Australian C-Hour Legislative Strategy

The Reciprocity Mandate: A Strategic
Framework

for

Integrating

Regenerative

Assets

into

Australian

Law

The Reciprocity Mandate: A Strategic Framework for Integrating Regenerative Assets into Australian Law Executive Summary Part I: The Australian Legislative and Political Landscape Section 1.1: From Inquiry to Legislation: A Deliberate and Consultative Path Section 1.2: Core Architecture of the Draft Digital Asset Platforms Bill 2025 Section 1.3: The Political Environment: An Alignment of Values and Ambition Part II: The Policy Case for a 'Regenerative Asset' Carve-Out Section 2.1: Deconstructing the 'Braided Economy' for Australian Policymakers Section 2.2: The Community-Hour as a Non-Financial Product Table 1: Comparative Analysis of Digital Asset Classifications (Australian Context) Section 2.3: The 'Fundamental Incompatibility' Hook Part III: A Strategic Framework for Legislative Integration Section 3.1: Strategic Entry Points Section 3.2: Crafting the 'Regenerative Asset' Amendment Table 2: Proposed Amendments to Australian Legislation Section 3.3: Proposed Regulatory Framework Part IV: A Multi-Pronged Advocacy and Engagement Strategy Section 4.1: Navigating the Parliamentary Process Section 4.2: Targeted Parliamentary Outreach Table 3: Key Stakeholder Matrix and Messaging Framework Section 4.3: Building a Coalition of Support Conclusion and Prioritised Recommendations Works cited

Executive Summary

The Australian Government is on the cusp of implementing a landmark regulatory framework

for digital assets. The exposure draft of the Treasury Laws Amendment (Regulating Digital
Asset,

And

Tokenised

Custody,

Platforms)

Bill

2025

represents

a

considered,

principles-based

approach

to

mitigating

consumer

harm

and

providing

market

certainty

by

bringing

custodial

intermediaries

under

the

established

Australian

Financial

Services

Licence

(AFSL)

regime.
1

While

this

platform-centric

model

is

a

pragmatic

and

necessary

step,

its

focus

on

financial

intermediaries

and

custodial

risk

creates

a

strategic

blind

spot.

It

fails

to

adequately

provide

for

a

new

generation

of

digital

assets

designed

not

for

financial

speculation,

but

for

social

and

ecological

regeneration.

This

omission

risks

stifling

a

uniquely

powerful

form

of

pro-social

innovation

that

aligns

directly

with

Australia's

national

interests.

This report presents a comprehensive legal and political strategy to address this gap by
establishing

a

legislative

'carve-out'

for

a

novel

asset

class:

the

'Regenerative

Asset'.

The

archetype

for

this

class

is

the

Community-Hour

(C-hour),

a

non-speculative

digital

receipt

for

one

hour

of

verified

contribution

to

community

well-being,

ecological

stewardship,

or

the

care

economy.
3
The C-hour is the cornerstone of a 'Braided Economy' model, designed to formally
measure,

value,

and

reward

the

foundational,

non-market

work

that

underpins

a

resilient

society

and

a

healthy

environment.

The central recommendation of this report is to amend the forthcoming Digital Asset
Platforms

Bill

2025

and

the

Corporations

Act

2001

to

create

a

distinct

and

appropriate

regulatory

pathway

for

Regenerative

Assets.

This

strategy

does

not

oppose

the

Government's

current

direction

but

seeks

to

enhance

it.

The

policy

justification

for

this

carve-out

is

derived

directly

from

the

Australian

Treasury's

own

'Token

Mapping'

exercise,

which

concluded

that

certain

non-intermediated,

community-governed

token

systems

may

be

"fundamentally

incompatible"

with

the

existing

financial

services

framework.
4
The C-hour system is a
quintessential

example

of

such

a

system.

By creating this clear legal lane, Australia can position itself as a global leader in fostering
technology

that

generates

tangible

social

dividends.

This

initiative

strengthens

the

proposed

Bill

by

promoting

genuine,

non-speculative

innovation,

enhancing

consumer

protection

through

an

asset

class

that

is

pro-social

by

design,

and

providing

a

powerful,

market-based

tool

to

achieve

the

Albanese

Government's

stated

ambition

for

a

more

inclusive,

purposeful,

and

"values-based

economy".
5
This report provides the specific legislative language, the
detailed

political

engagement

plan,

and

the

compelling

policy

narrative

required

to

turn

this

vision

into

a

legal

reality,

securing

profound

benefits

for

the

Australian

community

and

environment.


Part I: The Australian Legislative and Political
Landscape

Section 1.1: From Inquiry to Legislation: A Deliberate and Consultative
Path


Australia's approach to regulating digital assets has been characterized by a deliberate,
consultative,

and

evidence-led

methodology.

Unlike

jurisdictions

that

have

pursued

reactive

or

enforcement-centric

strategies,

the

Australian

policy

trajectory

reveals

a

commitment

to

understanding

the

underlying

technology

and

its

economic

functions

before

prescribing

regulation.

This

methodical

process,

from

parliamentary

inquiry

to

detailed

policy

consultation,

has

created

a

sophisticated

and

well-reasoned

foundation

for

the

current

legislative

reforms.

It

is

this

very

process

that

provides

the

critical

entry

points

for

a

nuanced

proposal

to

recognise

Regenerative

Assets.

The

government

has

demonstrated

a

clear

willingness

to

engage

with

complex

arguments

and

adapt

its

approach

based

on

evidence,

creating

a

favourable

environment

for

a

proposal

that

builds

upon,

rather

than

contradicts,

its

existing

work.

