Where things stand 

On 26 November 2025, the Treasury Laws Amendment (Genetic Testing Protections in Life Insurance and Other Measures) Bill 2025 (Bill) was introduced into the House of Representatives. The Bill includes proposed licensing exemptions for foreign financial service providers.

If passed, the Bill will create 3 replacement licensing exemptions being a ‘professional investor’ exemption, a ‘comparable regulator’ exemption and a ‘market maker’ exemption. The exemptions will replace the current limited connection relief and sufficient equivalence relief regimes.

On 5 December 2025, the Australian Securities and Investments Commission (ASIC) announced it has extended transitional relief for limited connection and sufficient equivalence relief, from 31 March 2026 to 31 March 2027.

ASIC has also stated that foreign financial service providers currently relying on an individual relief instrument with an expiry date linked to ASIC Corporations (Repeal and Transitional) Instrument 2016/396 can continue relying on the individual relief instrument until 31 March 2027.

What’s next

The Bill is expected to pass both houses of Parliament and receive Royal Assent during 2026.

Eligible foreign financial service providers can continue relying on limited connection and sufficient equivalence relief until 31 March 2027.

We are awaiting an announcement from ASIC regarding its position regarding transitional arrangements to the new regime.


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This article was originally published on 8 September 2025 and updated on 10 November, 27 November and 9 December 2025.