Zip model, AUSTRAC, qAUD legality · 06_bank_exchange/BANK_EXCHANGE_PLAN.md

qalarc — Bank / Exchange / Credit-Token Research & Design Plan

File: 06_bank_exchange/BANK_EXCHANGE_PLAN.md Research date: 6 September 2026 Prepared for: qalarc (qalarc.com, tradez.au, doof.ing, endispute.com.au) — QALS utility token, credit/token platform, DeFi exchange ("Qalx"), bank-like exchange system.

NOT LEGAL ADVICE. This document is a research synthesis prepared by an automated agent from public web sources. Financial services law in Australia is complex, fact-dependent and changing. Every material step described here must be validated by an Australian financial-services lawyer (fintech/credit/crypto practice) and, where relevant, by ASIC, APRA, AUSTRAC and the ATO before qalarc builds or launches anything. Claims that could not be verified against a live primary source at research time are tagged [UNVERIFIED].

1. Zip Co (ASX: ZIP) as the model

1.1 What Zip actually is in 2026

Zip is a dual-market (Australia/NZ + United States) point-of-sale instalment-credit and payments company. Its own investor relations page reports this FY26 scorecard (Zip reports on a calendar-year basis; figures as published at zip.co/investors, retrieved 6 Sep 2026):

Share price at retrieval: ~A$2.44. Zip's current strategic pushes visible on the IR page: a Stripe US partnership and an "AI and agentic commerce" product narrative — i.e., Zip itself is moving toward embedded/agentic checkout credit, which is exactly the adjacency qalarc is contemplating.

Product structure (AU): Zip Pay (smaller-limit, interest-free, fee-funded consumer account) and Zip Money (larger-limit line of credit carrying interest, historically a "continuing credit contract"), plus a US instalment product. Revenue comes primarily from merchant fees (MRC) charged as a % of transaction value, consumer fees (monthly account fees where charged), and interest on the Money-style product; Zip removed late fees in the US and has substantially de-emphasised consumer penalty fees in AU. [UNVERIFIED: current AU fee schedule and exact MRC range — industry norm ~3–6% of TIV for online BNPL.]

1.2 How Zip is licensed / regulated in Australia

• Since the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024, in force 10 June 2025, BNPL products in Australia are "low cost credit contracts" (LCCCs) regulated under the National Consumer Credit Protection Act 2009 (NCCP). From 10 June 2025 every BNPL provider must hold an Australian Credit Licence (ACL) authorising it as a credit provider and must be a member of AFCA (source: Hall & Wilcox, "Buy-now pay-later reform: what you need to know", Feb 2025 — see Sources).
• Fee caps in the LCCC regime (per the regulations as summarised by Hall & Wilcox): non-default fees capped at A$200 in the first 12 months and A$125 per subsequent 12-month window; default fees capped between A$120–A$320. Exceed the caps and the product is regulated as a full credit contract.
• LCCC providers may elect modified (scaled-down) responsible lending obligations: credit-bureau pull (ID, default, repayment history info), income/expenditure info, disclosure of other LCCCs/SACCs/leases; a presumption that contracts ≤A$2,000 meet the consumer's objectives; a 120-day pre-contract assessment window; and a written unsuitability-assessment policy. Lenders may also use the full RLO regime.
• Moneysmart (updated 14 Jul 2026) confirms the consumer-facing reality: fee caps, mandatory hardship/complaints processes, and BNPL applications and late payments appearing on credit reports.
• Important structural trap: the LCCC/"BNPL contract" definition requires a third-party provider paying a merchant on the consumer's behalf. Credit financed directly by the merchant itself (first-party closed-loop credit for its own goods/services) falls outside the BNPL/LCCC definition (Hall & Wilcox analysis). This is the single most important design lever for qalarc (see §5, Phase 1→3).
• Zip's credit is funded through warehouse facilities with bank lenders (receivables warehousing/securitisation), not deposits — Zip is not an ADI. [UNVERIFIED: current facility sizes and lenders; historically Zip's ANZ receivables warehousing involved major-bank funders; a Bendigo and Adelaide Bank relationship existed around earlier Zip products. Verify against Zip's latest annual report.] Regulatory capital does not apply to Zip as such, but ACL responsible-lending, AFCA membership and (for the funding vehicles) securitisation reporting do.

