FinTech Voice November 24, 2022

Dear Community,

Consultations continue to remain a priority through December – Treasury seeking feedback on the Buy Now, Pay Later Options Paper by 23 December; AUSTRAC seeking feedback on draft guidance in de-banking by 21 December; and APRA consulting on amending the minimum capital requirements for Purchased Payment Facilities Providers. We are working with members when drafting these submissions. See below for more.

Lastly, this week we also launched our talent matching program in partnership with Upplft to ensure talent stays in the community. Fintechs that are hiring or anyone who has recently been displaced can Register here to receive support.

FinTech Australia will be holding the Annual General Meeting on November 25 to vote for the new Director. We will announce the new Director soon after.

For any queries and support, please reach out to us.


Rehan D’Almeida,
General Manager,
FinTech Australia

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Buy Now, Pay Later Options Paper released

The Government is seeking feedback on the future regulatory framework for buy now, pay later (BNPL).

The Options Paper, released on Monday, outlines three potential options for regulatory intervention:

  1. Stronger industry self-regulation plus a new “affordability test” requirement.
  2. Limited BNPL regulation under the Credit Act, including licensing and scalable unsuitability test.
  3. Regulation of BNPL under the Credit Act, in line with credit cards and other traditional credit products.

We welcome the paper and the Government’s acknowledgement that BNPL products deliver real benefits to the vast majority of consumers. The paper provides a good basis for progressing a proportionate regulatory proposal which protects consumers and supports innovation.

Treasury is seeking feedback by 23 December. FinTech Australia will make a submission.

AUSTRAC consults on draft de-banking guidance

USTRAC is seeking feedback on draft guidance in relation to de-banking. The document is intended to provide guidance to ADIs and fintechs on AUSTRAC’s expectations when ADIs provide services to customers that they assess to be higher risk.

It follows AUSTRAC’s 2021 statement on de-banking which encouraged banks to take a case-by-case, risk based approach to managing AML/CTF risks. The draft guidance is unique because it provides guidance for ADIs as well as affected remitters, DCEs and fintechs on AUSTRAC’s expectations.

AUSTRAC is seeking feedback by 21 December. FinTech Australia will make a submission.

We are also holding a Working Group call for members on de-banking to discuss this guidance and the outcomes of the recent CFR report. If you would like to join, please register here.

APRA consults on minimum capital requirements for PPF providers

PRA is consulting on a proposal to amend the minimum capital requirements for Purchased Payment Facilities Providers.

The proposal is an interim measure while the Government continues to consider reforms to the regulatory framework for stored-value facilities (previously considered by the CFR in 2020 and likely to form part of the forthcoming consultation paper on a payments licensing framework).

The proposed amendments reduce the minimum capital requirement from 5 per cent to 4 per cent, move the capital measurement basis to Common Equity Tier 1 Capital, and provide for APRA to vary minimum capital adequacy requirements for individual PPFs.

APRA is seeking feedback by 13 February 2023. FinTech Australia will make a submission.

Treasury to progress custody rules for digital assets in 2023

The Government has suggested custody rules for digital assets will be prioritised and consulted on early next year, with legislation expected by the end of 2023.

This consultation will follow the forthcoming ‘token mapping’ consultation paper which is expected to be released before the end of this year. FinTech Australia will work with the Government and make submissions in support of both consultation processes.

If you have an interest in this space, please register for our Crypto Assets, Blockchain and Web3 Policy Working Group.

Unfair contract terms penalties legislated

Parliament has now passed amendments to make unfair contract terms illegal.

The reforms introduce civil penalty provisions outlawing the use of, and reliance on, unfair terms in standard form contracts. This significantly strengthens the previous provisions, which only resulted in a term being void if found ‘unfair’ by a court or tribunal.

The reforms also expand the scope of small businesses protected by the unfair contract terms provisions. The small business eligibility threshold increases from less than 20 employees to less than 100 employees, and an annual turnover threshold of less than $10 million has been introduced as an alternative threshold for determining eligibility.

