Cuscal’s Influence on Australian Payments Policy and Regulation

When Isabella Chen, CEO of a rapidly growing Brisbane-based fintech, received her first invitation to submit feedback on proposed RBA payment regulations, she was overwhelmed. The 47-page consultation document was dense with technical jargon, and the implications for her business weren’t immediately clear. What she didn’t realise was that many of the progressive policies outlined in that document had been shaped by decades of advocacy and innovation from Australia’s most influential payments infrastructure provider: Cuscal.

Behind every major advancement in Australia’s payments landscape—from the introduction of the New Payments Platform to the rollout of Consumer Data Right—lies a complex web of policy development, regulatory consultation, and industry collaboration. While most business owners focus on the end result, understanding who shapes these policies can provide crucial insights into where the payments industry is heading and how it might impact your business.

The Hidden Architects: How Cuscal Shapes Australia’s Payment Future

Most Australian business owners interact with payments regulation only when compliance deadlines loom or new requirements emerge. But the real influence happens years earlier, in boardrooms and consultation rooms where industry leaders work with regulators to design the frameworks that will govern tomorrow’s payment systems.

Cuscal’s regulatory influence stems from a unique position in Australia’s financial ecosystem. As both an Authorised Deposit-taking Institution (ADI) and a core infrastructure provider serving over 100 financial institutions, Cuscal sits at the intersection of regulatory compliance and practical implementation. This dual perspective—understanding both the regulator’s intent and the market’s needs—has made them a trusted voice in policy development.

From Consultation to Implementation: The Regulatory Lifecycle

The journey from policy concept to business reality follows a predictable pattern, and Cuscal’s involvement spans every stage. When the RBA or ASIC releases a consultation paper, Cuscal’s response isn’t just theoretical—it’s informed by real-world data from processing millions of transactions daily across diverse client bases.

The PayTo Revolution: When Industry Advocacy Meets Regulatory Innovation

Perhaps no recent example better illustrates Cuscal’s regulatory influence than the development of PayTo—Australia’s answer to modernising recurring payments and direct debits. The story begins not with a regulatory mandate, but with industry frustration over the limitations of traditional direct debit systems.

Ethan Rodriguez, treasurer at a Sydney-based subscription services company, had experienced the pain firsthand. “Our customers were constantly calling about unexpected debits, and we had no way to give them real-time control over their payments. The old system was built for a different era,” he recalls.

Recognising this widespread industry challenge, Cuscal began advocating for a new approach as early as 2019. Their position papers to the RBA didn’t just identify problems—they proposed specific technical solutions and implementation pathways. They argued that any new system should leverage the existing NPP infrastructure, provide real-time customer control, and maintain backward compatibility with existing business processes.

The Ripple Effect: How Regulatory Leadership Creates Market Advantages

Cuscal’s regulatory influence creates a cascading effect that benefits their entire client ecosystem. When they participate in policy development, they’re not just representing their own interests—they’re advocating for the diverse needs of community banks, credit unions, and fintech companies that rely on their infrastructure.

This broad representation is crucial because smaller financial institutions often lack the resources to engage meaningfully with regulatory consultations. A regional credit union might have valuable insights about customer needs, but lacks the regulatory expertise to translate those insights into technical policy recommendations. Cuscal bridges this gap, ensuring that diverse perspectives inform regulatory development.

Beyond Compliance: Driving Innovation Through Regulatory Engagement

While many organisations view regulation as a constraint on innovation, Cuscal has consistently demonstrated how active regulatory engagement can accelerate innovation. Their approach goes beyond mere compliance—they actively shape regulations to enable new business models and technologies.

The development of real-time payments capabilities illustrates this perfectly. Rather than waiting for the RBA to mandate real-time processing, Cuscal began building capabilities and advocating for supportive regulations years in advance. When Osko was launched as part of the NPP, Cuscal’s clients were among the first to offer real-time payments to their customers, creating immediate competitive advantages.

Industry Standards: Setting the Bar for Security and Innovation

Cuscal’s influence extends beyond formal regulation into industry standards and best practices. Their PCI-DSS Level 1 certification and involvement in payments security working groups helps establish benchmarks that smaller institutions can follow. When Cuscal implements a new security protocol or adopts an emerging technology standard, it often signals broader industry adoption.

For business owners, this standards leadership provides confidence and clarity. When Charlotte Murphy was evaluating payment processors for her Melbourne-based e-commerce business, she found comfort in choosing a provider that followed Cuscal’s infrastructure. “I knew that if Cuscal had vetted the security standards, I could trust the technology,” she explains.

Your Strategic Advantage: Understanding Regulatory Influence

Understanding who influences Australia’s payments regulation isn’t just academic—it provides strategic insights that can inform your business decisions. When you know that Cuscal has been advocating for specific policy directions, you can anticipate how regulations might evolve and position your business accordingly.

Your Decision Framework: Leveraging Regulatory Insights

As you evaluate payment solutions and partnerships, consider these strategic questions:

Is your potential partner actively engaged in regulatory development? Providers who participate in consultation processes and working groups often have better insight into upcoming changes and can help you prepare more effectively.

Do they have a track record of regulatory compliance? Look for partners with strong compliance credentials and a history of meeting regulatory deadlines. Cuscal’s ADI status and consistent regulatory engagement provide this assurance.

Can they help you anticipate future requirements? The best partnerships provide not just current compliance, but strategic guidance on emerging regulations that might affect your business.

Do they represent your business segment’s interests? Ensure your provider understands and advocates for the specific needs of businesses like yours during regulatory consultations.

The Future Landscape: What Cuscal’s Influence Means for Your Business

As Australia’s payments landscape continues evolving, Cuscal’s regulatory influence provides valuable signals about future directions. Their current advocacy focuses on areas like embedded finance, cryptocurrency integration, and cross-border payment efficiency—all areas that could significantly impact Australian businesses in coming years.

For forward-thinking business owners, understanding these policy directions enables proactive planning. If Cuscal is advocating for specific regulatory frameworks around embedded finance, it’s likely that these capabilities will become more accessible and standardised over time.

This regulatory leadership also provides stability and predictability. When major infrastructure changes are being considered, Cuscal’s involvement in the consultation process helps ensure that implementations are practical, phased appropriately, and consider the needs of diverse business models.

Building on Strong Foundations: The CAFX Advantage

Just as Cuscal’s regulatory influence provides stability and innovation in payments infrastructure, working with experienced partners can provide similar advantages in foreign exchange and international payments. Understanding regulatory trends and their business implications requires expertise that goes beyond simple compliance.

For businesses managing international transactions or currency exposure, partnering with specialists who understand both regulatory requirements and practical implementation becomes crucial. The same principles that make Cuscal effective in payments policy—deep technical expertise combined with practical market understanding—apply equally to foreign exchange solutions.

The payments industry will continue evolving, shaped by regulatory developments and technological innovation. By understanding who influences these changes and partnering with organisations that can help you navigate them, you position your business to thrive in whatever regulatory landscape emerges next.