The genesis of the current reform agenda can be traced to the landmark Final Report of the
Senate

Select

Committee

on

Australia

as

a

Technology

and

Financial

Centre,

tabled

in

October

2021.
7
Chaired by then-Senator Andrew Bragg, this comprehensive inquiry engaged
deeply

with

industry,

academia,

and

regulators

to

map

the

opportunities

and

risks

of

the

burgeoning

digital

asset

sector.
10
The Committee's report was pivotal, moving the policy
debate

beyond

simplistic

narratives

and

toward

a

sophisticated

understanding

of

the

technology's

potential.

It

made

twelve

key

recommendations,

forming

a

coherent

roadmap

for

reform.

Central

among

these

were

proposals

to

establish

a

market

licensing

regime

for

digital

currency

exchanges,

introduce

minimum

standards

for

the

custody

of

digital

assets,

and,

most

critically

for

this

strategy,

a

recommendation

that

the

Australian

Government,

through

Treasury,

conduct

a

'token

mapping'

exercise

to

determine

the

best

way

to

characterise

the

various

types

of

digital

assets

in

Australia.
8
The then-Coalition Government's response in December 2021, titled "Transforming Australia's
Payment

System,"

signalled

a

broad,

bipartisan

consensus

on

the

need

for

action

by

agreeing

in

principle

to

the

core

recommendations,

including

the

token

mapping

exercise.
14
This
commitment

was

subsequently

carried

forward

by

the

incoming

Albanese

Labor

Government,

demonstrating

a

shared

understanding

across

the

political

spectrum

that

regulatory

clarity

was

essential

for

both

consumer

protection

and

innovation.

This commitment culminated in the release of Treasury's 'Token Mapping Consultation Paper'
in

February

2023,

a

foundational

document

in

Australia's

digital

asset

policy

development.
4

This paper was not a simple taxonomy but a sophisticated attempt to apply Australia's
established

regulatory

principles

to

the

novel

crypto

ecosystem.

Its

methodology

was

explicitly

guided

by

two

long-standing

pillars

of

Australian

financial

regulation:

technology

neutrality

and

a

'functional

approach'.
17
Rather than creating bespoke rules for specific
technologies,

the

paper

sought

to

identify

the

economic

'function'

of

a

given

crypto

asset

or

service

and

assess

whether

that

function

fell

within

the

existing

regulatory

'perimeter'

of

a

'financial

product'

as

defined

in

the

Corporations

Act

2001
.
4
To achieve this, the paper proposed a framework for classifying crypto arrangements into
three

components:

the

'token'

(the

digital

record-keeping

unit),

the

'token

system'

(the

protocol

or

arrangement

governing

the

token),

and

the

'function'

(the

product

or

benefit

provided).
4
It is this analytical framework that produced the most significant conclusion for
the

purposes

of

this

strategy.

The

paper

drew

a

clear

distinction

between

two

types

of

token

systems:
1. Intermediated Token Systems: Where an intermediary (such as an exchange or a
custodian)

makes

promises

and

provides

services

to

a

consumer.

A

large

portion

of

the

crypto

ecosystem

falls

into

this

category,

and

the

risks

are

analogous

to

traditional

financial

services.
4
2. Public Token Systems: Where users form transactional relationships directly on a public
network,

often

governed

by

smart

contracts,

in

the

absence

of

a

traditional

intermediary.

The paper's critical finding, which forms the lynchpin of the policy case for a Regenerative
Asset

carve-out,

was

its

conclusion

regarding

this

second

category.

Treasury

acknowledged

that

products

in

this

category,

which

operate

without

the

intermediaries

that

financial

services

law

is

designed

to

regulate,

"may

be

fundamentally

incompatible

with

the

existing

financial

services

regulatory

framework".
4
This official recognition of a potential regulatory mismatch is
not

a

flaw

in

the

government's

analysis

but

a

sophisticated

observation

that

provides

the

explicit

policy

justification

for

creating

a

new,

more

appropriate

regulatory

pathway

for

assets

that

fit

this

description.


Section 1.2: Core Architecture of the Draft Digital Asset Platforms Bill
2025


The intellectual work of the Token Mapping exercise directly informs the architecture of the
Government's

proposed

legislative

solution:

the

exposure

draft

of

the

Treasury

Laws

Amendment

(Regulating

Digital

Asset,

And

Tokenised

Custody,

Platforms)

Bill

2025
,

released

for

consultation

in

September

2025.
1
The Bill is a direct and logical consequence of the token
mapping

findings.

Having

identified

that

the

primary

source

of

unmitigated

consumer

risk

resides

in

'intermediated'

platforms

that

take

custody

of

client

assets,

the

Bill

is

precisely

tailored to address this specific harm.
20
Its core logic is to regulate the activity of providing a
custodial

digital

asset

facility,

rather

than

attempting

to

define

the

legal

nature

of

every

underlying

asset

itself.

This is achieved through a significant amendment to the Corporations Act 2001 , which
introduces

two

new

categories

of

'financial

product'.
1
The creation of these new product
categories

brings

the

providers

of

these

facilities

squarely

within

the

existing

and

well-understood

AFSL

regime.

The

two

new

products

are:
● Digital Asset Platform (DAP): Defined as a facility where an operator holds digital
tokens

on

behalf

of

clients.

This

definition

is

broad,

intended

to

capture

a

wide

range

of

business

models,

including

cryptocurrency

exchanges,

custodial

wallet

providers,

and

staking

services

where

the

provider

takes

control

of

the

client's

tokens.
20
● Tokenised Custody Platform (TCP): Defined as a facility where an operator holds an
underlying

asset

(which

can

be

physical,

like

gold,

or

intangible,

like

shares)

and

creates

a

unique

digital

token

that

represents

the

client's

right

to

redeem

or

direct

that

underlying

asset.

