ASIC releases updated INFO 225

ASIC has released its updated INFO 225, clarifying how existing financial services laws apply to digital assets.

[30 October 2025]: ASIC released yesterday its updated Info Sheet "Digital assets: Financial products and services" ("INFO 225"), clarifying how existing financial services laws apply to digital assets and announcing a no-action position until 30 June 2026.

The guidance includes 18 worked examples and new expectations for advisors, responsible managers and product issuers.

Key insights

Some key insights from the updated INFO 225:

• The finalised guidance builds on ASIC’s December 2024 consultation, expanding from 13 to 18 worked examples and introducing new sections on custody, fund management, and transitional relief.

  
  

• The latest update replaces earlier “crypto-asset” terminology with the broader term “digital assets,” intended to capture virtual, tokenised, and coin-based products without exclusion.

  
  

• While the guidance does not create new law, ASIC said it aims to give businesses greater certainty ahead of Treasury’s planned Digital Asset Platforms (DAP) and Payment Service Providers (PSP) bills, which will introduce formal licensing for exchanges, custody platforms, and certain stablecoin issuers. 

  
  

• The regulator also reiterated that many digital assets, including yield-bearing tokens, staking programs, and asset-referenced stablecoins, will likely require an Australian Financial Services License (AFSL) under current law.

• The updated INFO 225 confirms ASIC's position that bitcoin is not a financial product.

Changes ahead

The guidance arrives as the Australian government advances its own digital-asset-platform 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 n 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 2026 transition.

If you're a digital asset business and wish to discuss how the updated INFO 225 impacts you, please get in touch with 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 contact with the Gen Advisory team.