ASIC's crypto capital draft sets a A$14 million floor for platforms that lack third-party custody

The A$14 million figure is half a formula. ASIC's draft asks operators without qualifying third-party custody arrangements to hold the greater of A$14 million in net tangible assets or 10% of average revenue ^[3], and the two prongs cross at A$140 million of average revenue ^[16]. Below that, the flat floor binds: a platform averaging A$50 million in revenue would hold A$14 million, or 28% of that revenue ^[17]. Above it, revenue sets the number, and a platform averaging A$300 million would hold A$30 million ^[18].

That is one model of the three ASIC is weighing ^[2], and Cointelegraph's report describes only that one. Operators can size one path. We think the first decision is custody, because the only published figure is attached to the absence of a qualifying third-party arrangement ^[3]. Amy-Rose Goodey, chief executive of the Digital Economy Council of Australia, names the same lever. She said the council will be "working closely with our members to examine the three proposed capital models in considerable detail, particularly their proportionality across businesses of different sizes and the concessions available for third-party custody." ^[11] Buying a qualifying custodian would then also change which line of the capital schedule an operator sits on. That could be wrong in three ways: ASIC could collapse the three models into one by March ^[7], the concession could prove smaller than the custodian's fees, or comments on proportionality could move the A$14 million itself.

Shange Chandra, chief executive of OKX Australia, expects the draft to sort operators. "These standards are appropriately onerous," he told Cointelegraph. "They will reward operators who have already invested in compliance, capital and custody. They will challenge operators who have waited to make that investment." ^[12] He said the proposals could drive industry consolidation ^[13], and he asked for a streamlined license process for established firms with a track record of compliance ^[14].

Goodey's point about business size has a number behind it. Under the A$14 million model, any platform averaging less than A$140 million in revenue holds more than 10% of that revenue as capital, and the share rises as revenue falls ^[19]. On trading, she said the restrictions on "principal trading, affiliated liquidity arrangements and best execution requirements will also warrant careful consideration, given their implications for how Australian exchanges operate and access liquidity." ^[15]

The calendar is short at one end and long at the other. Final standards are due in March 2027 and the law takes effect on April 8 ^[7][8], which leaves at most 38 days between them ^[9]. Applications then run to Oct. 7, 2027, about six months after the start date ^[10], and the report says operators can operate while ASIC assesses their applications ^[8]. Nov. 27 is the deadline for feedback on this draft ^[7]. We would count the custody-first view wrong if the March text drops the revenue prong or lands all three models on one figure.