This

covers

services

that

'tokenise'

real-world

assets.
20
Under the proposed legislation, any entity providing these DAP or TCP facilities, or providing
financial

services

such

as

advice

in

relation

to

them,

will

be

required

to

hold

an

AFSL

issued

by

the

Australian

Securities

and

Investments

Commission

(ASIC).
1
This triggers a comprehensive
suite

of

regulatory

obligations

designed

to

protect

consumers

and

ensure

market

integrity.

These

obligations

include

meeting

standards

for

capital

adequacy,

having

robust

risk

management

systems,

ensuring

key

personnel

are

competent,

providing

adequate

disclosure

to

clients

via

a

new

'Platform

Guide',

and

having

internal

and

external

dispute

resolution

mechanisms.
2
A key feature of the Bill's architecture is its deliberate technology-neutral language. The draft
legislation

avoids

using

specific,

and

potentially

transient,

technological

terms

like

'blockchain',

'cryptocurrency',

or

'distributed

ledger

technology'.
1
Instead, it uses broader
concepts

like

'digital

token'

and

'digital

object'.

This

approach

is

designed

for

longevity,

ensuring

the

framework

can

adapt

to

future

technological

developments

without

requiring

constant

legislative

amendment.

This

principle

of

technology

neutrality

is

a

strategic

advantage

that

can

be

leveraged,

as

it

allows

for

a

focus

on

the

economic

substance

and

purpose

of

an

asset,

rather

than

its

underlying

technical

implementation.

The Bill also includes a low-value exemption. Platforms that hold less than $5,000 per
customer

and

facilitate

less

than

$10

million

in

total

transactions

per

year

will

be

exempt

from

the

AFSL

requirement.
1
While this may provide a pathway for small-scale or early-stage
projects,

it

is

fundamentally

unsuitable

for

the

C-hour

protocol,

which

is

designed

for

national

and

global

scale

and

would

quickly

exceed

these

thresholds.

Therefore,

relying

on

this

exemption

is

not

a

viable

long-term

strategy.

The

C-hour

requires

a

dedicated,

purpose-built

regulatory

classification

that

recognises

its

unique

nature,

rather

than

an

exemption

based

on

its scale.

Section 1.3: The Political Environment: An Alignment of Values and
Ambition


The success of any legislative reform strategy depends critically on its alignment with the
prevailing

political

environment

and

the

priorities

of

key

decision-makers.

In

the

context

of

the

C-hour

proposal,

the

current

Australian

political

landscape

presents

a

uniquely

receptive

and

favourable

climate.

The

Albanese

Labor

Government's

core

economic

and

social

narrative,

the

specific

policy

interests

of

the

ministers

responsible

for

the

legislation,

and

the

backgrounds

and

public

statements

of

influential

committee

members

and

crossbenchers

all

indicate

a

powerful

alignment

of

values

and

ambition

with

the

foundational

principles

of

the

Regenerative

Asset

class.

This

proposal

does

not

need

to

create

a

new

political

conversation;

it

can

join

and

amplify

an

existing

one

about

how

to

build

a

more

purposeful,

inclusive,

and

sustainable

Australian

economy.

Government Leadership:
At the apex of economic policymaking, The Hon Dr Jim Chalmers MP , the Treasurer, has
embarked

on

a

significant

public

intellectual

project

to

redefine

the

goals

of

economic

policy

in

Australia.
24
In a widely discussed essay and numerous speeches, he has called for a move
towards

a

"values-based

capitalism"

or

a

"social

purpose

economy".
5
He argues that
economic

policy

must

look

beyond

traditional

metrics

like

GDP

to

measure

well-being

and

social

cohesion,

and

that

markets

should

be

designed

to

deliver

a

"social

dividend".
6
He has
explicitly

championed

the

expansion

of

social

impact

investing

and

the

need

to

find

new

models

to

fund

solutions

in

areas

like

aged

care

and

disability

services,

where

markets

have

traditionally

failed.
6
This overarching philosophy provides the premier political and intellectual
anchor

for

the

C-hour

proposal.

The

C-hour

is

a

tangible,

scalable

mechanism

to

build

the

very

"social

purpose

economy"

the

Treasurer

has

described.

Directly responsible for the legislation is The Hon Dr Daniel Mulino MP , the Assistant
Treasurer

and

Minister

for

Financial

Services.
30
As the minister steering the digital asset
reforms,

his

public

framing

is

crucial.

He

has

consistently

described

the

Bill's

purpose

as

"legitimising

the

good

actors

and

shutting

out

the

bad,"

and

providing

"certainty

for

business

and

confidence

for

consumers".
20
This framing creates a clear strategic imperative: to position
the

C-hour

not

as

a

fringe

crypto-asset

seeking

to

evade

regulation,

but

as

the

archetypal

"good

actor"

asset—one

that

is

non-speculative,

transparent,

and

pro-social

by

its

very

design.

The

advocacy

strategy

must

present

the

proposal

as

an

enhancement

that

helps

the

Minister

achieve

his

stated

goals.

Supporting this is The Hon Ed Husic MP , the Minister for Industry and Science.
36
His portfolio
focus

on

building

sovereign

capability,

backing

Australian-led

innovation,

and

creating

a

"Future

Made

in

Australia"

provides

a

powerful

industrial

policy

lens.
38
The Regenerative
Civilization

Protocol,

as

a

homegrown,

globally

significant

innovation,

can

be

framed

as

a

key

contributor

to

this

agenda,

positioning

Australia

at

the

forefront

of

a

new,

more

ethical

model

of

technological

and

social

development.

