ASIC No-Action Letter: Boosting Digital Asset Innovation 2025
In what can be called an ambitious move, on October 29, 2025, the Australian Securities and Investments Commission (ASIC) released a comprehensive regulatory framework, dealing with some classes of digital assets. Among the addresses are stablecoins, wrapped tokens, tokenised securities, and digital wallets. Together with the INFO 225, ASIC also brought a no-action letter.
But what is the primary aim of the release? According to the document, INFO 225 focuses on “businesses and people offering products and services in relation to digital assets generally.”
This is more important if your business is involved with digital assets, whether there are elements that are decentralised or not (e.g. exchanges, intermediaries, digital asset wallet providers, operators of decentralised finance platforms, asset managers and custodians.
This release aims to help everyone understand their obligations under the Corporations Act 2001 and the ASIC Act 2001.
The importance of this release also extends to individuals who are “considering, issuing or selling digital assets, dealing or advising on digital assets (whether to raise funds or otherwise), or offering other products or services related to digital assets.”
Let us take a deeper look at some of the big entrants of this new INFO 225 regime.
ASIC Updated Guidance (INFO 225)
Among the most recent introductions is the Updated Information Sheet 225 (INFO 225). The information sheet is majorly ASIC’s primary interpretative guidance for the financial services regime. First produced in 2017, since then, the INFO guidance has been updated in 2018, 2019, and 2021.
So, what are the latest updates in this guidance?
A media release statement accompanying INFO 225 notes that under the existing law: “Stablecoins, wrapped tokens, tokenised securities and digital asset wallets are among the digital asset products that ASIC considers to be financial products..”
In the statement, you will also find some 18 worked examples displaying the applications of ASIC’s financial product definition to the different use cases of digital assets. However, the document noted that this was not an exhaustive list. It actually says:
“The 18 hypothetical worked examples in Part A of this information sheet are not exhaustive. They are designed to help you think about these issues, but each product needs to be assessed on its own facts and circumstances. “
ASIC’s latest updates advise entities to separately analyse individual tokens and see if they qualify as financial products. Look into the rights and benefits attached, including the uses of the product. According to the document:
“This analysis is critical to determining whether the digital asset, and/or arrangement related to the digital asset, is a financial product.”
The production of this document aligns with the Digital Assets and Payment reforms proposed by the Australian Government.
However, since the Australian Government is already in consultations “on an exposure draft for amendments to introduce digital asset platforms and tokenised custody platforms as new financial products,” newer updates could come sooner than later.
So, what are the practical implications of the new INFO 225 updates?
If a product falls under the definition of a financial product, its issuance requires licensing and approval from regulators. By encouraging issuers to understand regulatory status before providing tokens, these updates promote compliance.
Although there has been a wave of regulatory ambiguity in various jurisdictions. These new ASIC updates provide more clarity, eventually encouraging institutional participation.
Class No-Action Letter Details
In its INFO 225 update, ASIC also issued a class no-action letter to balance innovation and the protection of investors. A no-action letter is a policy where a regulator outrightly says they will not take action against a certain conduct for a given duration.
As per the ASIC INFO 225:
“This is a letter in which we state to a particular person that we do not intend to take regulatory action over a particular state of affairs or particular conduct.”
However, this does not mean that laws are changing. And, it will not protect the organization from other third-party suits. This policy took effect from October 29, 2025, and will operate until June 30, 2026.
But really, why the need for No-Action?
The primary aim of the No-Action letter is to provide industry participants with a transitional period to adhere to the changes in direction. But this does not give companies a pass. And, as per the letter, “It is not a guarantee that we will not take action in the future, nor is it intended to affect the rights of third parties to take action in relation to any contravention. It is not legal advice and may be withdrawn at any time.”
Scope and eligibility
As per reports, the No-Action letters will target:
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Firms that provide financial services (AFS)
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Firms operating in financial markets
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Firms operating clearing/settlement facilities associated with digital assets are categorized as financial products.
Crypto lending/earn products, non-cash payment facilities (except stablecoins),are not within the scope of the no-action letter.
Moreover, the target group must have begun its activities on or before December 31, 2025, if the relief is to apply. And, the firms must take actions to apply for the AFSL, or other variations, by June 30, 2026.
For those applying for a market licence, and even clearing and settlement facilities, you must make a formal notification to ASIC by June 30, 2026, and take action within 12 months.
Conditions for No-Action
For firms providing services to retail clients, they must be members of the Australian Financial Complaints Authority (AFCA) before applying. And, they should remain members of the same for at least 12 months after ending their services.
Foreign entities are also allowed to register in Australia as foreign companies. However, the condition is appointing a local agent. A non-Australian company must “have been registered as a registered foreign company and have appointed a person as a local agent under section 601CF of the Act.”
RBA’s Project Acacia Announcements
Project Acacia is a collaborative research initiative between the Reserve Bank of Australia (RBA) and Digital Finance Cooperative Research Centre (DFCRC) to explore how tokenized asset infrastructure could support Australian wholesale markets. This project puts keen eyes on the ‘WHOLESALE’ tokenized asset market, including different forms of digital money like stablecoins, bank-deposit tokens, and a pilot wholesale CBDC.
As per Project Acacia consultation papers, there are five settlement models, including:
Considering the settlement models, on July 10, 2025, RBA, together with DFCRC, announced that they had settled on “24 innovative use cases from a diverse range of organisations.” These use cases include 19 pilot use cases and five proof-of-concept use cases with simulated transactions.
According to the RBA, the tests of the use cases would take a 6-month duration beginning mid-2025, and the results will be produced in Q1 2026.
While commenting on this, the Assistant Governor (Financial System) at the RBA, Brad Jones, said:
“The use cases selected in this project will help us to understand better how innovations in central bank and private digital money, alongside payments infrastructure, might help to uplift the functioning of wholesale financial markets in Australia.”
In a mission to support the new innovative class, ASIC reduced the licensing burdens for participants in Project Acacia. Kate O’Rourke, ASIC Commissioner, said:
“ASIC sees useful applications for the technologies underlying digital assets in wholesale markets. The relief from regulatory requirements that we have announced today will allow these technologies to be sensibly tested—to explore opportunities and identify and tackle risks.”
An inter-regulator collaboration in Australia is clear testimony that tokenized assets are not a mere sideshow, but an entire evolution. With Project Acasia, Australia towers above many other jurisdictions as a leader in creating and testing the next generation of finance.
Final Thoughts
ASIC’s latest developments, the INFO 225 update, and the no-action letter bring a dawn to a new digital asset regime in the country. The former represents clarity of the regulations, while the latter enables time for cooperation. It seems Australia aims to be among the pioneers of proper financial designs and testing, especially with the recent growth in tokenisation.
ASIC’s significance extends beyond Australian borders. It's a signal to global markets that tokenized assets and stablecoins are going into mainstream adoption. Businesses enjoy less regulatory friction, hence build without fear of enforcement disruptions. Individuals enjoy clarity in rules, which translates to safer platforms.
The move will speed up capital inflows, strengthen institutional participation, and encourage proper testing across both the crypto industry and the broader financial sector.
The transition means businesses and investors who come early and understand the implications of these developments will win in the new chapter. uCubed gives founders and investors a suitable environment for understanding new rules and navigating tokenized markets.
This article has been written for educational purposes only. This article does not constitute financial advice or advice to use as a financial product, and should not be perceived as a recommendation to integrate or use a form of technology that may pose risks to operations if not integrated correctly. Please note that successful blockchain integrations requires a strong foundation of knowledge, due diligence, research, development, training, and/or professional consulting.
