Skip to main content

Understanding Wholesale Client Status in Australia

Important Notice (May 2025) The information below is a general guide only and does not constitute legal, financial or professional advice. The definitions of a "wholesale client" under the Corporations Act 2001 (Cth) ("the Act") are complex. You must seek independent advice from a qualified financial adviser, accountant or lawyer before representing to Blockport—or to any other service provider—that you qualify. Blockport cannot determine your status for you.

Blockport's Non‑custodial Staking Interface​

Blockport offers the transactional features of its Staking Interface exclusively to clients who qualify as Wholesale Clients under the Act. Whether you meet the criteria is your responsibility. The summary below consolidates the most common pathways to wholesale status found mainly in ss 761G and 761GA of the Act.

A February 2025 Parliamentary Joint Committee review recommended that the monetary thresholds below remain unchanged for the time being, but it also urged Treasury to review them periodically. Consequently, the figures quoted are current as at 8 May 2025 but may change in the future.

How Can You Qualify as a Wholesale Client?​

Meeting any one of the five tests below may be sufficient. This is a simplified overview; the Act prevails where nuances arise.

1. Product Value Test (Price or Value of Financial Product)​

You want to stake at least AUD $500,000.

2. Individual Wealth Test (Net Assets or Gross Income)​

Applies to individuals. You must hold an accountant's certificate that:

  • is issued within the last two years and remains less than two years old at the time it is relied on; and
  • confirms either:
    • net assets ≥ AUD $2.5 million, or
    • gross income ≥ AUD $250,000 per annum for each of the last two financial years.

3. The 'Sophisticated Investor' Test (Experience‑based)​

Under s 761GA, an Australian Financial Services (AFS) licensee may treat you as wholesale without any dollar thresholds if:

  1. You can satisfy on reasonable grounds that, based on your investing experience, you can assess:
    • the merits of the product or service;
    • its value;
    • the risks involved;
    • your own information needs; and
    • whether the information provided is adequate.
  2. You receive from us, a written statement of those reasons before or at the time the service is provided.
  3. You sign a written acknowledgement that you will be treated as a wholesale client and understand the reduced retail‑client protections.

4. Professional Investor Test​

You are automatically wholesale if you are a "professional investor" (Act s 9). Common examples include:

  • An AFS licence holder.
  • A body regulated by APRA (e.g. banks, insurers, most super fund trustees).
  • A body registered under the Financial Sector (Collection of Data) Act 2001.
  • A trustee of a superannuation fund, approved deposit fund, pooled superannuation trust or public‑sector super scheme with net assets of at least AUD $10 million.
  • A person who controls at least AUD $10 million (including amounts held by associates or under trusts you manage).
  • A listed entity or a related body corporate of a listed entity.
  • An exempt public authority.
  • A body corporate or unincorporated body that carries on an investment business in financial products, interests in land or other investments using funds raised from the public.

5. Business Test​

You qualify if the product or service is provided for use in connection with a business that is not a small business.

Small business means a business that employs fewer than 20 people, or fewer than 100 people if it manufactures goods (Act s 761G(12)).

Why Wholesale Client Status Matters for Blockport​

Blockport's Staking Interface is structured on the basis that Wholesale Clients are presumed to have greater financial sophistication and risk tolerance. Accordingly, only clients classified as wholesale may access transactional features such as creating or managing stake accounts.

When you apply for whitelisting, you will be asked to confirm that you meet at least one of the Wholesale Client tests. It is your responsibility to ensure that representation is accurate and up to date.

Consequences of Being a Wholesale Client​

Wholesale Clients generally receive fewer statutory protections than retail clients. For example:

  • You may not receive a Product Disclosure Statement (PDS), a Financial Services Guide (FSG) or ongoing disclosure that would otherwise be required.
  • You may have limited access to certain external dispute‑resolution (EDR) schemes.
  • Some unsuitable‑advice provisions do not apply.

Make sure you understand these consequences before you represent yourself as wholesale.

Next Steps​

  1. Assess your status against the tests above (with professional advice if needed).
  2. If you qualify and wish to use Blockport's transactional staking features, complete the whitelisting application on our website or email [email protected].
  3. Retain all supporting evidence (e.g. accountant's certificates, signed acknowledgements) for your records.

Disclaimer​

This document is a summary only. The full legal definitions are contained in the Corporations Act 2001 (Cth). Blockport does not provide legal or financial advice and is not responsible for your assessment of your client classification.

Document last reviewed: 8 May 2025