Rethink, don’t rebuild: the implementation moment for Australian institutions

The conversation about digital assets in Australia has changed. The question is no longer whether institutions should participate. It is how. 

Look internationally. BlackRock, Fidelity, NYSE and Nasdaq are all building digital asset infrastructure. Bullish has acquired Equiniti. Computershare has announced native tokenisation. Ondo and Xstock are running structured versions of US equities on chain for 24/7 settlement. Assets are moving on chain. 

In Australia, we are seeing it first-hand. Traditional financial institutions are integrating as participants of our exchange to offer digital assets to their customers. Australian issuers are approaching us to list Australian-issued digital assets. A two-sided market is forming in real time. 

This is the implementation moment. The task is not to rebuild the existing financial system on new rails. It is to rethink how markets work when the assets, the money and the record are all digital. 

That starts with three decisions. How assets are held, how trades are executed, and how the new infrastructure aligns with regulation. Custody, market access, regulatory alignment. 

Custody 

The first decision is custody. Where the assets sit while the institution holds them. 

Custody and execution belong in separate entities, with separate balance sheets and separate oversight. In my opinion, the venue that matches your trades should not be the entity that holds your assets, and a failure in one should not reach the other. 

The bar for institutional custody follows. Assets bankruptcy-remote from the exchange. Held in statutory trust. Segregated client by client. Beneficial ownership preserved through any insolvency. None of these are optional. 

This is not new. Digital asset markets already let customers choose how their assets are held: self-custody, or third party custody. Institutions should have the same choice, plus one improvement. They can nominate their own qualified custodian and automatically direct their trades to them. 

BTC Markets already operates this way. Trades match on our exchange. Assets sit with a third-party qualified custodian. The next step is a custodian-agnostic model, where each client picks its own custody network, and we direct trades into it. 

These networks already exist. The question is no longer whether to separate the architecture. It is what connects the separated parts. 

This will require post trade digital asset service providers to integrate just like traditional financial markets.

Market access 

The second decision is market access. How and where trades are executed. 

A regulated exchange is neutral infrastructure. It brings buyers and sellers together in a central limit order book and matches their trades on a fair, orderly and transparent basis. That neutrality, and the public price formation it creates, is the foundation financial markets rest on. 

For an institution with fiduciary duties, an exchange delivers what best execution requires: a lit order book, transparent pricing, and transparent fees. Australia’s market integrity rules make that transparency the standard, not a feature. A licensed operator also runs surveillance, monitoring for manipulation, wash trading, layering and spoofing, and reports suspicious activity to ASIC. That is the difference between a market you can trust and one you take on faith. 

That is the case for the exchange at the center: public price formation, regulatory oversight, and neutral infrastructure institutions can trust. 

Regulatory alignment, and where the value sits 

The third decision is regulatory alignment. Not as compliance, but as the foundation for where most of the value sits. 

Project Acacia put a number on it. The annual opportunity from tokenisation is around A$24 billion, and most of it sits not in the tokens or the money, but in the post-trade infrastructure that settles and records them. So, the market operator’s role does not stop when a trade is matched. It runs through to settlement. 

That makes the exchange an integrated stack across the trade lifecycle: pre-trade, trade, post-trade. When each institution holds assets with its own custodian, across different networks, something has to connect those networks post trade. That is the market operator’s role. It is the one place that connection can sit without re-concentrating the risk separation was meant to remove. 

The real work is in the plumbing. An integrated matching and settlement layer should offer a choice of models: atomic, netting, or intraday windows. Not every institution wants atomic settlement. Some want the capital efficiency of netting, since atomic settlement means pre-funding both legs of every trade in full. Others hit technology limits across custody networks. So, the job is not just to run a market. It is to build the plumbing that gives institutions the settlement model they need. 

Project Acacia found the same thing. Pure cross-chain settlement is not practical at scale, and synchronising existing networks does most of the work with little loss of efficiency. The legal foundation is partly there. The Payments Systems and Netting Act already shows how settlement finality can be protected. The task is to build the new settlement world on that footing: more efficient, with the same protections intact. 

Australia’s moment 

None of these are theoretical. Regulatory clarity in Australia is the unlock. The work across Treasury and ASIC, on the digital asset framework, digital asset platforms, and how tokenised markets are licensed, shows the rethink is already happening. The settlement and clearing questions are being worked through, not deferred. 

This is the shift we opened with. Internationally, the largest institutions are building. In Australia, a two-sided market is forming in real time: institutions joining to reach digital assets for their clients, issuers bringing local assets to list. 

The three decisions are now live. How assets are held, how trades are executed, and how the new infrastructure aligns with regulation. This is what we are building at BTC Markets. We should not be the only Australian operator doing so. 

The opportunity is understood. The work now is to implement it. 

As BTC Markets marks 13 years in Australia’s digital asset industry, many of these questions are now moving from theory into implementation in real time. I’ll be on the Custody, Markets and Capital Flow panel at the DECA Conference at 4:00pm on Monday 15 June. If any of this resonates, come find me and let’s continue the conversation.

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