1.3 What is copyable vs what needs a licence

Copyable without an ACL (closed-loop only): prepaid/store-credit economics; checkout UX (instalment display for prepaid balances); internal credit-scoring models (as analytics on your own users, not as "credit"); merchant-side "float" — holding prepaid customer funds creates working capital, but see stored-value/PF rules in §2.4 before monetising it.

Needs licences: any third-party-paid instalment credit to consumers (ACL/LCCC from 10 Jun 2025); charging interest on money owed to qalarc for non-qalarc goods; late fees above the caps; operating credit for third-party merchants (that's the Zip model proper); anything marketed with "credit/loan" language; using restricted words like "bank".

2. "Setting up our own bank" — the Australian reality check

2.1 ADI licensing (APRA)

From APRA's live licensing page (retrieved 6 Sep 2026, see Sources):

• "Banking business" under Part 5 of the Banking Act 1959 = taking deposits (other than as part-payment for identified goods or services) + making advances. Do both → you need an ADI licence; doing it without one is an offence. Corporations only (no partnerships/unincorporated).
• Two pathways: direct (meet the full prudential framework on day one) and restricted (RADI) — the Restricted ADI pathway lets you conduct limited banking business for up to two years while you build to full compliance, per APRA's New entrants – a pathway to sustainability framework (Aug 2021 information paper, still the governing guidance).
• Restricted words: APRA consent is required to use "bank/banker/banking/neobank/banq" etc. if you are not an ADI — relevant to how qalarc markets any "bank-like" product.
• Realism: capital in the tens of millions (recent neo-bank entrants raised A$100m+ before launch), a 2–4+ year journey, full prudential framework (CPS 230 operational risk, CPS 234 info security, capital & liquidity standards), FAR accountability registrations. [UNVERIFIED: no new locally-incorporated ADI licences granted in the 2022–2026 window to my knowledge — the 2019 wave (Volt, 86400, Judo) was the last; Volt surrendered its licence in 2022. Verify current applicants with APRA's register.]

2.2 Stored value / purchased payment facilities (PPF)

APRA authorises large Purchased Payment Facility providers as a special class of ADI — if your stored-value instrument is "widely available, used as a means of payment, and redeemable on demand," APRA (with ASIC and RBA) can capture it. Small closed-loop prepaid balances redeemable only for the issuer's own goods/services are generally outside this, but the boundary matters enormously for QALS (see §5). The 2020 CFR review of Stored Value Facilities recommended a modernised regime that is still being progressed. [UNVERIFIED: current SVF legislative status as of Sep 2026.]

2.3 AUSTRAC: digital currency exchange → "Virtual Asset Service Provider" registration

Verified directly from AUSTRAC's live site (pages updated May 2026):

• AUSTRAC now brands crypto exchanges as Virtual Asset Service Providers (VASPs). If you exchange "digital currency" (crypto ↔ money, or crypto ↔ crypto) for customers with a geographical link to Australia, you must register with AUSTRAC (enrolment first, then registration via AUSTRAC Online). This is the "DCE registration" — the cheapest and fastest regulatory toehold for Qalx.
• The registration form itself (retrieved in full, 13 May 2026 version) asks for: wallet addresses you control; classes of virtual assets (explicitly including stablecoins, tokenised assets, governance tokens); deposit/withdrawal channels; transaction/volume expectations; an ML/TF risk assessment approved by a senior manager; AML/CTF policies (personnel due diligence, CDD per customer type, PEP screening, source-of-wealth processes, monitoring rules/thresholds, employee training, independent review cadence); key personnel history and fit-and-proper disclosures; and unlawful-activity disclosures.
• The 2024–2026 AML/CTF reforms expanded designated services ("Virtual asset designated services" is now its own AUSTRAC page), extending coverage across more VA activities and (from 2026) to professional-services gatekeepers. Assume broker/transfer/custody-style crypto activities are captured, not just exchange.
• Ongoing obligations: AML/CTF program, SMRs (suspicious matter reports — 24h/3h deadlines depending on type), TTRs (threshold transaction reports, A$10,000+ cash [UNVERIFIED: EFT TTR relief from the 2024 amendments — confirm current scope]), IFTI reports, ongoing CDD/EDD, annual industry contribution levy (small entities pay little-to-none; levy scales with revenue). [UNVERIFIED: exact levy amounts.]
• Registration is a reputation + program bar, not a capital bar: typical prep cost with consultants is A$20k–80k + 3–6 months. [UNVERIFIED: cost estimate is industry anecdote.]

