated, adaptive cyber-attacks that can autonomously identify vulnerabilities and evade traditional defences, requiring organisations to fundamentally rethink their cyber security strategies – Ross Phillipson, Simon Burns and Melissa Fai (21 April 2026).

G+T Insight – Mythos AI: autonomous cyber threats and why boards must act now – outlines how Mythos-class AI is powering a new generation of autonomous cyber threats capable of self-directed attacks, and why boards must urgently reassess their governance frameworks and cyber resilience strategies – Ross Phillipson, Simon Burns and Melissa Fai (21 April 2026).

G+T Insight – Authorisation after iiNet: power, indifference and the future of intermediary liability – compares the US Supreme Court's decision in Cox Communications v Sony Music with Australia's iiNet ruling, examining the United States treatment of intermediary liability in Cox and considering the emerging battleground as enforcement pressures shift beyond conventional ISPs to platforms and AI-enabled services – Rebecca Dunn, Caitlin Meade and Molly Allen (21 April 2026).

G+T Insight – Social sector spotlight – April 2026 – Darren Fittler, Elizabeth Wighton, Neha Sharma and Caroline Conan-Davies (16 April 2026).

G+T Insight – From goodwill to payroll: navigating the volunteer employee distinction for charities – discusses the line between a volunteer and an employee – Tom Brett, Elizabeth Wighton, Taylor Goodrum and Neha Sharma (16 April 2026).

G+T Insight – Proposed overhaul of foreign resident capital gains tax rules – discusses the government’s proposals for a significant overhaul of Australia's foreign resident capital gains tax – Julian Cheng, Matthew Charman and Sophie Jiang (15 April 2026).

G+T Insight – Navigating Australia’s foreign investment regime – explains some aspects of the rules governing foreign investment in Australia and the screening process – Alastair Corrigall, Deborah Johns, Sarah Findley and Ebony Keenan-Dunn (15 April 2026).

G+T Insight – Takeovers and schemes review 2026 – analyses public M&A transactions involving ASX-listed targets announced in 2025 with a value exceeding $50 million – Rachael Bassil, Costas Condoleon, Olivia Blakiston and Wes Bainbridge (13 April 2026).

G+T Insight – Treasury consults to regulate super platform investment governance and switching risks – summarises the Treasury’s recent consultations – Luke Barrett, Silvana Wood, Tom Salzano, Chris Whittaker and Manda Knezevic (13 April 2026).

Calendar dates 

• 8 May 2026 – Submissions to ASIC consultation on proposed updates to derivative transaction rules due.
• 30 May 2026 – AML/CTF reforms: Notify AUSTRAC of AML/CTF Compliance Officer (deadline for existing entities).
• 1 July 2026 – Mandatory climate-related financial disclosures for Group 2 entities apply in respect of financial years starting on or after this date.
• 1 July 2026 – Key AML/CTF obligations commence for Tranche 2 entities (such as lawyers, accountants, conveyancers and providers of real estate services).
• 13 July 2026 – Key CDR obligations commence for non-bank lenders.
• 31 July 2026 – Submissions to ASIC consultation on increasing net tangible assets requirement for responsible entities due.
• 4 December 2026 – Amendments to the Corporations Act to expand substantial holding disclosure to commence.
• 1 July 2027 – Mandatory climate-related financial disclosures for Group 3 entities apply in respect of financial years starting on or after this date.