Why Digital-Asset Rules Matter for All Funds

A new draft Bill is pushing Australia’s regulatory frontier into what was once niche territory: digital-asset platforms and tokenised-custody services.

While that may sound distant from the broader investment landscape, the standards it introduces could become a blueprint for how all fund operations are expected to demonstrate control, transparency and accountability.

In other words, these reforms aren’t just about digital assets. They are a preview of what is coming for the entire financial ecosystem.

Understanding the new framework

The Treasury’s Digital Asset and Tokenised Custody Bill 2025 proposes to bring digital-asset and tokenised-custody operators under the Australian Financial Services Licence regime.

The Bill aims to close the gap between how traditional custodians are supervised and how digital-asset businesses currently operate.

It would extend to any entity with possession, custody or control of digital assets, whether for its own investors or on behalf of others. Those within scope would be required to meet AFSL obligations for conduct, governance, capital adequacy and reporting.

As noted in a submission by professional services firm KPMG, the approach reflects a move toward “functional regulation,” a model that focuses on what a business does, rather than the form its assets take. It’s a principle already influencing how regulators assess a broader range of financial services activities.

A wider signal for governance

Seen through a wider lens, the proposed framework marks another step in the convergence between technology, custody and regulation.

As operations become more digital, every part of the fund ecosystem, from registry to reporting, increasingly runs like a platform.

For a large proportion of wholesale funds, digital assets may sit outside their mandate. Yet the principles driving these reforms are becoming universal: clarity of control, verifiable data flows and accountability built into every process.

The World Economic Forum’s Digital Assets Regulation report highlights the same global trajectory. Whether assets are tokenised or traditional, regulators around the world are setting expectations for traceability, operational resilience and real-time oversight.

From platforms to operations

Even outside the digital-asset space, fund operations now depend on platform-style infrastructure.

Investor portals, onboarding engines, registry systems and compliance tools form the backbone of how funds interact with investors and regulators.

At Wicklow, we implement and oversee these operational systems for wholesale managers. Our focus is not only on efficiency, but on ensuring that each function - registry, onboarding, AML/CTF, and compliance monitoring - reflects the same governance principles regulators are now codifying for digital platforms: defined control, transparent data lineage and active accountability.

This is what we call governance as infrastructure: systems designed not just to execute, but to explain.

Interpreting the shift

Viewed strategically, these changes do more than extend regulation to a new sector. They show how policymakers are defining frameworks that expect systems to demonstrate control and traceability in real time.

For wholesale operators, the implications are practical. The same standards that now apply to digital-asset platforms are filtering through to traditional funds, service providers and custodians.

The reforms go further than many realise, introducing standards that, while designed for digital-asset custody, are likely to become benchmarks across the broader funds industry.

• Functional regulation: obligations based on what you do, not what you are, a model that could equally apply to registry or onboarding providers performing critical custody functions.

• Demonstrable control: a shift from written policies to auditable evidence of who held, moved or authorised assets, pointing toward traceable registry data and transparent operational logs.

• Operational resilience: requirements for system segregation, continuity and recovery, setting a precedent for stronger technology and data-governance standards across fund infrastructure.

• Continuous oversight: expectations of live visibility and monitoring, rather than periodic reporting, echoing the regulatory move toward real-time assurance.

• Defined accountability: explicit governance maps showing who is responsible for each layer of custody and control, a level of clarity still emerging across traditional fund structures.

Together, these elements mark a shift from compliance as declaration to compliance as demonstration; a change that will influence not just digital-asset platforms, but every participant in the investment ecosystem.

The future of governance is visible

Wicklow’s work has always centred on building systems that make governance visible and measurable.

Our registry, onboarding and compliance solutions are designed not only to perform but to show, with data, traceability and real-time accountability.

As the line between regulation and technology continues to blur, the ability to evidence governance will define operational credibility.

For fund managers, that means building systems that can demonstrate integrity, not just assert it.

Governance has always underpinned trust. What’s emerging now is a new expectation: that it can be proven as clearly as it’s performed.