2.4 Alternatives to a bank licence

1. Sponsor-bank / PayFac route: partner with an ADI or licensed PSP for user money flows; you never touch "deposits," the partner holds the banking relationship (this is how most AU fintechs operate).
2. Banking-as-a-Service partners (AU, 2026): Airwallex (AU-founded global payments/banking stack, AFSL-holder — natural for multi-currency accounts), Zepto (AU PayFac/payments infrastructure), Novatti (issuer-processor; also historically an AUSTRAC-registered digital-currency business and issuer of the AUDC AUD stablecoin on Stellar [UNVERIFIED: current AUDC status after Novatti's corporate changes]). Volt is dead (licence surrendered 2022). There is no AU-licensed "Solaris-style" full BaaS at scale; realistically you assemble ADI sponsor + PSP + issuer-processor. [UNVERIFIED: partner pricing and current product menus — talk to each.]
3. Stored-value/e-money: no general AU e-money licence exists; large PPFs fall to APRA (§2.2), payment products can trigger PSRA (payment systems regulation) / RBA access regimes, and non-cash payment products can trigger AFSL implications depending on structure. This is a lawyer question, not a build question.
4. Closed-loop loyalty/prepaid credit (no licence, within limits): prepayment for identified goods or services is carved out of "banking business" (the Banking Act carve-out quoted by APRA) and first-party credit falls outside the BNPL/LCCC definition (§1.2). Boundaries: no third-party redemption network, no interest, no external merchants paid on the consumer's behalf, fee caps if it ever looks like LCCC credit, and consumer-funds safeguarding/ASIC guidance on unclaimed money if balances persist. Verify the exact "prepaid services" exemption logic with counsel — this is the load-bearing wall of Phase 1.

2.5 ASIC / token mapping / crypto-ETF context

• Crypto ETFs have been admitted on ASX/CBOE since 2022 under existing AFSL/product-disclosure rules (INFO 225 framework). [UNVERIFIED beyond general knowledge — check ASIC's current crypto-ETP guidance page.]
• Treasury's token mapping consultation (2023) and the follow-up consultation on regulating digital asset (exchange/custody) platforms proposed an AFSL-based licensing regime for platforms dealing in tokenised financial products, plus requirements for stablecoin issuance and custody/safeguarding. As at research date I could not verify whether this legislation has passed; the RBA's Oct 2025 FSR explicitly contrasts Australia's still-developing approach with the US GENIUS Act (2025) and EU MiCA (in force). Treat "AU stablecoin/platform licensing law" as pending/uncertain — a live question for your lawyer.
• MiCA relevance if qalarc ever serves EU users: an AUD or multi-currency stablecoin would be an e-money token (EMT) requiring an e-money institution licence in an EU member state, full reserve backing, and redemption rights (per MiCA as summarised in RBA/ESMA materials).

3. Stablecoin / tokenised AUD — designing "qAUD" properly

3.1 Where Australia actually is (verified, 2026)

From the RBA's Tokenised Money hub and Project Acacia final report (published 2026; media release MR-26-13; speech After Acacia, 25 Mar 2026):

• The RBA classifies tokenised money into tokenised central bank reserves (wCBDC), retail CBDC, stablecoins, and tokenised deposits. A tokenised deposit is a digital claim on a commercial bank's balance sheet; a stablecoin is a private-sector token maintaining par via reserve assets.
• Retail CBDC: the RBA has determined there is "no public interest case" to issue one (position paper, Sep 2026). So no government-AUD token to plug into.
• Project Acacia conclusions: interoperable private tokenised money (stablecoins or tokenised bank deposits) can support tokenised asset markets; central bank money remains foundational; a digital financial market infrastructure (DFMI) sandbox and a tokenised government bond initiative are being explored; an industry Deposit Token Working Group has been extended and a Joint Regulator–Industry Tokenisation Advisory Group formed. Translation: the official direction of travel for wholesale AUD tokens is bank-issued deposit tokens, not startup stablecoins.
• Bank pilots: ANZ A$DC (2022) and NAB AUDN (2023) were permissioned, pilot-scale issuer-bank stablecoins/deposit tokens; neither is a public production product as at research date. [UNVERIFIED current status.] The most durable public AUD stablecoin effort has been Novatti's AUDC (Stellar) — also unverified in current form (§2.4).
• RBA FSR Oct 2025 (stablecoin focus topic): global stablecoins ≈ US$250b (Jun 2025), +50% y/y, dominated by Tether (US$162b) and USDC (US$61b); regulated under GENIUS (US) and MiCA (EU) elsewhere. Australia = watcher, not legislator (yet).

