Revolut’s ADI Licence Application Explained (June 2026)

Introduction

Revolut Payments Australia Pty Ltd has applied to the Australian Prudential Regulation Authority (APRA) to become a licensed Authorised Deposit-taking Institution (ADI). As an e-wallet provider, the company is seeking this regulatory approval to transition its virtual customer accounts into official deposit accounts.

This application demonstrates the strict licensing pathways and regulatory requirements that financial technology companies must meet under the Banking Act 1959 (Cth) (“Banking Act“). This article explains Revolut’s ADI application and the APRA assessment process for fintechs so you can understand the operational changes and regulatory steps involved.

Interactive Tool: Check Your Readiness & Pathway for an APRA Banking Licence

Revolut Australia Seeks an ADI Licence

Revolut’s Current Status as an E-Wallet Provider

According to an email sent to their customers on Friday 12th of June 2026, Revolut Payments Australia Pty Ltd has formally applied to APRA to become an ADI. Currently, Revolut is not an ADI and is not authorised to offer deposit products to its customers in Australia.

The company operates by providing users with a ‘virtual’ account, which functions as a digital wallet with the following features:

• Electronic money storage: Holding electronic money, also referred to as stored value.
• Alternative fund protection: Under this model, the funds held in these accounts are protected by a bank guarantee rather than the government’s Financial Claims Scheme.

The Proposed Transition to Deposit Accounts

If APRA approves the application and grants Revolut an ADI licence, a significant change will occur for its customers. Existing e-wallet accounts would transition into deposit accounts.

This change means that the balance in a customer’s account would be treated differently:

• End of stored value: The balance would no longer be considered stored electronic money.
• ADI deposits: Instead, it would become a deposit held with an ADI.

Revolut has indicated it will provide further notification to customers if the licence is granted and these changes become effective.

Key Operational Changes & Customer Impacts

Activating Financial Claims Scheme Protection

If APRA grants the ADI licence, the transition to deposit accounts activates a significant protection for account holders.

Eligible Australian dollar deposits will be covered by the Financial Claims Scheme (FCS). Backed by the Australian Government, this program protects deposits up to a value of $250,000 per person for each ADI. Ultimately, this scheme ensures that customers’ funds are secure up to that limit in the event an institution fails.

Maintaining Existing AFSL & ACL Authorisations

While becoming an ADI would involve a change to Revolut Australia’s entity name and licensing status, other key business identifiers will not be affected. Furthermore, the company has stated that its existing authorisations will be maintained.

Specifically, the following will remain the same:

• Australian Financial Services Licence (AFSL);
• Australian Credit Licence (ACL);
• Australian Company Number (ACN); and
• Australian Business Number (ABN).

APRA Licensing Pathways for Fintech Companies

The Direct Pathway for Established Entities

APRA provides a direct pathway for businesses that already have the necessary resources and capabilities to become an ADI. This route is designed for established entities prepared to meet the full prudential framework from the outset.

To successfully apply through this pathway, a company must demonstrate its immediate readiness to commence banking operations. If the ADI licence is granted, the organisation can begin conducting its intended banking business without a restricted period.

The Restricted Pathway for Emerging Neobanks

For fintechs and other new entrants that need time to develop their resources, APRA offers a restricted pathway. This option allows a company to conduct limited banking business as a Restricted ADI for a maximum of two years.

This pathway is designed to help emerging businesses achieve specific goals before transitioning to a full licence. Key objectives during the restricted period include:

• Seeking the investment required to fully operationalise the business.
• Testing the company’s operational model in a controlled environment.
• Progressing compliance to meet the full prudential framework required for a standard ADI licence.

Regulatory Hurdles & Assessment Timelines

Navigating the Lengthy APRA Assessment Process

The APRA licensing assessment is an iterative process that typically takes between 12 and 18 months to complete. Prospective applicants are encouraged to engage with APRA’s licensing team early to understand the requirements before lodging a formal APRA licence application. This pre-application stage allows for feedback on key areas, including:

• governance;
• financial resources; and
• risk management frameworks.

Once an applicant is ready, they must submit a formal application with Board-approved documentation. APRA commences its detailed assessment after receiving a substantial set of high-quality materials. To demonstrate they can operate safely within the financial system, applicants must provide comprehensive information on their:

• ownership structure;
• financial position; and
• governance and risk frameworks.

Strict Rules on Using Restricted Banking Words

Under the Banking Act, financial businesses that are not an ADI must obtain consent from APRA before using restricted words. Ultimately, this requirement ensures the public has confidence in the institutions they are dealing with.

These restricted terms include:

• bank;
• banker;
• banking; or
• similar words or expressions, such as neobank, banc, or banq.

An ADI applicant can request APRA’s consent to register a company or business name with a restricted word after lodging their licence application. If consent is given, it is usually subject to conditions, such as not using the name publicly until the ADI licence is officially granted.

Conclusion

Revolut’s application to APRA for an ADI licence highlights the rigorous regulatory pathways fintechs must navigate to offer banking services. This move would transition customer e-wallets to deposit accounts, bringing them under the protection of the FCS.

For other financial technology companies looking to apply for an ADI licence, understanding APRA’s detailed assessment process is the first step. If your business needs guidance on the licensing pathways or preparing an application, contact our APRA application lawyers at Click Legal for specialised advice on your regulatory obligations.

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