Below is a practical, compliance-first checklist and technical plan for custom software development targeted at financial services in Australia — covering the regulatory guardrails, key integrations, security and architecture best practices, delivery steps, and ballpark timelines/costs.

Executive summary

• Primary non-negotiables for fintechs and financial institutions in Australia: APRA prudential requirements for regulated entities (esp. CPS 234 on information security), AML/CTF obligations, the Privacy Act / Australian Privacy Principles (APPs), Consumer Data Right (CDR / “Open Banking”) rules for data sharing, and banking/payment-rail rules (e.g., NPP/PayID). (handbook.APRA.gov.au, AUSTRAC.gov.au, OAIC.gov.au, Treasury.gov.au, AusPayPlus.com.au)

Regulatory & compliance checklist (must-address items)

• APRA CPS 234 (information security) — for APRA-regulated entities: asset classification, life‑cycle controls, testing, incident response and Board-level responsibility. Ensure controls (including third parties) meet CPS‑234 expectations. (handbook.APRA.gov.au)
• AML/CTF (AUSTRAC and related Amendment Act): implement a documented, risk‑based AML/CTF program, appoint an AML/CTF compliance officer, and follow reporting obligations. Note major reforms with outcome-focused program requirements coming into force per government guidance (see AUSTRAC/Attorney‑General guidance for transition dates). (AUSTRAC.gov.au, ag.gov.au)
• Privacy Act / Australian Privacy Principles (APPs): privacy-by-design, clear privacy policy, manage cross-border disclosures, data subject access/correction, retention, and breach notification. (OAIC.gov.au)
• Consumer Data Right (CDR / Open Banking): if you’re a data holder or an accredited data recipient, implement CDR rules, accreditation, secure APIs and accurate data provisioning. The ACCC/Treasury administer CDR rules and accreditation processes. (accc.gov.au, Treasury.gov.au)
• Licensing (ASIC / AFSL): if you provide financial advice or deal in financial products, check AFSL obligations and competency/financial-resource requirements. Factor licensing and compliance costs/time into project planning. (asic.gov.au)
• Payments & rails: plan integrations for Australian rails you need — e.g., NPP (real‑time payments / PayID), BPAY, card schemes, and local clearing requirements; each has technical and commercial onboarding steps. (AusPayPlus.com.au)
• Third-party & outsourcing risk: regulators expect you to assess and test third-party controls and to maintain oversight (APRA, OAIC expectations).

Security, privacy and operational controls (concrete items to implement)

• Threat modelling + security requirements up-front (STRIDE/PASTA); map threats to regulated data flows.
• Data classification and minimisation; treat personal & financial data as high sensitivity; avoid using production PII in dev/test (or desensitise it).
• Strong identity & access management: OAuth2/OpenID Connect for APIs, short-lived credentials, MFA for admin access, role-based least privilege.
• Encryption: TLS 1.2+ in transit; field-level encryption for high-value data at rest; KMS/Hardware security modules for keys.
• DevSecOps: integrate SAST/DAST, dependency scanning (SBOM), secret scanning, container image scanning, and automated security gates in CI/CD.
• Logging, monitoring, SIEM, and retention: immutable logs, tamper-evident storage, and alerting mapped to incident response playbooks (CPS 234 requires tested incident response & Board reporting).
• Testing: automated unit/integration tests + regular pen tests, red‑team exercises, and DR/business continuity testing.
• Certifications and audits: ISO 27001 and SOC 2 are commonly requested by enterprise clients/partners — consider them as part of commercial readiness.

Architecture & technology patterns (what works for finance)

• Cloud-first with Australian-region deployments (AWS/Azure/GCP local regions) to simplify data residency & latency; adopt shared-responsibility and contractually require subprocessor visibility for data residency.
• Microservices or modular bounded contexts (Domain‑Driven Design) to isolate sensitive domains (payments, KYC, ledger).
• Event-driven architecture / message queues for resilience and auditability (Kafka/RabbitMQ/managed cloud equivalents).
• Single source of truth ledger for money flows (immutable transactions, audit trail).
• Use strong typing and proven frameworks (Java/.NET/Go/TypeScript) for core payments/ledger logic; pick teams’ strongest stack but prioritize maintainability and testability.
• API-first design and OpenAPI specs; versioned APIs with backward-compatibility guarantees for partners and CDR.