3.2 qAUD design specification (qalarc-owned claim vs partner-bank deposit token)

Two legal shapes, pick per phase:

Option A — "qAUD" as a claim on qalarc (private stablecoin shape). 1. Issuance: 1 qAUD minted only against cleared AUD received into a segregated reserve account; smart-contract (IOTA chain) mints to the depositor's qalarc wallet address. 2. Reserves: 100% AUD — held as deposits at an Australian ADI (in a segregated trust account in the name of the trustee for holders) plus, at scale, Commonwealth Government Securities / term deposits to earn modest carry. Never commingled with operating funds. 3. Segregation & bankruptcy-remoteness: a separate trustee company (or custody trust arrangement) holds reserves so that in qalarc's insolvency holders are creditors of the trust, not qalarc. (Mirrors the safeguarding logic in MiCA EMT rules and the Treasury custody proposals.) 4. Attestation: monthly third-party (registered company auditor) attestation of wallet + reserve balances, hash-published; real-time on-chain proof-of-reserves dashboard as a stretch goal. 5. Redemption: par redemption to AUD on demand (T+0 internal / T+1 bank), burn on withdrawal; redemption fee capped and disclosed. 6. Consistency rule: total minted − burned ≤ reserve balance, enforced by multi-sig mint/burn policy (see §4 ledger). 7. Legal risk: an auditable-claim-on-issuer token at par is exactly the instrument Treasury's proposed regime (and MiCA EMT rules) target; without a partner licence this should stay closed-loop (redeemable only inside qalarc apps) until Phase 2+.

Option B — qAUD as a partner-bank deposit token. The Acacia-endorsed path: an ADI partner issues tokenised deposits; qalarc operates the wallet/UX layer. No reserve risk on qalarc's balance sheet; you surrender issuance economics and need a bank willing to tokenize (Deposit Token Working Group members are the candidates). Realistically Phase 3+.

Phase-1 pragmatic shape: "qAUD" is not a token at all — it's an internal prepaid credit balance (A$-denominated units in the ledger), 1:1 with AUD paid in, spendable only on qalarc services. Same mint/burn ledger mechanics, zero transferability, no secondary trading. This keeps it inside the §2.4 closed-loop carve-out.

4. Qalx exchange — architecture blueprint (QALS/qAUD spot)

4.1 System shape

• Chain: IOTA-derived (feeless, DAG) with an EVM-compatible settlement layer for tooling; QALS and qAUD as native/Bridged tokens. All exchange operations happen inside qalarc's internal ledger, not on-chain — chain entries are the proof layer (mint/burn anchors), not the trading venue. (This is how every compliant AU exchange works: internal double-entry ledger + on-chain settlement at the edges.)
• Core: PostgreSQL-based double-entry ledger — every user balance is a liability account; every asset (AUD due from bank, QALS inventory, stablecoin reserve) is an asset account; no balance update without a balanced journal entry (sum of debits = sum of credits); immutable, append-only journal with daily hash anchored on-chain (cheap integrity proof).
• Matching engine: central-limit-order-book (e.g. open-source core or OAX/LGO-style engines, or build: in-memory price-time-priority CLOB with ~10k+ TPS headroom) for QALS/qAUD and (Phase 2+) BTC/ETH/AUD pairs. Settlement is atomic within the internal ledger; trade = two journal entries + one clearing entry.
• Mint/burn on deposit/withdrawal: AUD deposit (PayID/Bank transfer via PSP) → credit user AUD liability + bank asset → user converts to qAUD → debit AUD liability / credit qAUD liability + reserve asset, mint on-chain to user's custodied address (or keep internally-custodied in Phase 1). Withdrawal burns. On-chain transfers between users disabled until AUSTRAC registration + transfer-of-value legal sign-off (transfers create remittance/AML exposure).
• Custody: Option 1 (recommended Phase 2): Fireblocks MPC custody/policy engine (coverage for IOTA-class assets [UNVERIFIED — confirm IOTA support directly]). Option 2 (self-hosted, open-source): IOTA Stronghold (iotaledger/stronghold.rs) — open-source secure enclave/secret-management for key shards; combine with HSMs and 2-of-3 geographically split key ceremonies. Hot wallet ≤ ~5% of assets; warm/cold split with time-locks and quorum withdrawal policy; proof-of-solvency (Merkle-sum tree of user liabilities vs controlled assets) published monthly.
• KYC/AML stack: FrankieOne (AU-founded KYC/AML orchestration used by AU banks — natural fit, handles ID doc + biometrics + PEP/sanctions + adverse media), or Sumsub / Persona for lighter-weight flows. Tiered limits: Tier 1 (email + basic ID) low caps; Tier 2 (full KYC) higher; source-of-funds above threshold. [UNVERIFIED: per-verification pricing — typically A$1–4/verification at volume; get quotes.]
• Price oracle: volume-weighted composite of 2–3 external venues (Coinbase/Kraken/Binance) + Chainlink-style feeds where available for majors; for QALS/qAUD the exchange's own book is the primary source with circuit-breakers on >10% 1-minute moves.
• Market-making basics: qalarc runs (or contracts) a market maker quoting QALS/qAUD with fixed spread + inventory caps; MM operates on the internal ledger like any user but under a written agreement excluding it from wash-trade logic; avoid qalarc trading against customers with undisclosed material info — document everything (this is an ASIC-conduct issue even pre-licensing).
• AUSTRAC reporting: SMRs within deadline on suspicion; TTRs for A$10k+ cash (EFT scope per current rules [UNVERIFIED]); IFTIs for international transfers; enrolment + VASP registration before first trade (§2.3).