Key Parliamentary Committees:
The legislative journey of the Bill will be critically shaped by parliamentary committees,
particularly

in

the

Senate.

The

Senate

Economics

Legislation

Committee

is

the

primary

body

responsible

for

scrutinizing

Treasury

legislation.

Its

current

Chair

is

Senator

Lisa

Darmanin

(ALP,

VIC)
.
42
Senator Darmanin's career prior to entering parliament was with the
Australian

Services

Union,

where

she

was

a

lifelong

advocate

for

workers

in

the

community

and

care

sectors,

leading

landmark

campaigns

for

equal

pay

and

the

recognition

of

undervalued

work.
44
Her public statements and career history demonstrate a deep, personal
understanding

of

the

very

issues

the

C-hour

is

designed

to

address.

Her

position

as

chair

of

the

key

committee

represents

an

extraordinary

alignment,

making

her

a

pivotal

and

potentially

highly

receptive

audience

for

this

proposal.

In the House of Representatives, the Standing Committee on Economics , chaired by
Minister

Husic,

plays

a

vital

role

in

shaping

economic

debate.

Its

membership

includes

influential

voices

such

as

the

independent

Member

for

Wentworth,

Ms

Allegra

Spender

MP
.
36

A

former

business

leader,

Ms

Spender

is

deeply

focused

on

Australia's

productivity

challenges,

intergenerational

fairness,

and

the

need

for

ambitious

economic

reform.
47
The
C-hour's

potential

to

unlock

the

productivity

of

the

non-market

economy

and

create

new

forms

of

value

for

community

contribution

speaks

directly

to

her

stated

policy

concerns.

Opposition and Crossbench:
Building bipartisan support is essential for the long-term success and stability of any
legislative

reform.

Senator

the

Hon

Andrew

Bragg

(Liberal,

NSW)

is

a

key

figure

in

this

regard.
51
As the architect of the 2021 Senate inquiry, he has a deep understanding of the
issues

and

is

a

vocal

advocate

for

a

clear,

pro-innovation

regulatory

framework.
10
His
frustration

with

the

current

government's

pace

of

reform

led

him

to

introduce

his

own

Private

Senator's

Bill,

the

Digital

Assets

(Market

Regulation)

Bill

2023
,

demonstrating

his

willingness

to

lead

on

the

issue.
11
Engaging him constructively and positioning the Regenerative Asset
carve-out

as

a

logical

extension

of

his

own

committee's

work

will

be

critical.

Similarly, Senator the Hon Jane Hume (Liberal, VIC) , a former Minister for Superannuation,
Financial

Services

and

the

Digital

Economy,

is

a

highly

experienced

and

respected

voice

on

financial

technology

and

innovation.
42
Her support would lend significant credibility to the

proposal within the Coalition.
Finally, The Australian Greens are natural allies for this initiative. Their core platform is built
on

principles

of

ecological

sustainability,

social

justice,

and

challenging

economic

models

that

externalize

costs

onto

the

community

and

the

environment.
59
The C-hour's function of
rewarding

environmental

regeneration

and

community

work

aligns

perfectly

with

their

policy

objectives,

making

them

strong

potential

champions

for

the

amendment

in

the

Senate,

where

they

frequently

hold

the

balance

of

power.
61

Part II: The Policy Case for a 'Regenerative Asset'
Carve-Out



Section 2.1: Deconstructing the 'Braided Economy' for Australian
Policymakers


To secure a legislative carve-out, the conceptual framework of the 'Braided Economy' and the
Community-Hour

must

be

translated

from

a

global

protocol

into

the

specific

language

and

context

of

Australian

public

policy.

The

core

argument—that

modern

capitalism

operates

on

an

"incomplete

ledger"

by

failing

to

value

foundational

work—must

be

grounded

in

tangible

Australian

challenges

and

data.
3
By doing so, the C-hour is no longer presented as an
abstract

technological

novelty,

but

as

a

pragmatic,

market-based

tool

designed

to

solve

well-documented,

pressing

national

problems.

The concept of the "incomplete ledger" resonates powerfully with Australia's widely discussed
"productivity

puzzle."

While

productivity

in

traditional

sectors

is

a

constant

focus

of

economic

debate,

the

vast

and

growing

'foundational

economy'—comprising

care,

community

services,

and

environmental

stewardship—is

often

overlooked

in

these

discussions.

Yet,

this

sector

is

critical

to

national

well-being

and

economic

resilience.

The

C-hour

offers

a

mechanism

to

make

the

value

of

this

work

visible

on

a

national

scale.

For

instance,

volunteering

in

Australia

contributes

an

estimated

$290

billion

to

the

economy

annually—a

staggering

figure

that

remains

largely

invisible

in

conventional

economic

accounts.

Similarly,

the

work

of

over

2.65

million

informal

caregivers,

who

provide

essential

support

to

the

elderly

and

people

with

disabilities,

represents

an

enormous

economic

subsidy

to

the

formal

healthcare

and

social

services

systems.

The

C-hour

system,

through

mechanisms

like

a

'Caregiver's

Dividend',

would

provide

a

formal,

non-welfare-based

recognition

and

reward

for

this

essential

labour,

directly addressing the Treasurer's call for new models that create a measurable "social
dividend".
3
Furthermore, the C-hour can be framed as a powerful tool for achieving specific government
policy

objectives.

