Australia’s regulatory landscape for stablecoins entered a new phase in September 2025, as the Australian Securities and Investments Commission (ASIC) unveiled the ASIC Corporations (Stablecoin Distribution Exemption) Instrument 2025/631. This move directly impacts intermediaries, market makers, custodians, and general advice providers, who facilitate access to stablecoins issued by licensed entities. The exemption is already reshaping how financial product rules apply to stablecoin distribution, with the AUDM stablecoin by Catena Digital Pty Ltd leading as the first beneficiary.
Historically, any entity distributing stablecoins classified as financial products had to secure an Australian Financial Services (AFS) licence or other market approvals. ASIC’s 2025 instrument effectively removes this barrier for intermediaries dealing in certain AFS-licensed stablecoins. The goal: reduce regulatory friction while maintaining consumer protections during Australia’s digital asset reform period.
Key Provisions of the ASIC Stablecoin Exemption
The exemption covers a range of intermediary activities, including:
- General advice on eligible stablecoins
- Dealing in (excluding issuance of) stablecoins
- Market making
- Custodial or depository services
These activities can now be performed without separate AFS, market, or clearing and settlement facility licenses, provided the underlying issuer holds an AFS licence for the specific stablecoin. For now, only AUDM qualifies under this regime, but ASIC has left the door open for future expansion to other compliant issuers.
What Intermediaries Must Do to Stay Compliant
The relief comes with obligations. Intermediaries must ensure retail clients have timely access to the issuer’s Product Disclosure Statement (PDS), when available. This transparency requirement is non-negotiable and will be central to compliance audits. The exemption is temporary and set to expire on June 1,2028, giving both regulators and industry players time to adapt before permanent frameworks are enacted.
Key Compliance Duties for Stablecoin Intermediaries (2025)
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Distribute Only AFS-Licensed Stablecoins: Intermediaries must ensure they only distribute stablecoins issued by entities holding a valid Australian Financial Services (AFS) licence, such as AUDM by Catena Digital Pty Ltd.
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Provide Product Disclosure Statements (PDS) to Retail Clients: When a PDS is available for the stablecoin, intermediaries must make it accessible to all retail clients before or at the time of distribution.
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Limit Activities to Permitted Services: Exemptions apply strictly to general advice, market making, dealing (excluding issuance), and custodial or depository services for eligible stablecoins. Issuance and other activities remain regulated.
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Maintain Ongoing Compliance with ASIC Exemption Conditions: Intermediaries must comply with all conditions set out in the ASIC Corporations (Stablecoin Distribution Exemption) Instrument 2025/631, including record-keeping and reporting obligations.
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Observe Temporary Nature and Expiry Date: The exemption is temporary and will expire on June 1, 2028. Intermediaries should monitor regulatory updates and prepare for potential changes post-expiry.
This regulatory easing aligns with Australia’s broader strategy to foster digital asset innovation while safeguarding market integrity. By lowering licensing hurdles for distributors, notably without relaxing standards for issuers, ASIC is signaling a pragmatic approach that balances growth and oversight.
The Bigger Picture: Digital Asset Reform and Market Impact
The timing of these exemptions is significant. Australia is midstream in its overhaul of crypto policy settings, with further reforms expected through 2028. By targeting intermediaries rather than issuers, ASIC aims to stimulate competition among service providers while maintaining strict control over who can issue regulated financial product stablecoins.
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