In January 2021, we welcomed the opportunity to respond to Treasury’s Consultation, the Review of the Australian Payments System. A summary of our submission follows.
Australia has a world-class payments system, and its regulatory architecture has largely stood the test of time. We are at an inflection point where payments, traditionally the purview of banks, has been transformed by technology, the associated proliferation of data, new participants and business models, and customer expectation to service the digital economy.
Alongside this, a range of industries, not just financial services, are thinking differently about payments, data, and more broadly what constitutes the transfer of value. As the participants, products and services evolve, it is appropriate to consider whether the current regulatory architecture is well suited to the new paradigm, given its dominant focus on financial stability and prudential oversight.
The challenge for regulation is to provide a level playing field in which new business models can flourish, while providing appropriate protection for, and maximising benefits to, customers. The needs of the digital economy will be well serviced by a regulatory architecture that is based on greater clarity, coordination, and self-regulation; this can be achieved by:
The full submission (including Appendix 1 and 2) is available below.