ASIC publishes updated INFO 225

In October 2025, ASIC issued its much-anticipated revised version of Information Sheet INFO 225, reflecting developments in the digital financial assets sector and clarifying how regulatory obligations apply.

This Gen Advisory article summarises the revised INFO 225's key features and implications for digital financial asset services providers in Australia.

Background

• ASIC has updated Information Sheet 225: Digital assets: Financial products and services (“INFO 225”), providing clarification on how the existing financial services regulatory framework applies to digital financial assets The updated guidance provides examples of circumstances under which a digital product or service is likely to be captured, or not captured, as a regulated financial product.

  
  

• The update was released alongside a class no-action letter, applicable until 30 June 2026, to give digital asset businesses time to transition to or obtain appropriate AFS licensing.

  
  

• INFO 225 does not introduce new law. Instead, INFO 225 confirms ASIC's position that many digital assets are financial products under the existing financial services regime.

INFO 225 (October 2025 version) - Some key insights

1. Broader terminology: The sheet now uses “digital assets” instead of “crypto-assets,” encompassing not just cryptocurrencies but also tokenised real-world assets, stablecoins, wrapped tokens, wallets and others.

   
   

2. Expanded worked examples: INFO 225 now contains 18 worked examples (as compared to 13 in the Oct 2024 draft Consultation Paper version), covering the following areas:

   
   

 1. Exchange in-house tokens;

2. Gaming non-fungible tokens

3. Basic proof-of-stake systems 4. Managed staking and staking as a service

5. Bitcoin

6. Yield-bearing stablecoins

7. Gold-linked tokens

8. Membership non-fungible tokens

9. Tokenised real estate

10. Prepaid services

11. Blockchain launch

12.Meme coins

13. Tokenised concert tickets

14. Tokenised bonds

15. Traditional derivatives

16. Wrapped tokens

17. Digital asset wallets

18. Non-interest bearing stablecoins

3. Detailed classification guidance: Within each of the above topics areas, INFO 225 provides detailed guidance - including practical scenarios and "counterfactuals" - on whether a digitial asset (or product involving a digital) is likely or unlikely to fall within one of the below five classifications.

(i) a facility for making an investment;

(ii) an interest in a managed investment scheme; (iii) a security (e.g. shares or debentures);

(iv) a derivative;

(v) a non-cash payment (NCP) facility.

Note: Although many digital asset offerings do not fit neatly within the above "financial services / products" regulatory definitions – ASIC’s guidance provides useful clarity.

4. Bitcoin not a financial product: The updated INFO 225 confirms that Bitcoin is unlikely to be regarded as a financial product. This is consistent with Treasury’s position.

   
   

5. Clearer obligations for service providers: The update highlights how existing licensing obligations (e.g. the need for an AFSL) and regulatory duties apply to digital-asset services, including custody, disclosure, design and distribution obligations.

6. Regulatory relief and transitional arrangements: Recognising that many digital-asset businesses may suddenly find themselves unlicensed under the new interpretation, ASIC has issued a sector-wide “no-action” position (i.e., temporary regulatory relief) to allow businesses to apply for an AFSL or meet other obligations.

Changes ahead

The guidance arrives as the Australian government advances its own Digital Assets Platform (DAP) and Tokenised Custody Platform (TCP) legislation, expected to introduce a formal licensing regime for exchanges and custodians later this year. 

ASIC has advised that its framework will evolve alongside those Treasury reforms, but that entities should already be preparing to comply with existing obligations.

Implications for digital asset businesses

For digital asset businesses, now is the time to review whether your activities are captured under the updated AFSL framework and prepare ahead of the 30 June 2026 transition deadline.

Businesses which fail to lodge an AFSL application with ASIC by 30 June 2026 will need to cease providing any financial services relating to digital assets.

If you're a digital asset business and wish to discuss how the updated INFO 225 impacts you, please reach out to the Gen Advisory team.

Note: This article is of a general nature and not intended to address the objectives, financial situation or needs of any particular individual or entity. It is provided for information purposes only and does not constitute professional or legal advice.

Should you have any questions regarding this article, please get in touch with the Gen Advisory team.