Current consultations

We are currently developing submissions to consultations on:

– AUSTRAC’s draft guidance on de-banking;

– Senate References Committee Inquiry into ASIC;

– Treasury’s BNPL Options Paper;

– APRA’s proposals for PPF minimum capital requirements.

We have recently made submissions on:

– Treasury’s draft legislation to enable CDR action initiation;

– APRA’s draft prudential standard CPS 230 (Operational Risk Management);

– The Board of Tax’s consultation paper on the tax treatment of crypto assets and transactions;

– ASIC Industry Funding Model Discussion Paper;

– Senator Bragg’s private bill on digital assets regulation;

– DESE’s Startup Year Consultation Paper.

See our recent submissions on our website.

FinTech Australia regularly makes submissions to consultations across a wide range of policy and regulatory issues. Communications about how to get involved in these processes are distributed to our Policy Working Group membership.

💳Stay or Go has revealed 1 in 2 credit card customers (6.1 million in total) would benefit by simply transferring to a more suitable product with their current bank. Remaining on their current product is estimated to be costing these customers a collective $1.5 billion each year. Consumers can access Stay or Go at

📚BSI is offering FinTech members a special discount on Information Security and other training courses. Please use the promotional code EOY2022 at checkout to activate your 20% discount. Offer valid 1 November to 9 December 2022. Email for more information on how BSI can help you. See here

📱Modern Card Issuance: The “new normal” in Banking implies the delivery of an intuitive mobile app combined with the swift roll-out of an integrated solution. To launch such a modern card program, card issuers must re-invent their card issuing platform. See here

🏦Payment innovations in a customer-centric world join them as they explore how payment innovations can help you build a more customer-centric business. As the year draws to a close, they’ll also reflect on the payment innovations that defined 2022, as well as predictions for 2023. 1 Dec, 1-2 pm. Register here

Don’t miss all the news and insights from our members and corporate partners from our newsroom.

  1. Frollo calls for government consumer awareness campaign as more businesses embrace Open Banking
  2. Adatree, in partnership with energy technology enabler Accurassi, is making it possible for thousands of households to securely and easily transition homes to zero carbon by providing personalised and accurate data on how many solar panels are needed to offset one’s current energy consumption.
  3. Mambu and Credisense collaborate to offer APAC lenders a next-generation end-to-end lending solution
  4. BetaCarbon launches first platform enabling Australians to invest in Australian carbon via blockchain
  5. DoxAI has a new deal to expand digital services marketplace for finance industry. Lakeba and Microsoft sign strategic partnership to support growth of high-tech businesses
  6. Thriday signs exclusive Banking-as-a-Service agreement with Regional Australia Bank
  7. Open Finance Advisors launches to help make open banking in Australia a reality
  8. partners with Joust to help millions of Australians find their dream property
  9. DL COMMS has shared about four mums behind Australia’s number one social network for parents raising children with disabilities. Kindship, who have raised more than $1 million that will go towards their start-up that unravels NDIS complexity.
  10. Bridgit has expanded its broker network this month by partnering with one of Australia’s largest mortgage broking groups, Finsure.
  11. Frollo has disabled screen scraping for 20 more banks in its free money management app and instead will rely on Open Banking data for those banks.
  12. Fintech coaXion signs equipment finance pilot agreement with non-bank lender, opens new funding round.
  13. DoxAI has appointed Lisbeth Hadingham to be its new Executive Vice President North America.

  1. Emerging Markets FinTech is a step ahead
  2. Why zero trust security is central to operational resilience – and regulatory compliance
  3. Complii FinTech Solutions pursues ongoing growth following Registry Direct acquisition
  4. Banking veteran Rob Craig joins Aussie fintech payFURL as Chief Strategy Officer
  5. How are fintech players leveraging technology to offer better solutions to Indian customers?
  6. Australia’s technology industry: What to expect in the next few years

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