Australia Apple Pay review findings released on October 6 put NFC access, wallet fees and payment routing at the center of a possible regulatory intervention. The Reserve Bank of Australia summarized 75 stakeholder submissions before selecting its payment-system priorities.
The RBA said it would publish those priorities by the end of 2026. Further consultation on chosen issues is expected from mid-2027, meaning today’s paper starts a selection process rather than imposing new rules.
Key Insights
- The Australia Apple Pay review found broad support among stakeholders for fair access to iPhone NFC functions.
- Apple said more than 125 Australian financial institutions support Apple Pay and disputed the case for wallet-specific regulation.
- The RBA will identify regulatory priorities by year-end, with further consultation planned from mid-2027.
The most consequential question is whether mobile-wallet operators should face access, transparency or price obligations. Stakeholders also raised American Express fees, BNPL costs and gaps in account-to-account payments.
Australia Apple Pay Review Puts NFC Access First
Many stakeholders asked the RBA to prioritize mobile wallets, particularly Apple Pay. They argued that a device maker controlling both hardware and the native wallet can influence how rivals access phone functions.
Submissions focused on near-field communication, which lets a phone communicate with a contactless terminal. Some respondents described Apple’s NFC and Secure Element access terms as commercially unattractive or too restrictive for rival wallets.
The submissions contrasted Australia with Europe, where Apple provides fee-free access to host card emulation. Stakeholders said that arrangement had enabled competing wallets to offer different functions.
Most respondents favoring intervention proposed fair, reasonable and non-discriminatory access. Some also wanted coverage extended to wearable devices and limits on contractual or technical conditions that could weaken access in practice.
Apple rejected wallet-specific regulation. The company told the RBA that Apple Pay is network-neutral and available to institutions on equal terms, with more than 125 Australian financial institutions supporting the service.
Apple also said its NFC and Secure Element platform had been available to authorized Australian developers since October 2024. It argued that wallet transactions record materially lower fraud rates than the wider industry.
The disagreement makes market access more important than simple availability. A technical interface may exist while commercial terms still determine whether a rival can build a viable product.
Wallet Fees Add a Second Regulatory Question
The Australia Apple Pay review also examined fees paid by card issuers. Several stakeholders said transaction fees had not fallen despite higher volumes and lower unit costs.
They proposed collecting and publishing fee data, removing contractual disclosure restrictions and considering controls if charges did not reflect costs. Apple said its fees had not increased since launch and reflected security and service value.
Apple further said it charges a uniform fee across issuers. Its bilateral contracts do not permit unilateral fee increases, according to the submission summary.
That dispute places transparency before price controls. Regulators would need comparable fee and cost information before deciding whether pricing reflects market power or normal commercial negotiation.
| Payment area | Evidence highlighted | Possible response raised |
|---|---|---|
| Mobile wallets | NFC access and undisclosed issuer fees | Access terms and fee transparency |
| American Express | Nearly one-quarter of 2024 credit and charge value for three-party networks | Outcome-based or equivalent regulation |
| Buy now, pay later | Average merchant fee near 3% in 2025 | Fee disclosure and surcharge-rule review |
| Account-to-account | Access, interoperability and refund gaps | Standards and governance changes |
American Express and BNPL Broaden the Review
The RBA paper extends beyond Apple. Stakeholders said three-party card networks accounted for almost one-quarter of Australian credit and charge-card transaction value in 2024.
Some respondents argued that American Express competes with regulated four-party networks without equivalent interchange restrictions. American Express and industry groups countered that its integrated structure is different and provides useful competition.
BNPL fees produced another cost question. The RBA cited estimates that average BNPL merchant fees were about 3% in 2025, roughly three times the average fee for four-party cards.
However, BNPL represented only about 2% of Australian retail payments in 2025. Opponents of additional rules said its scale did not justify priority treatment after consumer-credit regulation took effect in June 2025.
Those payment-rail questions differ from the securities-market issues in Fusion’s SEC tokenized stock rules analysis. Both cases show regulators testing whether existing categories still fit technology-led products.
They also contrast with Europe’s issuer-focused approach covered in Fusion’s USDAU stablecoin launch under EU rules. Australia’s paper focuses on access, fees and routing across established retail rails.
What Happens Next for Australia Apple Pay Rules
No Apple Pay rule changed on October 6. The RBA must first choose which issues warrant formal work under its competition, efficiency and financial-stability mandate.
The review also considers account-to-account payments. Non-bank providers described costly access, opaque sponsorship terms, inconsistent PayTo implementation and weak refund or dispute protections.
These problems matter as payment products increasingly overlap. Fusion’s report on a Treasury-based ETF tied to stablecoin reserve rules shows how payment infrastructure can connect with regulated investment products.
The immediate catalyst is the RBA’s year-end priority list. That document should reveal whether Apple Pay access and fees advance to formal consultation, remain under monitoring or give way to broader payment-network reforms.




