Research & Insights
Background reading that doesn't belong on a homepage. Take as much or as little as you like — none of it is required before a session, and none of it is advice.
The Receipts · a full edition
This is an entire edition, published here rather than described, so you can judge the research before you give us an email address. Every document named is public and free. None of this is advice.
The claim
“ASIC sets AU$14 million capital rule for crypto exchanges holding user assets. Platforms that hold customer assets directly must maintain AU$14 million in net tangible assets.”
Reported 16 October 2026
One number, in a dozen places, inside seventy-two hours. Australian platforms that hold your coins need fourteen million dollars, and the small ones are finished.
It is a real number, in a real ASIC document, published the day before. We opened the document anyway.
The document
ASIC Consultation Paper 392 — Digital asset law reform implementation: proposed standards and guidance, published 15 October 2026, announced the same day in media release 26-245MR. Submissions close 5pm AEDT on 27 November 2026.
The figure is in Proposal D3, Table 7 — the net tangible assets requirement for digital asset platform operators. ASIC wrote that table three times, because it is proposing three different models.
| If third-party custody conditions are met | The requirement |
|---|---|
| All three models | the greatest of $200,000, or 0.5% of average underlying asset value up to $7,000,000, or 10% of average revenue |
| If they are not met | |
| Model 1 | the greater of $14,000,000 or 10% of average revenue |
| Model 2 | the greater of $7,000,000 or 10% of average revenue where the operator never holds an underlying asset that is a financial product; otherwise the greater of $14,000,000 or 10% of average revenue |
| Model 3 | the greatest of $2,000,000, or 0.5% of average underlying asset value up to $14,000,000, or 10% of average revenue — plus $500,000, $750,000 or $1,000,000 depending on activity |
Indexed annually to CPI.
Do they match
Partly — and the parts that don't are the parts that matter. This is not a fabrication. Several outlets reported the $200,000 alternative and said the figures were proposed. It is something harder to catch: a document that was read, and then flattened. Three joins.
The paper's own words: “We are consulting on three alternative approaches to the NTA requirement.” Seven questions are attached, D3Q1 to D3Q7. D3Q2 asks which model best supports the objectives. D3Q4 asks whether the amounts are appropriate. The note under Proposal D2 says it outright: “The draft financial requirements instrument will change following consultation feedback.”
Against that: “ASIC sets”, “must maintain”, present tense, no condition. A regulator asking the industry which of three numbers to pick has not picked one.
The coverage carried a two-row table: holds assets directly, $14 million; uses a qualified custodian, $200,000. That is Model 1, presented as the regime.
Model 2 never appears — it has a $7,000,000 tier with no row to sit in. Nor does Model 3, where the base is $2,000,000 and the $14 million figure is a cap on a percentage, not a floor: “0.5% of average underlying asset value up to $14,000,000.”
Same digits, reversed function. A platform's exposure differs by an order of magnitude depending on which model ASIC lands on — which is precisely what D3Q2 is asking the industry.
The test is net tangible assets: assets less liabilities less intangibles, on the balance sheet. Not money raised, not cash in the bank, not a bond lodged with ASIC.
And every limb reads “the greater of”. Ten per cent of average revenue sits beside the fixed figure in all three models, so for a large enough platform the requirement lands above $14 million. “Bar” and “cap” both have it backwards.
The part nobody reported
Everyone treated the $200,000 as the discount for using a custodian. Paragraph 130 says what it costs: written assurance from the custodian and, with limited exceptions, audit reports attesting that the custodian holds the net tangible assets the operator would otherwise have needed.
The obligation doesn't shrink. It moves — onto whoever holds the keys. That is the actual design, it is the real answer to “does this kill the small platforms”, and it was sitting in paragraph 130 of a document anybody can download for nothing.
And one we could not close
Something we weren't looking for. ASIC has published two different commencement dates for its own Act. Its implementation roadmap of 20 April 2026 says the Digital Assets Framework Act “will commence on 9 April 2027”. CP 392, published 15 October 2026, says “The DAF Act commences on 8 April 2027”.
We could not open section 2 of the Act itself — the register pages we reached give the assent date and no commencement table. So we are not telling you which date is right. We are telling you the regulator has published both, and that answering it properly needs section 2 of Act No. 38 of 2026 read directly.
That isn't a gotcha. Government documents are written by people under deadlines. The point is narrower and more useful: if a date matters to you, one source is not enough — even when the source is the regulator, and even when the regulator wrote the Act.
Nothing here was invented. $14,000,000 is in Table 7 of a real ASIC paper. Everything that made the claim wrong was a condition dropped on the way to the headline — a consultation became a rule, three models became one table, a revenue escalator vanished, and a ceiling was reported as a floor.
Ask it of anything, including us: what is the document, and what did it say on either side of the number?
Opened for this edition: ASIC, CP 392, 15 October 2026 (Proposal D1; Proposal D2 note; Proposal D3 and Table 7; paragraph 130; questions D3Q1–D3Q7) · ASIC media release 26-245MR, 15 October 2026 · ASIC, Roadmap for digital assets law reform implementation, 20 April 2026 · Federal Register of Legislation, Corporations Amendment (Digital Assets Framework) Act 2026, No. 38, 2026 — assent and registration details only, section 2 not retrieved. Headlines are cited as examples of the claim in circulation, not as sources for anything.
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