On 5 December 2025, ASIC has again extended the transitional relief for foreign financial services providers (FFSPs) for an additional 12 months (until 31 March 2027).

A person who carries on a financial services business in Australia must hold an Australian financial services licence (AFSL) covering the provision of the financial services (Corporations Act 2001 (Cth) (Corporations Act)).  The new relief instruments released on 5 December 2025 exempt FFSPs from the requirement to hold an AFSL when providing financial services to Australian wholesale clients.

These transitional measures reflect that the Federal Parliament has not yet legislated formal FFSP exemptions into the Corporations Act (though this appears to be getting closer!).  On 26 November 2025, the Federal Parliament introduced the Treasury Laws Amendment (Genetic Testing Protections in Life Insurance and Other Measures) Bill 2025 (the Bill).  Schedule 2 to the Bill establishes three exemptions in the Corporations Act from the requirement to hold an AFS licence. and we have previously written about the three new exemptions created by the Bill on our blog here.

Please reach out to us if you would like further information on this transitional relief or the reforms proposed by the Bill and how these changes may impact your current or future business operations in Australia.