Revolut Officially Becomes a Bank After Securing Its Australian ADI Licence

Introduction

On 21 July 2026, APRA granted Revolut Payments Australia Pty Ltd an unrestricted authorised deposit-taking institution licence under the Banking Act 1959 (Cth) (‘Banking Act‘), together with a non-operating holding company licence for Revolut Australia NOHC Pty Ltd. Operating as Revolut Bank Australia, the entity can now accept deposits, offer regulated deposit products, and issue credit in its own right.

For AFSL and ACL holders, compliance teams, and fintech businesses, the decision marks a significant development in APRA’s approach to digital-first entrants in retail banking. This article examines the legal and regulatory implications of the licence grant and what it means for other regulated entities.

The APRA ADI Licence Grant & Its Immediate Legal Effect

APRA Grants Revolut An Unrestricted ADI Licence Under The Banking Act

On 21 July 2026, the Australian Prudential Regulation Authority (APRA) granted Revolut Payments Australia Pty Ltd a licence to operate as an authorised deposit-taking institution (ADI) under the Banking Act. APRA concurrently licensed Revolut Australia NOHC Pty Ltd as a non-operating holding company (NOHC) under the Banking Act. The entity now trades as Revolut Bank Australia, with its Australian Financial Services Licence, Australian Credit Licence, ACN, and ABN remaining unchanged.

The licence is an unrestricted ADI licence, allowing Revolut to conduct full banking operations from commencement without a restricted or transitional phase. This marks a different outcome from Revolut’s United Kingdom experience, where the Bank of England initially issued a restricted licence before granting full permissions in March 2026.

What Revolut Can Legally Do Now That It Couldn’t Do Before

Before 21 July 2026, Revolut operated in Australia as a provider of electronic money services, with customer funds safeguarded by a bank guarantee rather than held as regulated deposits. The grant of an ADI licence under the Banking Act changes that legal position.

Revolut can now:

• accept deposits from the general public in its own name;
• offer regulated savings products;
• pay interest on those deposits; and
• issue credit products — including personal loans and credit cards — using customer deposits as a funding source.

None of these banking activities were permitted before Revolut held an ADI licence under the Banking Act.

Revolut’s Australian Footprint At Licence Grant Date

Existing Australian Operations, Customers & Products At The Time Of Approval

Revolut first launched in Australia in 2020, but it did not apply for an ADI until June 2026. By the time APRA granted the ADI licence on 21 July 2026, its Australian customer base had reached over one million users. The business operated under an Australian Financial Services Licence (AFSL) and Australian Credit Licence (ACL), providing a digital money management platform through its app.

Its core product set included:

• multi-currency foreign exchange;
• payment cards;
• international transfers; and
• access to equities trading.

This existing operational footprint meant Revolut was not a greenfield applicant seeking to build infrastructure and a customer base from scratch.

Why Scale, Earnings & Track Record Matter For APRA’s Comfort

APRA’s comfort in granting an unrestricted ADI licence was supported by Revolut’s demonstrated financial scale and earnings diversification — factors that distinguished it from earlier Australian neobank applicants. In its most recent financial year before the licence grant, Revolut’s Australian operations reported revenue of $71 million and a net profit of $7.4 million.

Globally, Revolut reported profit of US$2.3 billion on revenue of US$6 billion, with revenue streams spanning:

• subscriptions;
• interchange; and
• transaction fees

rather than reliance on a single product line. The entity also held a full banking licence in the United Kingdom, providing APRA with a track record of operating under prudential supervision in a comparable regulatory environment.

Key Product & Operational Changes Triggered By The Banking Licence

From E-Money To FCS-Protected Deposit Accounts

On 21 July 2026, all existing Revolut customer balances ceased to be held as electronic money and became deposit accounts. References to “electronic money” in Revolut’s terms were replaced with “money” to reflect this new legal status.

The bank guarantee that previously safeguarded customer funds ended on the same date. Eligible Australian dollar deposits are now protected by the Australian Financial Claims Scheme (FCS), an Australian Government guarantee up to $250,000 per account holder. The existing Product Disclosure Statement applicable to electronic money was withdrawn from 21 July 2026, as it does not apply to deposit accounts.

