How Regulatory Change is Shaping Project Delivery in Fintech

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Australia’s financial services sector is evolving rapidly; from the rise of AI-enabled portfolio tools, digital investor platforms to the growing demand for transparency and personalisation. Beneath this innovation, regulatory change is quietly but fundamentally reshaping how projects are planned and delivered.

For Business Analysts (BAs) and Project Managers (PMs), compliance is no longer just a final-stage checkbox. It is embedded in every sprint, every feature, and every system design. Whether you’re in payments, funds and investments, or capital markets understanding the regulatory landscape is essential to delivering projects.

The Expanding Web of Regulation

Regulatory oversight in Australia is tightening in response to increased digitalisation, complexity and consumer expectations. Key drivers shaping project delivery across financial services include:

  • Consumer Data Right (CDR) – expanding from banking to energy and open finance, impacting data consent, APIs, and privacy
  • ASIC’s Design and Distribution Obligations (DDO) – requiring firms to define target markets and monitor product performance
  • Breach Reporting Reforms (under RG 78) – mandating more timely and transparent reporting of compliance failures
  • Operational Risk Management (CPS 230) – APRA’s new cross-sector standard on operational resilience, applicable from July 2025
  • Greenwashing Crackdown – ASIC’s enforcement of accurate ESG claims in product disclosures and marketing
  • T+1 Settlement Reform – coming in 2026, requiring faster post-trade processes and operational readiness
  • ASIC’s INFO 225 and INFO 269 – guidance on digital advice and the responsible use of artificial intelligence in financial services
  • Data breach obligations under the Privacy Act and the Notifiable Data Breaches (NDB) scheme

These regulatory shifts are not just legal concerns, they influence how platforms are architected, how teams collaborate and how value is delivered.

Five Ways Regulation Is Reshaping Project Delivery

1. AI: Emerging Enabler and Risk

AI is increasingly being used across financial services as a project delivery professional, it’s essential to start building a working knowledge of how these technologies are applied. This is especially important as ASIC has signalled growing expectations around algorithmic transparency, bias management and appropriate use — particularly under licensee obligations (RG 255, RG 274).

In parallel, the Australian Government has proposed 10 guardrails to guide the safe and responsible use of AI. This includes principles such as fairness, privacy protection, accountability and contestability. These guardrails are becoming key reference points for how financial institutions design, deploy and govern AI tools.

BA Insight: This means clearly documenting how AI models operate, what data they rely on and how they align with responsible use standards.

PM Insight: This means allocating time for explainability, model validation and ethical review gates especially in consumer-facing features.

AI tools can assist but must be governed. Always validate AI-generated documentation or insights through legal and compliance SMEs to ensure alignment with both regulatory guidance and ethical expectations.

2. Cross-Functional Regulatory Design

Australia’s regulatory obligations are no longer confined to legal and compliance teams.  They now span across technology, product, UX, data, risk and operations which is why cross functional collaboration is so important. Regulatory change impacts not just what firms build, but how they build it and who needs to be involved.

Take ASIC’s Design and Distribution Obligations (DDO) as an example. DDO requires financial services firms to:

  • Clearly define a Target Market Determination (TMD) for each product
  • Track how customers are actually using the product versus how it was originally intended
  • Take action if the product is being misused or causing harm

This isn’t just a legal compliance issue; it affects how UX is designed, how product usage is tracked through analytics and how data is collected and shared across systems. In other words, it’s a cross-functional challenge.

BA Insight: Capture DDO, AML/CTF, or ESG requirements early in your functional specifications. Don’t treat these as afterthoughts or constraints, treat them as foundational inputs that should shape the product from the beginning.

PM Insight: Bring legal, compliance and risk teams into the delivery process early. Treat them as collaborative partners, not gatekeepers. Create structured touchpoints like joint backlog reviews and sprint checkpoints to help make proactive risk and compliance decisions.

3. Agile + Governance = The New Normal

While fintechs often favour agile for its speed and flexibility, Australian regulators increasingly expect traceable, testable and auditable outcomes. This has led to a rise in hybrid delivery models; agile at the team level, with governance at the program level.

