This regulatory analysis will delve into the background of action initiation in Australia, as well as the wider context that drives the nature and speed of CDR-related proposals. It will also map out the relevant legislative and authorities framework applicable to the CDR. Furthermore, the analysis will provide a detailed examination of the proposed action initiation regime, with its multiple layers and new types of licensed CDR-participating entities. It will explore the possible implications of the proposed measures for the payments industry, including the potential for increased competition, business growth and need for compliance.