Changes To Terms, Disclosures, Complaints & Privacy Settings

Revolut updated its terms and conditions across all account types — Personal, Joint, and Kids & Teens — effective 21 July 2026. The revised documents reflect the new trading name, Revolut Bank Australia, though the entity’s AFSL, ACL, ACN, and ABN remain unchanged.

The complaints email address was changed to [email protected], and the Complaints Policy was updated with new procedural information. Revolut’s Privacy Policy was expanded to include further details about personal information collection, storage, and processing, and now contains a new section on automated decisions that may apply when customers use certain products. These updates align Revolut’s consumer-facing framework with the obligations of an ADI licensed under the Banking Act.

What Revolut’s ADI Licence Signals For Other AFSL/ACL Holders

A New Benchmark For Digital-First Entrants Into Retail Banking

Revolut’s entry as an unrestricted ADI under the Banking Act on 21 July 2026 resets expectations for any fintech or payments business weighing a banking licence. APRA’s comfort reflected demonstrated scale, including:

• an Australian customer base exceeding one million;
• diversified revenue; and
• a record of operating under UK prudential supervision.

The decision indicates APRA will favour applicants that bring an established operational footprint and proven earnings, not just a technology proposition. AFSL and ACL holders contemplating an ADI pathway should expect scrutiny of financial sustainability and governance maturity well before lodging an application.

Implications For Product Design, Distribution & Customer Expectations

Digital-first entrants like Revolut raise the bar for UX, real-time functionality, and disclosure clarity across retail banking. Other AFSL and ACL holders may face pressure to review their own product roadmaps, particularly around:

• account opening speed;
• in-app transparency; and
• terms written in accessible language.

The shift also affects distribution strategies. Revolut’s licence means regulated deposit and credit products are now offered through a purely app-based channel alongside FX, trading, and payments. Licensees distributing through traditional channels may need to assess whether their customer onboarding and disclosure frameworks remain fit for purpose in a market where digital delivery is the norm.

The Regulatory Context & Lessons From APRA’s Decision

APRA’s Approach After The Xinja & Volt Experience

The failures of Xinja and Volt Bank raised questions about APRA’s licensing framework for digital entrants. Both were Australian neobanks that secured ADI licences under the Banking Act but could not sustain operations, returning their licences after struggling with capital and profitability.

The government amended APRA’s mandate in the week before the Revolut decision to support productivity and growth. Revolut’s one-million-strong Australian customer base, diversified revenue, and existing record under UK prudential supervision addressed concerns that earlier neobank failures had exposed, setting it apart from local start-ups that lacked comparable scale.

Key Prudential & Conduct Themes For Future Digital Bank Applicants

APRA’s grant of an unrestricted ADI licence to Revolut signals a preference for applicants that arrive with demonstrated financial sustainability. Revolut reported Australian revenue of $71 million and net profit of $7.4 million in its most recent financial year, with globally diversified income from subscriptions, interchange, and transaction fees.

Governance maturity, risk and compliance readiness, and the ability to operate under existing prudential supervision appear central to APRA’s assessment, and Revolut held a full UK banking licence before the Australian decision, providing a track record of meeting regulatory expectations.

Future applicants should expect scrutiny of the following well before lodging an application, rather than seeking to build these capabilities during a restricted phase:

• Capital adequacy;
• Funding stability; and
• Consumer outcome frameworks.

Conclusion

On 21 July 2026, APRA granted Revolut an unrestricted ADI licence under the Banking Act, enabling it to accept deposits, offer savings products, and issue credit — all protected by the FCS up to $250,000. The decision sets a new benchmark for AFSL and ACL holders, signalling that APRA will expect demonstrated scale, revenue diversity, and governance maturity from digital-first banking applicants.

Regulated entities considering a move toward deposit-taking or credit activities should assess how this licensing precedent affects their own regulatory readiness. Contact Click Legal’s APRA licensing lawyers to discuss how APRA’s evolving approach may shape your compliance and licensing strategy.