In

the

environmental

sphere,

it

can

create

direct

incentives

for

participation

in

regeneration

and

conservation

activities,

supporting

the

work

of

community

groups

like

Landcare

and

local

conservation

volunteers.

In

social

policy,

it

can

foster

community

cohesion

and

combat

loneliness

by

rewarding

mentorship,

neighbourhood

support,

and

civic

engagement.

This

reframes

the

C-hour

from

a

'cryptocurrency'

into

a

versatile

public

policy

instrument.

It

is

a

market-based,

non-bureaucratic

mechanism

for

directing

human

capital

towards

areas

of

national

priority

that

are

currently

underserved

by

the

traditional

financial

economy.

This

narrative

aligns

with

the

principles

of

both

major

parties:

it

offers

a

market-oriented

solution

that

empowers

individuals

and

communities,

consistent

with

conservative

principles,

while

also

achieving

progressive

goals

of

valuing

care

work

and

strengthening

the

social

safety

net.


Section 2.2: The Community-Hour as a Non-Financial Product

The legal cornerstone of the strategy is to establish that the Community-Hour (C-hour)
system,

as

designed,

falls

outside

the

existing

regulatory

perimeter

of

the

Corporations

Act

2001
.

It

is

not

a

'financial

product'

and

the

protocol

governing

it

is

not

a

'Digital

Asset

Platform'

(DAP)

or

a

'Tokenised

Custody

Platform'

(TCP)

as

defined

in

the

proposed

2025

Bill.

This

argument

is

not

based

on

a

technical

loophole,

but

on

the

fundamental

purpose

and

structure

of

the

asset,

which

is

intentionally

designed

to

be

non-financial.

A systematic analysis against the definitions in Chapter 7 of the Corporations Act and ASIC's
guidance

demonstrates

this

distinction.
62
The C-hour is not: ● A Security: The C-hour fails the established legal test for an investment contract (known
in

the

US

as

the

Howey

Test

and

applied

similarly

in

Australian

jurisprudence).

There

is

no

"investment

of

money"

with

an

"expectation

of

profits

arising

from

the

efforts

of

a

third

party".
3
Users earn C-hours through their own personal contributions of time and effort.
The

value

they

receive

is

a

direct

result

of

their

own

work,

not

the

managerial

efforts

of

a

promoter

or

a

centralised

entity

seeking

to

generate

a

financial

return

for

investors.
3
● An Interest in a Managed Investment Scheme (MIS): An MIS involves people
contributing

money

or

assets

to

a

common

pool,

which

is

then

used

by

a

'responsible

entity'

to

generate

financial

benefits

that

are

distributed

back

to

the

members.
62
The
C-hour

system

operates

differently.

There

is

no

common

pool

of

invested

capital.

The

governing

body,

a

Decentralized

Autonomous

Organisation

(DAO),

is

not

a

responsible

entity

managing

investments

for

profit;

it

is

a

community-governed

protocol

for

verifying

and recording contributions. The benefits are earned individually and directly by
participants

for

their

own

work.
3
● A Derivative or a Non-Cash Payment Facility: The C-hour's value is not derived from
another

financial

instrument,

nor

is

it

designed

as

a

general-purpose

facility

for

making

payments

across

the

economy.

Its

utility

is

primarily

within

the

'Reciprocity

Economy'

for

redeeming

specific

community-backed

goods

and

services.
3
Crucially, the C-hour protocol is also not a DAP or a TCP under the proposed 2025 Bill. The
defining

characteristic

of

both

a

DAP

and

a

TCP

is

the

presence

of

a

custodial

'operator'—an

intermediary

that

holds

assets

on

behalf

of

clients.
20
This custodial relationship is the specific
risk

the

Bill

is

designed

to

regulate.

The

C-hour

system

is

architected

to

eliminate

this

risk.

C-hours

are

earned

directly

into

a

user's

self-custodied

digital

wallet.

The

user

has

exclusive

control

of

their

private

keys

and,

therefore,

their

assets.

The

protocol's

software

and

the

governing

DAO

facilitate

the

verification

and

issuance

of

C-hours,

but

they

do

not

take

custody

of

them.

The

'operator'

is

the

decentralised

community

itself,

not

a

corporate

intermediary.

This

fundamental

structural

difference

means

the

C-hour

system

does

not

create

the

custodial

risks

that

the

AFSL

regime

for

DAPs

and

TCPs

is

designed

to

mitigate,

making

that

regulatory

framework

both

unnecessary

and

inappropriate.


Table 1: Comparative Analysis of Digital Asset Classifications
(Australian

Context)


Feature Financial Product ( Corporations Act 2001 )
Digital Asset Facility (Proposed Bill)
Proposed: Regenerative Asset
Primary Purpose Financial investment; capital formation; risk management; non-cash payment.
To provide a custodial platform for holding and transacting digital assets on behalf of clients.
To measure, value, and reward non-financial contributions to community and ecological well-being.
Value Derivation Expectation of future financial profit from the efforts of others;
Market value of the underlying digital assets held in custody; platform
Verified off-chain human work (e.g., one hour of caregiving,

underlying financial instruments.
utility. volunteering, or environmental restoration).
Issuance / Creation Method
Issued by a promoter or company via an investment contract (e.g., a PDS or prospectus).
A facility is 'issued' or provided by a platform operator to a client who opens an account.
Earned directly by individuals through verified personal contributions to the community.
Key Risks Investor fraud; lack of disclosure; market volatility; insolvency of the issuer.
Platform insolvency; commingling of assets; fraud; cyber theft; operational failure of the custodian.
Integrity of the contribution verification process; failure of DAO governance; lack of redemption utility.
Appropriate Regulator
ASIC (under a full AFSL and/or market licence regime).
ASIC (under the proposed AFSL regime for DAPs and TCPs).
ASIC (under a proposed new, light-touch registration and disclosure framework).

