AUSTRAC 2026: the DASP regime and the 29 July deadline

AUSTRAC - the Australian Transaction Reports and Analysis Centre - supervises anti-money-laundering and counter-terrorism-financing compliance for digital currency exchange providers and remittance dealers, and providers must be registered before offering services. For years that registration perimeter was built around one activity: exchanging digital currency. If you did not run an exchange, you could plausibly conclude the register was not about you.

That conclusion has expired. Per AUSTRAC's published transition guidance as reported in mid-2026, the regime moved to the broader DASP scope with effect from 31 March 2026, with a transition registration deadline of 29 July 2026 for firms coming into the expanded perimeter. AUSTRAC's enrol-and-register guidance on austrac.gov.au is the primary source, and because transition arrangements are exactly the kind of detail that gets refined in-flight, check it directly rather than relying on a summary - including this one.

Per the published scope, the DASP perimeter reaches beyond exchange to custody, transfers and other digital-asset services. That is the practical shift: firms that never thought of themselves as exchanges - custodians holding client assets, platforms moving digital assets on instruction, service providers built around someone else's tokens - now have a registration question to answer where previously they had a comfortable assumption.

The honest first step is a scoping exercise, not a filing. Map what you actually do for Australian-facing clients against the published scope, in writing. Some firms will find they were already caught under the old DCE perimeter and are late rather than newly in scope; others will find a genuinely new obligation with a dated deadline attached. The two positions call for the same urgency and different paperwork.

The registration itself is administrative - forms, identity, business details, through the enrol-and-register process AUSTRAC publishes on austrac.gov.au. The filing is not the work. Behind the registration must sit a real AML/CTF programme - one that reflects the services you actually provide and the risks they actually carry - because AUSTRAC reviews what stands behind the form, not just the form.

With weeks rather than months on the clock, the programme is the constraint. A firm with a functioning compliance framework can credibly file now. A firm starting from a blank page has to be honest about whether what it assembles before the deadline is a programme or a prop - and regulators are practised at telling the difference.

If Australian-facing digital-asset services are a marginal part of your book, the cleanest answer may be to stop providing them - documented, orderly, with clients notified and assets handled properly. No registration, no programme, no deadline.

We flag this route because it is legitimate, and we flag its narrowness in the same breath. The expanded perimeter exists precisely to catch services that used to sit outside it, so the set of firms that can genuinely restructure their way out is smaller than the set of firms that would like to. If the analysis requires creative reading of the published scope, it is not a restructure - it is an exposure with a memo attached.

When the clock is short, the fallback is buying a company that is already on the register rather than racing to put your own there. SKY7's live catalogue includes an Australian entity holding a dual registration - AUSTRAC digital currency exchange (DCE) plus independent remittance dealer (IRD) - which covers both the exchange and remittance sides of the perimeter in one structure. The current inventory is on our licences page.

An acquisition is a regulatory event, not a private handover. Ownership changes on registered entities must be reflected with AUSTRAC per its rules, and the AML/CTF programme has to keep functioning under the new owner from day one. How that process runs in practice - and what regulators look at when the keys change hands - is covered in our guide to buying a licensed company.

The decision turns on facts you already hold: what you actually do for Australian-facing clients, the true state of your AML/CTF programme, and whether an acquisition target that fits your model exists right now. We run this as a single structured scoping exercise - see how a SKY7 mandate runs - and the output is a route recommendation with dated milestones, not a memo that admires the problem.