Submissions

We help policymakers and regulators understand the needs of an efficient payments system.

  • Inquiry into Future Directions for the Consumer Data Right

    In May 2020, AusPayNet welcomed the opportunity to respond to Treasury's Consultation, Inquiry into Future Directions for the Consumer Data Right.

    Our submission highlighted the prerequisites for a successful data economy: an effective and robust governance framework and customer identification and verification.

    This model has been tried and tested over time, as payments technology and consumer preferences have changed, and continue to change. Utilising this experience and leveraging existing regulatory processes and procedures, not only provide useful learnings and insights, but could be a more cost-efficient way of delivering a world class data economy for Australia.

    The full submission is available below.

     
  • Review of Retail Payments Regulation

    In January 2020, AusPayNet was pleased to provide a response to the Reserve Bank of Australia Issues Paper, Review of Retail Payments Regulation.

    AusPayNet’s submission provided both general comments about self-regulation as well as answers to specific questions outlined in the review. Key points outlined in our submission included:

    • Market forces and technological change are underpinning a wave of innovation in the payments industry and offering new ways for consumers and business to pay and accept payments;
    • Self-regulation is working effectively to identify and solve potential challenges over the medium-to-longer term;
    • As the self-regulatory body for the Australian payments system, AusPayNet is continuously reviewing and improving on this model to ensure it evolves to meet the needs of the rapidly change payments landscape;
    • Existing government initiatives (such as the consumer data right and CFR review of stored-value facilities) will complement industry initiatives in helping to provide a foundation for future innovation

    AusPayNet welcomes the opportunity to continue to work with the RBA on this ongoing review. In particular, we will continue to update the RBA on the progress and outcomes of our own Future State of Payments consultation. AusPayNet's submission can be accessed below.

  • FinTech and RegTech

    In December 2019, we responded to the Issues Paper published by the Senate Select Committee on Financial Technology and Regulatory Technology. 

    AusPayNet’s submission provides an overview of the Australian payments system, the changes to the ways we pay, and highlights some of our work to support fintechs. This includes:

    • better understanding fintech requirements of the Australian payment system; and
    • creating a pilot and approval process for non-standard payment devices for use in the Australian market, where there is no international standard for device security assessment.

    AusPayNet’s submission is available below. 

    On 19 February 2020, our CEO Andy White, took part in the Public Hearing held by the Committee in Sydney. His Opening Statement is also available below.

    Chaired by Senator Andrew Bragg, the Committee will present its final report in October 2020. The Committee’s Issues Paper is available here

     

  • AI, Australia’s Ethics Framework

    In May 2019, we were pleased to make a submission to the Data61 consultation, Artificial Intelligence (AI), Australia’s Ethics Framework.

    Data61 sought feedback on the proposed Australian Ethics Framework, designed to help ensure AI is developed and applied responsibly in Australia.

    Our submission highlights AI as key pillar of innovation for the payments industry and sees the discussion paper as a useful starting point. Two current AI use cases are applicable to the payments industry: authentication practices; and automated decisions based on payment data. AusPayNet’s response seeks to clarify the scope of the framework, clearly articulate consumer benefits and ensure the transparency and accountability of any AI system. Our submission further highlights the need for payment networks to ensure the highest level of security due to the sensitivity of information being transmitted, a practice which must be continued with the application of AI and machine learning.

    AusPayNet will work through our comments with Data61, providing input into the next version of the Ethics Framework.

    Access our Submission below.

  • Review of Retail Payments Regulation: Stored-value Facilities

    In October 2018, we responded to the Council of Financial Regulators’ (CFR) Issues Paper, Review of Retail Payments Regulation: Stored-value Facilities.

    Key objectives for the review included identifying opportunities to simplify the regulatory framework for stored value facilities (SVFs) – currently known as purchased payment facilities or PPFs – and ensure that regulation does not pose an undue obstacle to innovation and competition.

    This was a recommendation of both the 2014 Financial Systems Inquiry and the 2018 Productivity Commission inquiry, Competition in the Australian Financial System.
     
    Our submission noted that, based on the Australian consumer trend towards uptake of digital payments and fintech solutions, SVFs could become ubiquitous and have a variety of purposes. AusPayNet suggested that the CFR should explore a graduated regulatory framework for SVFs that offers temporary relaxation of requirements for new entrants within a restricted environment, for testing purposes.

    Based on the consultation, the CFR will develop recommendations in early 2019.

  • Introducing an Economy-Wide Cash Payment Limit

    In June 2018, we provided a submission to the Black Economy Taskforce's recommendation to implement an economy-wide cash payment limit of $10,000.

    One of the recommendations from the Black Economy Taskforce (BET) is the introduction of an economy-wide cash payment limit of $10,000 made to businesses for goods or services from 1 July 2019.  

    The government in its response to the BET report agreed. On 25 May 2018, Treasury released a consultation to seek stakeholder feedback on implementation issues resulting from such a limit.
     
    Our submission along with the Treasury consultation paper is available for access below.

  • Competition in the Australian Financial System - Draft Report

    On 7 February 2018, the Productivity Commission (PC) released its Draft Report into Competition in the Australian Financial System. Further submissions were sought by 20 March 2018.
     
    The Draft Report included several draft recommendations impacting the Australian payments system. AusPayNet’s submission focused on these issues including merchant routing, interchange fees, and the ePayments Code. Our submission to the Draft Report can be accessed at the link below.
     
    The Final Report is due to Government by 1 July 2018 and is expected to be released later this year. 

    The Draft Report builds on an earlier consultation paper, released in July 2017. Our submission to the initial consultation paper can be accessed here.

  • Digital Economy Strategy

    'The Digital Economy: Opening up the conversation'

    In September 2017, the Australian Government announced a consultation to inform the development of its Digital Economy Strategy.

    The consultation had a broad scope including areas relevant to the payments industry such as digital technology and infrastructure, data sharing, standards, cybersecurity and digital literacy. Among other things, our submission highlighted that:

    • The industry has invested heavily in building new infrastructure to ensure Australia’s world-class payments system continues to support the digital economy into the future.
    • A self-regulatory approach continues to be the most appropriate way for the industry to navigate the challenges and opportunities presented by the digitalisation of the global economy.

    The Government is expected to launch the Digital Economy Strategy in the first half of 2018.