AFIA submission to APRA licensing consultation

On 31 October 2025, AFIA supports APRA’s efforts to improve the ADI licensing framework and strongly advocates retaining the Restricted ADI (RADI) pathway as a critical mechanism for fostering innovation and competition in banking. The submission argues that removing RADI would stifle new entrants and proposes reforms to make it more effective, including extending the two-year licence period, allowing phased expansion of product offerings, and introducing staged capital requirements. AFIA emphasises that clearer expectations, faster decisions, and proportionate requirements are essential to enable new business models while maintaining financial stability, and calls for APRA to adopt an enablement-focused approach that balances prudential standards with innovation.

 View the submission here.