What was broken
A fintech startup building a financial-advisory platform for small businesses needed early capital to build and reach its market.
What we did
CapEasy shaped the seed fund application — market-gap sizing, a utilisation plan, and financial projections aligned to the raise.
We structured the proposal to the scheme’s eligibility requirements.
A seed fund approval is the reviewing committee’s sanction; actual disbursement follows the scheme’s due-diligence and compliance milestones and is not guaranteed.
Where it landed
The startup secured approval from a public seed fund program.
Fintech has no R&DTI sector guide — which makes the software test decisive
business.gov.au publishes six sector guides for the R&D Tax Incentive: agrifood, biotechnology and medical sciences, built environment, energy, manufacturing, and software development. There is no fintech or financial services guide. That is not an oversight to wait out — it means a fintech's R&D claim gets tested against the software development guide's general bar: an activity is core R&D only when the team hits a genuine technical hurdle that no existing knowledge, method or solution can resolve, tested through a hypothesis-driven experiment. For a platform built on top of established financial infrastructure — payment rails, credit bureau feeds, accounting-software integrations — the recurring dispute is the same one AusIndustry sees across the sector: wiring a documented third-party API into a new UI is integration, not R&D, on its own; building an underwriting model or a reconciliation engine that no published method already solves can clear the bar.
The mechanics underneath that test have not moved: a company with aggregated turnover under $20 million claims the refundable offset — its company tax rate plus an 18.5% premium; a company at or above $20 million claims the non-refundable offset, at an 8.5% premium on R&D spend up to 2% of total expenditure and 16.5% above that. The premium component caps at $150 million of notional R&D deductions a year, and registration with the Department of Industry, Science and Resources through the R&DTI customer portal is due within 10 months of the end of the income year the activities were conducted in. The 2026–27 Federal Budget flagged further changes to the program starting 1 July 2028, but the current settings above still govern every registration lodged before then — check the confirmed detail with your registered tax agent closer to the date rather than planning against an announcement.
ASIC's Enhanced Regulatory Sandbox: test before you're licensed, not instead of records
ASIC runs the fintech-specific route founders usually mean by "regulatory sandbox": the Enhanced Regulatory Sandbox (ERS), administered through ASIC's Innovation Hub. Under the Corporations (FinTech Sandbox Australian Financial Services Licence Exemption) Regulations 2020 and the equivalent credit-licence regulations, an eligible fintech can test defined financial services or credit activities against defined products for up to 24 months without first holding an Australian Financial Services Licence or Australian Credit Licence. Use of the exemption is by notification, not automatic approval — ASIC reviews what is submitted and can reject a notification that is incomplete or falls outside the eligible service and product list set out in Information Sheet 248. The Innovation Hub's informal guidance, taken before lodging, is what most fintechs use to confirm eligibility rather than finding out from a rejection.
The 24 months is a licensing exemption, not an accounting one. A platform testing under the ERS is still building the same evidentiary record everyone else is: which activity was tested, on which cohort, for how long, and what changed as a result — because the exemption window closes on a clock and the AFSL or ACL application that follows it will ask what the sandbox period actually demonstrated. That record and the R&D substantiation record are usually the same underlying ledger, tracking the same experiments by date.
Project accounting is what turns a claim into an export, not a reconstruction
business.gov.au's record-keeping guidance for the R&DTI is explicit that records should be created at the time the R&D activity happens and kept for five years after the expenditure is claimed, with a cost allocation showing which activities the spend relates to. For a fintech, the artefacts that satisfy that test are usually already sitting in engineering and product tools rather than a compliance folder: model iteration logs and backtesting results for a scoring or underwriting engine, the written case for why a documented integration pattern didn't resolve a problem, and the experiment plan and results behind it. What is missing more often than the artefacts themselves is the accounting layer tying them to spend — a chart of accounts that separates R&D-coded engineering time and infrastructure cost from ordinary operating expense, reconciled monthly rather than reconstructed against a calendar six weeks before the 10-month registration deadline.
CapEasy's part in this is the utilisation plan, the projections, and the ledger tied to the activity — the same discipline behind this engagement's SISFS application, applied to whichever Australian instrument is in front of a founder: an R&DTI registration, an ERS notification, or a state or Commonwealth grant sourced through the business.gov.au grants finder. The eligibility determination, the licensing exemption decision, and the lodgment itself are prepared for your registered BAS or tax agent, and for ASIC where a sandbox notification or licence application is involved — those calls sit with the regulator and the agent, never with the preparer.
What to take from it
- There is no fintech or financial-services sector guide for the R&D Tax Incentive — claims get tested against the software development guide's technical-hurdle bar, and integrating a documented third-party API is the pattern AusIndustry disputes most.
- Current R&DTI rates: refundable offset (turnover under $20m) at company tax rate plus 18.5%; non-refundable offset (turnover $20m+) at 8.5% up to 2% R&D intensity and 16.5% above it, capped at $150m of notional deductions, registered within 10 months of year-end.
- ASIC's Enhanced Regulatory Sandbox exempts eligible financial services or credit activities from an AFSL or ACL for up to 24 months — by notification and Innovation Hub review, not automatic approval.
- The sandbox's 24-month clock and the R&D substantiation record run on the same evidence: what was tested, when, on whom, and what changed — keep one ledger, not two.
- A chart of accounts that separates R&D-coded time and infrastructure spend from ordinary opex, reconciled monthly, is what makes a registration or licence application an export instead of a reconstruction — and everything here is prepared for your registered BAS or tax agent, and for ASIC where a licence or sandbox filing is involved, to lodge.