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ARTICLE · 01 DECEMBER 2025

Fourth Time Lucky? The Fourth FFSP AFSL Bill Is Introduced To Parliament

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

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On 26 November 2025, Parliament introduced a new bill to enact new foreign financial service provider (FFSP) exemptions to the need to hold an Australian financial services licence (or AFSL).

AustraliaFinance and Banking
Fiona Smedley
Fiona Smedley
Adam Hickey
Adam Hickey
Jack Zhou
Jack Zhou
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On 26 November 2025, Parliament introduced a new bill to enact new foreign financial service provider (FFSP) exemptions to the need to hold an Australian financial services licence (or AFSL).

Background

  • The passporting exemptions and limited connection exemption which operate to exempt foreign financial services providers (FFSPs) from the need to hold an Australian financial services licence (AFSL) when providing financial services to wholesale clients in Australia and are due to expire on 31 March 2026 (see our earlier article of 31 July 2024).
  • In 2022 the Government had proposed a bill to introduce legislation to replace the passporting exemptions and limited connection exemption with new FFSP exemptions called the 'comparable regulator exemption' and the 'professional investor exemption'.

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