Specific fintech integrations to plan for

• Open Banking / CDR: implement CDR APIs, consent flows, accreditation process and data quality controls. (Treasury.gov.au, accc.gov.au)
• Payments: NPP (real‑time), BPAY, card networks, and settlement — each requires commercial onboarding + technical adapters. (AusPayPlus.com.au)
• Identity & KYC: integrate commercial identity/KYC providers (ID verification, AML screening), and log decision evidence for compliance.

Delivery process & governance (recommended)

1. Discovery & compliance mapping (2–6 weeks): map legal/regulatory obligations to product features and tech controls.
2. Security & architecture sprint (2–6 weeks): produce threat model, data classification, high-level architecture, and sprint backlog with compliance stories.
3. MVP / PoC (3–6 months): core flows, secure APIs, basic compliance controls, sandboxed payments/KYC integrations.
4. Production hardening & audit (2–4 months): pen tests, SOC/ISO readiness, privacy impact assessment, CDR/accreditation prep if required.
5. Ongoing ops & compliance: continuous monitoring, patching, annual reviews, and incident simulation exercises.

Typical timelines & ballpark costs (very approximate)

• Small fintech MVP (KYC + basic payments features): 3–6 months, ~AUD 150k–500k.
• Mid-sized product (production-ready ledger, integrations, compliance hardening): 6–12 months, ~AUD 500k–2M.
• Enterprise/core banking-style platform (full feature set, high assurance, large integrations): 12–36+ months, AUD 2M+. These ranges depend heavily on scope, compliance obligations (e.g., CPS‑234/AUSTRAC complexity), third‑party vendor fees, accreditation/licensing costs, and scale.

Commercial / procurement considerations

• Build vs buy: for high‑assurance controls (KYC, AML screening, payments switch), consider best-of-breed vendors rather than building everything in-house.
• Contracts: include strong SLAs, audit rights, security controls and breach/notification clauses with suppliers/subprocessors; regulators expect oversight.
• Insurance & capital: factor professional indemnity, crime/fraud, and cyber insurance into the budget and the AFSL / prudential expectations where applicable.

Practical next steps (for a new project)

• 1. Do a short (2–4 week) compliance & technology discovery focused on APRA/AML/Privacy/CDR scope mapping.
• 2. Produce an MVP spec that isolates high‑risk areas (payments/KYC/data sharing) and prioritizes compliance-enabled features.
• 3. Run a security baseline (architecture review + threat model + roadmap to CPS‑234 alignment).
• 4. Plan accreditation/licensing timelines early (CDR accreditation, AFSL or other licences take months and have preconditions).

Authoritative references (starting points)

• APRA CPS 234 (Information Security). (handbook.APRA.gov.au)
• AUSTRAC guidance and AML/CTF program reforms (see Attorney‑General / AUSTRAC pages for effective dates and new requirements). (ag.gov.au, AUSTRAC.gov.au)
• OAIC — Australian Privacy Principles (Privacy Act). (OAIC.gov.au)
• Treasury / ACCC — Consumer Data Right (CDR) / Open Banking. (Treasury.gov.au, accc.gov.au)
• NPP / Australia payments infrastructure (AusPayPlus). (AusPayPlus.com.au)

If you want, I can:

• produce a one-page compliance mapping for your exact product idea (which regulations apply to which features), or
• draft an Example Architecture diagram + backlog of compliance user stories (CPS‑234, AML/CTF, APPs + CDR-ready items),
• or estimate a more accurate timeline and budget if you share scope (e.g., payments rails required, CDR participation, expected monthly active users).

Which of those would you like me to prepare next?