4.2 What must NOT ship in Phase 1

On-chain transferability of value between users, fiat on/off ramps for third parties, listing tokens qalarc doesn't own, margin/leverage, or paying external merchants. Each flips a regulatory switch (remittance, VASP, AFSL/market conduct, credit).

5. Synthesis — 3-phase compliance-lite roadmap

Phase 1 — Closed-loop credit (QALS as prepaid compute credit)

Time: 0–3 months · Cost: <$50k (mostly legal review) - QALS sold for AUD as prepayment for identified qalarc services (compute/AI credits, subscriptions, marketplace fees) — anchored to the Banking Act carve-out ("deposits other than as part-payment for identified goods or services" are what triggers ADI law — prepayment for services is the carve-out) and the first-party-credit carve-out from BNPL/LCCC (§1.2). - Non-transferable, non-redeemable for cash (or redeemable only within a short statutory-style window with fee disclosure — counsel call), A$-priced internally (the "qAUD-as-ledger-units" shape, §3.2). - Zip-copyable elements only: prepaid balance UX, instalment display on prepaid balances, internal scoring for service limits (not credit). - Required: T&Cs drafted by fintech counsel; consumer-guarantee (ACL) compliance; privacy act handling; no "bank/credit" language; consider gift-card/unclaimed-money rules for long-dormant balances.

Phase 2 — AUSTRAC VASP registration + Qalx spot + partner rails

Time: 3–9 months · Cost: A$150k–400k (program build, consultants, audit, legal, vendor fees) - Build AML/CTF program to the AUSTRAC VASP registration questionnaire spec (§2.3 — we have the full question list), enrol, register, then open Qalx with qAUD/QALS pair(s). - Fiat rails via sponsor bank/PSP (Airwallex/Zepto-class partner); reserves per §3.2 Option A with auditor attestation. - Custody via Fireblocks or Stronghold-based self-custody; KYC via FrankieOne; ledger per §4.1. - Watch the pending Treasury digital-asset-platform/stablecoin legislation (§2.5) — if it passes, budget an AFSL-variation or licensing project (~A$100–300k, 6–12 months [UNVERIFIED estimate]).

Phase 3 — Licensed credit (Zip-style) and/or tokenised-deposit banking rails

Time: 12–36 months · Cost: A$300k–1m+ (ACL + credit ops) or A$30m+ (ADI/RADI) - Path A (recommended): ACL with LCCC authorisation. Apply for an ACL authorising credit provision; comply with modified RLOs (bureau pull, income/expenditure, ≤A$2k presumption, 120-day window, written policy); fee caps A$200/125 + A$120–320 default; AFCA membership. Enables "pay with QALS-credit" instalments across qalarc's own apps first (first-party credit is LCCC-exempt, but you'll want the ACL the moment you pay third-party merchants). Fund receivables balance-sheet-first, warehouse later (Zip model §1.2). - Path B (aspirational): RADI → ADI. Only if the vision is genuine deposit-taking "bank" rails for the app ecosystem. RADI caps at 2 years limited operations; capital realistically A$50m+ raised, 2–4 years to full licence (§2.1). A lighter variant: partner-bank deposit token (§3.2 Option B) riding the Acacia/Deposit Token Working Group direction — get AUD deposit tokens from an ADI partner and distribute them, achieving "bank-grade qAUD" without APRA licensing yourself.

