Safeheld
    Sign inBook a demo

    Australia. Client money, held in trust.

    Australian financial services licensees, including issuers of non-cash payment facilities, are licensed and supervised by ASIC under the Corporations Act 2001.

    Book a demoSee the platform
    Rules applied
    Client money, Corporations Act s.981B, with s.1017E shown.
    Reports prepared
    FS71 auditor's report, Part 2, with a client money schedule for the auditor.
    Checked
    Every business day, for each licensee, in Australian dollars.

    What ASIC expects.

    Client money in a designated trust account with an ADI by the next business day, and an auditor's opinion on those accounts every year.

    Client money

    AFS licensees that receive client money in connection with a financial service. Supervised by Australian Securities and Investments Commission.

    Corporations Act 2001 ss.981A, 981B, 989B, 1017E; Corporations Regulations 7.8.01
    RequirementWhat the rule saysReference
    WhereA designated trust account with an Australian ADI, holding only client money.s.981B; reg. 7.8.01
    By whenNo later than the next business day after receipt.s.981B
    Stored valueMoney paid to acquire the licensee's own non-cash payment facility by way of issue is not client money.s.981A(2)(c)
    Money before issueMoney received for a product not yet issued goes to an ADI account on the day or next business day, held on trust.s.1017E
    Annual auditThe auditor gives an opinion on the internal controls and the accounts operated under s.981B.s.989B; FS71 Part 2

    How Safeheld applies it. The s.1017E duty is shown to the firm and not tested separately. Proposed payment service provider reforms are not law and are not applied.

    Returns and reports.

    What is filed, when and where, and exactly what Safeheld produces for it.

    FS70 and FS71ASIC
    How often
    Annual
    Due
    Four months after year end, three for a disclosing entity
    Filed through
    ASIC Regulatory Portal, lodged together
    Completion workbook

    The FS71 licensee details and a client money schedule the auditor tests for Part 2: accounts, reconciliations, shortfall days, the largest shortfall, client money at year end and breaks.

    The financial statements in FS70 and the signed auditor's report come from the licensee and its auditor. Every report is reviewed and approved by your team before it is filed.

    Every day

    What Safeheld runs for Australia.

    Reconcile. Every trust account matched to the client ledger each business day, in Australian dollars.
    Investigate. Receipts not in trust by the next business day raised as breaks, with the cause recorded.
    Forecast. Funding needs for the next 24 hours, 7 and 30 days.
    Act. Transfers into trust proposed and approved within limits.
    Report. The client money schedule for the FS71 audit, and read-only access for the auditor.
    Nexus Payments Pty LtdAUD, 30 Sep 2026, close of businessMeets
    Owed to customersA$4,118,400.00
    Counted under the rulesA$4,160,250.00
    ExcessA$41,850.00
    Rules
    Client money in trusts.981BMeets
    Money before issues.1017EMeets
    Money before issue is shown to the firm and checked by it.

    Questions.

    Is stored value on our own facility client money?

    No. Money paid to acquire the licensee's own non-cash payment facility by way of issue is excluded by s.981A(2)(c). It is left out of the requirement, and s.1017E may still apply before issue.

    What does the auditor need from us?

    An opinion on the internal controls and the accounts kept under s.981B, given in Part 2 of FS71. Safeheld prepares the client money schedule the auditor tests.

    Do the proposed payments licensing reforms apply?

    Not yet. They are not law. When they are enacted, the new safeguarding rules are added as a new rule version from their effective date.

    How are trust accounts reconciled?

    Every business day, against the client ledger, for each licensee, with any receipt not in trust by the next business day raised as a break.

    Customer money in Australia, accounted for every day.

    Book a demoAll jurisdictions