Section 2.3: The 'Fundamental Incompatibility' Hook

The most compelling policy argument for a bespoke legislative carve-out for Regenerative
Assets

is

not

one

that

needs

to

be

invented

from

whole

cloth.

It

is

an

argument

that

the

Australian

Treasury

has

already

made

itself.

The

strategic

approach

is

to

leverage

the

government's

own

sophisticated

analysis

from

the

Token

Mapping

Consultation

Paper,

positioning

the

proposed

amendment

as

the

logical

and

necessary

policy

response

to

its

own

findings.
4
This transforms the advocacy from a request for special treatment into a
collaborative

effort

to

complete

the

government's

own

policy

architecture.

The argument can be constructed in a clear, linear progression that is easy for policymakers

to follow: 1. Acknowledge and Endorse Treasury's Analysis: The first step is to commend Treasury
for

its

nuanced

and

insightful

analysis

in

the

Token

Mapping

paper.

Specifically,

its

distinction

between

'intermediated

token

systems'

and

'public

token

systems'

is

a

crucial

and

accurate

observation

of

the

crypto

ecosystem's

structure.
4
2. Affirm the Appropriateness of the Draft Bill for Intermediated Systems: The second
step

is

to

affirm

that

the

Digital

Asset

Platforms

Bill

2025

is

an

excellent,

well-designed,

and

appropriate

regulatory

framework

for

the

risks

associated

with

'intermediated'

systems.

By

focusing

on

custodial

platforms,

the

Bill

correctly

targets

the

primary

source

of

consumer

harm

seen

in

recent

market

failures,

such

as

platform

insolvency

and

the

misuse

of

client

funds.
20
This demonstrates that the proposal is not anti-regulation, but
pro-
appropriate
-regulation.
3. Classify the C-hour as a 'Public Token System': The third step is to clearly
demonstrate

that

the

C-hour

and

the

Regenerative

Civilization

Protocol

are

a

quintessential

example

of

a

'public

token

system'.

It

is

a

system

designed

to

enable

a

community

to

form

transactional

relationships

(the

earning

and

redemption

of

C-hours)

directly,

governed

by

a

transparent

protocol

and

a

DAO,

specifically

without

the

need

for

a

traditional,

custodial

intermediary.
3
4. Invoke Treasury's Own Conclusion: The final and most powerful step is to directly
quote

or

paraphrase

Treasury's

own

conclusion

from

the

Token

Mapping

paper:

that

such

public,

non-intermediated

systems

"may

be

fundamentally

incompatible

with

the

existing

financial

services

regulatory

framework".
4
This line of reasoning leads to an unavoidable conclusion. If the government's own expert
analysis

has

identified

a

class

of

systems

that

do

not

fit

the

existing

regulatory

model,

and

the

C-hour

is

a

prime

example

of

such

a

system,

then

attempting

to

force

it

into

the

legislative

framework

designed

for

'intermediated'

systems

would

be

a

policy

error.

It

would

create

a

regulatory

mismatch,

imposing

inappropriate

and

burdensome

obligations

designed

for

risks

that

do

not

exist

in

the

C-hour

model,

while

failing

to

address

the

unique

risks

that

do

(such

as

governance

and

verification

integrity).

Therefore,

the

creation

of

a

separate,

bespoke

'carve-out'

is

not

a

special

favour

or

an

exemption

from

the

rules.

It

is

the

direct,

logical,

and

responsible

policy

action

required

to

address

the

"fundamental

incompatibility"

that

Treasury

itself

has

identified.

This

approach

allows

advocates

to

present

themselves

as

helpful

partners

in

the

policy-making

process,

assisting

the

government

in

completing

the

important

work

it

has

already

started.


Part III: A Strategic Framework for Legislative
Integration

Section 3.1: Strategic Entry Points

A coherent policy case must be matched with a precise and actionable legislative strategy.
The

primary

and

most

immediate

legislative

vehicle

for

creating

a

legal

carve-out

for

Regenerative

Assets

is

the

Treasury

Laws

Amendment

(Regulating

Digital

Asset,

And

Tokenised

Custody,

Platforms)

Bill

2025
.
1
The strategy is to propose amendments directly to
this

Bill

as

it

moves

through

the

policy

development

and

parliamentary

process.

This

is

the

most

efficient

pathway,

as

it

leverages

the

existing

political

momentum

and

legislative

timetable

for

digital

asset

reform.

The secondary but essential legislative target is the parent act, the Corporations Act 2001 ,
specifically

Chapter

7,

which

contains

the

foundational

definitions

of

'financial

product'

and

'financial

service'.
21
Any amendment to the new Bill to create a carve-out must be supported
by

a

corresponding

definitional

amendment

to

the

principal

Act

to

ensure

legal

consistency

and

clarity.

The

proposed

amendments

are

designed

to

work

in

tandem:

one

creates

the

positive

legal

definition

of

a

'Regenerative

Asset',

and

the

other

explicitly

excludes

it

from

the

new

custodial

platform

regime.

The timing of this intervention is critical. The most effective entry point is the current public
consultation

phase

on

the

exposure

draft

of

the

Bill.