Key legal questions for the fintech lawyer (take this list)

1. Does the Phase-1 prepaid QALS construct stay outside "banking business" (Banking Act Part 5) and outside LCCC/credit regulation at every edge case (refunds, expiry, gifting, business users)?
2. Where exactly does a non-transferable A$-denominated credit balance become a "stored value facility"/PPF requiring APRA authorisation, and does limiting redemption to qalarc services avoid it?
3. Is qAUD (Option A) a "financial product" under Ch 7 Corporations Act (managed investment/debt product risk) — and what changes when Treasury's digital-asset platform/stablecoin bill passes?
4. Which AUSTRAC designated services does each Qalx feature trigger (exchange, transfer, custody), and does internal-only (no external transfers) reduce Phase 2 scope?
5. LCCC structuring: can QALS-denominated instalments (variable AUD value) satisfy LCCC fee caps and modified RLOs, or must credit be AUD-denominated with QALS as rewards only? (FX-like denomination of consumer credit is a novel question — get a written opinion.)
6. Safeguarding: trust structure for qAUD reserves + customer crypto (segregation, insolvency remoteness, auditor attestation scope).
7. Tax: GST treatment of QALS sales (gift-card-style until redemption?), CGT on qAUD conversion events, and the ATO's view of tokenised AUD as foreign currency vs CGT asset.
8. Marketing/restricted words: permissible use of "bank-like", "exchange", "credit" language pre-licence.

Sources (primary, retrieved 6 Sep 2026)

• Zip Co — Investor Relations (FY26 scorecard): https://zip.co/investors
• Hall & Wilcox — Buy-now pay-later reform: what you need to know (14 Feb 2025; LCCC/ACL/RLO mechanics, fee caps, third-party-provider carve-out): https://hallandwilcox.com.au/news/buy-now-pay-later-reform-what-you-need-to-know/
• Moneysmart (ASIC) — Buy now pay later services (updated 14 Jul 2026): https://moneysmart.gov.au/other-ways-to-borrow/buy-now-pay-later-services
• APRA — Licensing guidelines for ADIs (direct/restricted pathways, Banking Act Part 5, PPFs, restricted words): https://www.apra.gov.au/banking/licensing-guidelines-authorised-deposit-taking-institutions
• AUSTRAC — Registration questions for virtual asset service provider (13 May 2026): https://www.austrac.gov.au/new-austrac/register-us/registration-questions-virtual-asset-service-provider
• AUSTRAC — Virtual asset service providers industry hub: https://www.austrac.gov.au/industry-and-business/your-industry/virtual-asset-service-providers
• AUSTRAC — Virtual asset designated services (AML/CTF reforms): https://www.austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/virtual-asset-designated-services
• RBA — About Tokenised Money (four-type taxonomy; retail-CBDC "no public interest case" position paper Sep 2026; Deposit Token Working Group): https://www.rba.gov.au/payments-and-infrastructure/tokenised-money/about.html
• RBA — Project Acacia (final report & conclusions; DFMI sandbox; wCBDC): https://www.rba.gov.au/payments-and-infrastructure/tokenised-money/project-acacia/
• RBA — FSR Oct 2025 Focus Topic Recent Trends in Stablecoins… (US$250b market; GENIUS Act; MiCA): https://www.rba.gov.au/publications/fsr/2025/oct/focus-topic-recent-trends-in-stablecoins-and-considerations-for-financial-stability.html

Deliberately [UNVERIFIED] at research time: Zip's current AU fee schedule/warehouse lenders; AU stablecoin/bank-pilot production status (ANZ A$DC, NAB AUDN, Novatti AUDC); passage of Treasury's digital-asset-platform/stablecoin legislation; AUSTRAC levy amounts and EFT-TTR scope; vendor pricing (Fireblocks, FrankieOne, Sumsub); recent ADI applicant pipeline.