Law Council of Australia

Business Law Section

Regulation of Payment Service Providers—Tranche 1a draft legislation

Submission Date: 6 November 2025

This submission is made by the Financial Services Committee of the Business Law Section of the Law Council of Australia (the Committee) and relates to the exposure draft legislation, explanatory materials and factsheet concerning Tranche 1a of proposed legislation with respect to the regulation of payment service providers (Tranche 1a Materials).

Background

Treasury released the Tranche 1a Materials for public consultation on 9 October 2025. The Committee understands that the Tranche 1a Materials form part of 2 sub-tranches of legislation with respect to payments licensing reforms. There will be a Tranche 1b and the relevant Tranche 1b exposure draft legislation and related materials are anticipated to be released for consultation in late 2025 (as was proposed in an industry roundtable in October 2025) or in 2026. It is proposed that Tranches 1a and 1b (and subsequent tranches) will subsequently be introduced to Parliament in a single Bill at some time in 2026 (and other amendments, including to the ePayments Code, proposed in a similar timeframe).

The Tranche 1a Materials cover core concepts and licensing obligations for payment service providers. Tranche 1b is expected to contain further licensing obligations (such as safeguarding payment-related money), exemptions and exclusions, APRA powers, a framework for unclaimed monies, a rule-making power for a mandatory ePayments code and transitional arrangements.

Last Updated on 07/11/2025

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