By

lodging

a

comprehensive

submission

with

Treasury

that

includes

the

detailed

legal

arguments

from

Part

II

and

the

specific

draft

legislative

text

from

Section

3.2,

the

proposal

can

be

considered

by

departmental

officials

and

the

Minister's

office

before

the

Bill

is

finalised

and

introduced

to

Parliament.

This

provides

the

greatest

opportunity

for

the

amendments

to

be

adopted

into

the

government's

own

version

of

the

Bill,

which

is

a

far

more

effective

strategy

than

attempting

to

force

amendments

later

in

the

parliamentary

process.

Should

this

initial

approach

be

unsuccessful,

the

secondary

strategy

would

be

to

work

with

supportive

parliamentarians

to

move

the

amendments

during

the

committee

stage

of

the

Bill's

review

in

the

Senate.


Section 3.2: Crafting the 'Regenerative Asset' Amendment

To move from a policy concept to a legal reality, it is essential to provide policymakers with
concrete,

professionally

drafted

legislative

language.

This

significantly

lowers

the

barrier

to

adoption

and

demonstrates

a

high

level

of

sophistication

and

seriousness.

The

proposed

amendment

package

consists

of

two

core

components

designed

to

be

inserted

into

the

relevant legislation.
Part 1: New Definition in the Corporations Act 2001
The first component is the creation of a positive legal definition for the new asset class. This
would

involve

proposing

a

new

definition

for

insertion

into

the

primary

definitions

section

of

the

Corporations

Act

2001

(section

9

or

761A).

The

proposed

wording

is:

regenerative asset means a digital representation of value that:
(a) serves as a digital receipt for a verified, non-financial contribution of time,
effort,

or

resources

to

community,

ecological,

or

social

well-being;

and

(b) is earned by a person through such a verified contribution and is not offered
to

the

public

primarily

for

the

purpose

of

a

passive

financial

investment

or

with

the

expectation

of

profit

derived

from

the

managerial

efforts

of

a

promoter

or

third

party;

and

(c) is not a non-cash payment facility within the meaning of section 763D.
This definition is carefully crafted to be both precise and principles-based. It anchors the
asset

in

its

pro-social

purpose

(subsection

a),

distinguishes

its

issuance

method

from

that

of

a

security

or

investment

product

(subsection

b),

and

explicitly

separates

it

from

payment

systems

(subsection

c).

Part 2: Exclusionary Clause in the Draft Digital Asset Platforms Bill 2025
The second component is an exclusionary clause to be inserted into the section of the new
Bill

that

defines

a

'digital

asset

platform'.

This

ensures

that

while

Regenerative

Assets

are

legally

recognised,

the

protocols

that

facilitate

them

are

not

captured

by

the

custodial

AFSL

regime.

The

proposed

wording

is:

A facility is not a digital asset platform to the extent that it is a facility for
holding,

or

facilitating

the

use

of,

a

regenerative

asset.

This dual-pronged approach is legally robust. It first establishes 'Regenerative Asset' as a
distinct

legal

concept

within

the

foundational

law

of

Australian

financial

services.

It

then

uses

that

new

definition

to

explicitly

and

cleanly

carve

it

out

from

the

specific

custodial

regime

being

created

by

the

new

Bill.

This

creates

the

necessary

legal

space

for

a

separate,

more

appropriate

regulatory

framework

to

be

developed

for

this

unique

asset

class.


Table 2: Proposed Amendments to Australian Legislation

Act / Bill Section for Amendment
Proposed New / Amended Language
Strategic Rationale
Corporations Act 2001
Section 761A (Definitions)
Insert a new definition: " regenerative asset means a digital representation of value that: (a) serves as a digital receipt for a verified, non-financial contribution...; and (b) is earned by a person... and is not offered to the public primarily for the purpose of a passive financial investment...; and (c) is not a non-cash payment facility..."
Creates a clear, positive legal definition for the C-hour and similar assets within the principal Act. This anchors their legal status in their pro-social purpose and non-financial nature, providing a durable foundation for their regulation.
Treasury Laws Amendment (Regulating Digital Asset, And Tokenised Custody, Platforms) Bill 2025
Section defining 'digital asset platform' (e.g., proposed s763F of the Corporations Act )
Insert a new exclusionary sub-clause: "A facility is not a digital asset platform to the extent that it is a facility for holding, or facilitating the use of, a regenerative asset."
Legally separates Regenerative Asset protocols from the AFSL regime designed for custodial, speculative platforms. This prevents the application of an inappropriate and burdensome regulatory

framework and creates the clear policy need for a new, 'fit-for-purpose' alternative.
Corporations Act 2001
Chapter 7 (New Part)
Add a new Part: " Part 7.XX — Registration of Regenerative Asset Protocols ". This Part would establish a light-touch registration regime administered by ASIC.
Proactively establishes a bespoke, appropriate regulatory framework. This counters any argument that the carve-out is an attempt to avoid all oversight, positioning the proposal as responsible and committed to consumer protection and governance integrity.

Section 3.3: Proposed Regulatory Framework

A legislative strategy that merely creates a carve-out without proposing an alternative form of
oversight

is

politically

vulnerable.

It

can

be

portrayed

as

an

attempt

to

create

an

unregulated

'wild

west',

which

runs

counter

to

the

government's

clear

focus

on

consumer

protection.
20
To
pre-empt

this

criticism

and

demonstrate

a

commitment

to

responsible

innovation,

the

carve-out

must

be

paired

with

a

proposal

for

an

alternative,

'fit-for-purpose'

regulatory

framework.

This

framework

should

be

designed

to

address

the

unique

risks

of

Regenerative

Assets,

which

are

related

to

governance

and

verification

integrity

rather

than

custodial

or

market

risk.