Traditionally, governance was linked to Waterfall delivery, with formal stage gates and approvals at each phase. However, today’s governance focuses on ensuring compliance and traceability without needing to follow a rigid Waterfall structure. Agile teams can integrate regulatory checks into their iterative processes to meet these expectations while maintaining flexibility.

BA Insight: Maintain clear traceability between user stories and regulatory obligations. For example, link user consent stories to CDR and Privacy Act compliance.

PM Insight: Build “regulatory checkpoints” into sprints or milestones. For example, include mandatory legal sign-off before releasing updates that impact product terms, disclosures, or consent flows.

This hybrid approach combines the agility of iterative delivery with the rigor of governance, ensuring compliance without sacrificing speed.

4. Operational Resilience and Readiness (CPS 230)

CPS 230, effective July 2025, requires all APRA-regulated entities to strengthen their controls over critical operations, third-party vendors and incident response. The standard emphasises operational resilience, meaning financial firms must be prepared to continue operations even in the face of disruptions such as cyberattacks, system failures or vendor issues. This places new pressure on projects to build resilience from day one, rather than bolting it on later.

The regulation covers areas like disaster recovery, backup systems and maintaining service continuity for critical functions such as client funds, payments and trading. It also requires companies to assess and manage the risks posed by their third-party vendors, ensuring these external partners are held to the same resilience standards.

BA Insight: Document service criticality and third-party reliance early in your requirements, particularly for products that handle client funds, trading or payments. Ensure resilience requirements are clear and traceable in functional specifications.

PM Insight: Map out dependencies on cloud platforms, data providers or outsourced operations teams. Ensure business continuity and resilience are factored into the early phases of the project, including disaster recovery and incident response plans.

5. Increased Demand for Data Governance and Disclosure

Regulators are placing greater emphasis on data governance and disclosure, expecting real-time visibility and evidence-backed transparency into how firms operate and make decisions. This includes areas like ESG (Environmental, Social, and Governance) transparency, breach reporting and investor disclosures. Fintechs are no longer just required to prove that their products work; they must also demonstrate that these products are fair, responsible and meet their advertised promises.

This means fintechs must provide clear and verifiable evidence that their products align with regulatory expectations and operate in a way that doesn’t mislead or harm customers. This trend is driving increased demand for proper data governance and audit trails to ensure that all claims (especially those related to ESG) are substantiated and can be easily tracked.

BA Insight: Work closely with data and reporting teams to ensure traceability from input data to customer output. Ensure ESG claims are substantiated with verifiable metrics (ASIC’s Info Sheet 271 outlines expectations).

PM Insight: Plan for parallel build and assurance processes. This often means preparing audit evidence in advance of go-live, particularly for products that will be reviewed by APRA or ASIC. Ensure that all regulatory compliance checks are completed and signed off before launch to avoid post-launch issues.

The Expanding Role of Project delivery

In this new era, BAs and PMs are not just delivery professionals; they are risk navigators, regulatory translators and compliance advocates. Core capabilities now include:

  • Interpreting ASIC, APRA and OAIC guidance
  • Translating obligations into functional and non-functional requirements
  • Supporting change impact assessments across people, process, and tech
  • Preparing delivery artefacts for compliance reviews or audits
  • Bridging the knowledge gap between legal, product, data and tech

As innovation in technology finance, AI and consumer expectations accelerates, regulatory pressure in Australia is only intensifying. With the rise of standards like CPS 230, increased expectations around AI governance, ESG disclosures and real-time compliance, the old approach of bolting on regulatory checks at the end is no longer viable.

Today, regulatory design is becoming central to delivery. For Business Analysts and Project Managers, this means shifting from reactive compliance to strategic integration; embedding regulatory thinking into planning, execution and cross-functional collaboration.

Done well, compliance is no longer a blocker. It’s a blueprint for building trust, moving faster and scaling with resilience.

Amaleen Ibrahim – Consultant – LinkedIn

Kapital Consulting is a niche Fintech Recruitment Business specialising in Technology, Project Services and Data Recruitment across Australia. For more information connect with us on www.kapitalconsulting.com.au and follow us on www.linkedin.com/company/kapital-consulting