The proposed framework would be a 'light-touch' registration regime, not a full AFSL regime.
Protocols

that

issue

or

facilitate

Regenerative

Assets,

such

as

the

C-hour

protocol,

would

be

required

to

register

with

ASIC.

This

would

provide

regulators

with

visibility

over

the

sector

without

imposing

the

costly

and

inappropriate

compliance

burdens

of

the

AFSL

framework.

Upon registration, the protocol's operators (i.e., the governing DAO or its legal wrapper) would
be

required

to

comply

with

a

set

of

tailored

standards

focused

on

transparency

and

integrity.

These

standards

would

include:
● Integrity of Contribution Verification: The protocol must have clear, publicly disclosed,
and

auditable

rules

and

processes

for

how

contributions

are

verified

and

how

Regenerative

Assets

are

earned.

This

addresses

the

core

risk

of

the

system's

integrity

and

ensures

that

assets

are

genuinely

linked

to

pro-social

work.
● Governance Transparency: The protocol must publicly disclose its governance
framework.

This

includes

the

rules

of

the

governing

DAO,

how

proposals

are

made

and

voted

upon,

how

the

protocol's

treasury

is

managed,

and

the

rights

of

asset

holders

within

the

governance

system.

This

provides

participants

with

a

clear

understanding

of

how

the

system

is

controlled

and

can

be

changed.
● Consumer Information and Disclosure: The protocol must provide users with a clear,
concise,

and

easy-to-understand

'Protocol

Statement'.

This

document,

analogous

to

the

Bill's

'Platform

Guide',

would

not

be

a

financial

product

disclosure

statement

(PDS).

Instead,

it

would

outline

the

protocol's

purpose,

the

nature

of

the

Regenerative

Asset,

the

specific

goods,

services,

or

benefits

for

which

it

can

be

redeemed,

the

risks

associated

with

participation

(e.g.,

governance

failure,

smart

contract

risk),

and

the

dispute

resolution

process.

This proposed framework achieves the ideal balance. It removes Regenerative Assets from a
regulatory

regime

designed

for

speculative

financial

products

while

establishing

a

new

regime

that

is

precisely

tailored

to

their

unique

characteristics

and

risks.

It

ensures

accountability

and

protects

participants

while

fostering

the

growth

of

this

powerful

new

model

for

social

and

ecological

innovation.


Part IV: A Multi-Pronged Advocacy and Engagement
Strategy



Section 4.1: Navigating the Parliamentary Process

A sophisticated legislative proposal requires an equally sophisticated and strategically timed
advocacy

campaign.

The

objective

is

to

guide

the

'Regenerative

Asset'

amendment

through

the

key

inflection

points

of

the

Australian

parliamentary

process,

building

a

broad

coalition

of

support

at

each

stage.

The

strategy

must

be

proactive,

engaging

with

the

policy

development

process

before

the

Bill

is

finalised,

and

adaptable,

preparing

for

engagement

throughout

the

legislative

journey.

The advocacy campaign will be sequenced according to the following timeline-based
strategy:
1. Immediate (Consultation Phase): The highest leverage opportunity exists now, during
the

public

consultation

period

for

the

exposure

draft

of

the

Digital

Asset

Platforms

Bill

2025
.

The

immediate

priority

is

to

finalise

and

lodge

a

comprehensive

submission

with

the

Australian

Treasury.

This

submission

will

be

the

formal

vehicle

for

the

arguments

and

draft

legislative

text

detailed

in

Parts

II

and

III

of

this

report.

It

will

be

framed

as

a

constructive

contribution

aimed

at

enhancing

and

future-proofing

the

government's

proposed

framework.
2. Short-Term (Pre-Introduction Phase): Following the submission, the focus will shift to
direct

engagement.

The

goal

is

to

secure

briefings

with

the

senior

ministerial

advisors

in

the

offices

of

the

Treasurer

(Dr

Chalmers)

and

the

Assistant

Treasurer

(Dr

Mulino).

The

purpose

of

these

meetings

is

to

present

the

proposal

directly,

answer

technical

questions,

and

make

the

political

case

for

why

adopting

this

amendment

strengthens

their

legislation

and

aligns

with

their

core

policy

objectives.
3. Medium-Term (Parliamentary Phase): Once the Bill is finalised by the government and
introduced

into

Parliament,

the

primary

focus

of

advocacy

will

shift

to

the

Senate,

specifically

the

Senate

Economics

Legislation

Committee,

which

will

conduct

an

inquiry

into

the

Bill.

This

phase

will

involve

preparing

a

supplementary

submission

for

the

committee,

seeking

to

appear

and

provide

testimony

at

public

hearings,

and

engaging

directly

with

the

offices

of

all

committee

members,

with

a

particular

focus

on

the

Chair,

Senator

Darmanin.
4. Contingency (Amendment Phase): If the government does not adopt the proposed
amendments

in

its

own

version

of

the

Bill,

the

strategy

will

shift

to

having

the

amendments

moved

in

the

Senate.

This

will

involve

working

closely

with

identified

parliamentary

champions—such

as

Senator

Bragg

from

the

Coalition

and

Senators

from

The

Australian

Greens—to

have

our

proposed

legislative

text

formally

moved

as

amendments

during

the

committee

stage

of

the

debate

in

the

Senate

chamber.

This

requires

building

the

cross-party

support

necessary

to

ensure

the

amendments

have

a

realistic

chance

of

passage.

This phased approach ensures that influence is applied at every critical juncture, from the
initial

policy

formulation

within

the

executive

to

the

final

legislative

debate

in

the

parliament.