Financial Services Guide

Before using Canvas Prime

You should read this FSG carefully, together with the Canvas Prime terms of service and any other document we give you, before using the Canvas Prime service.

This FSG is issued to wholesale clients only. Canvas Digital does not provide Canvas Prime, or any other financial service, to retail clients under the ERS exemption. "Wholesale client" has the meaning given in section 761G of the Corporations Act 2001 (Cth), as further explained in the Canvas Prime onboarding materials provided to you before you receive the Canvas Prime service.

Corporate relationship

Canvas Digital is a wholly-owned subsidiary of Canvas Technology Group Pty Ltd.

The ERS exemption

The ERS Regulations allow eligible new financial-services businesses to test defined financial services for a limited period (up to 24 months) without holding an AFSL, subject to scope and exposure limits and the conduct conditions in Part 5 of the ERS Regulations. Canvas Digital has lodged the notification required by reg 16 with ASIC and the exemption from s911A of the Corporations Act 2001 (Cth) is in force for the Canvas Prime service.

• Date of notification lodged with ASIC: 30 April 2026
• Date of ASIC ERS letter granting the exemption: 28 May 2026
• Date exemption commenced: 30 May 2026
• Scheduled end of testing period: 29 May 2028 (24 months, non-extendable)
• AFSL application status: Application in progress. Canvas Digital will hold an AFSL on grant.

Financial services provided under the exemption

Canvas Prime is a non-cash payment facility (NCPF) within the meaning of s763D of the Corporations Act 2001 (Cth). The financial services Canvas Digital provides in connection with Canvas Prime under the ERS exemption are:

• Dealing in an NCPF by issuing, varying and disposing of the Canvas Prime NCPF, as principal; and
• Providing general financial product advice in relation to the Canvas Prime NCPF and foreign exchange contracts in connection with AUD/USDT conversion and cross-border payments.

Scope of authorisation

These are the only financial services Canvas Digital is authorised to provide under the ERS exemption. Nothing in this FSG, in our marketing material, or in any communication from our personnel should be read as an offer to provide a financial service outside that scope.

What Canvas Prime does not include

For the avoidance of doubt, Canvas Digital does not under the ERS exemption:

• provide personal financial product advice. Only general advice is provided. We do not consider your personal objectives, financial situation or needs when providing general advice;
• operate, or invite investment in, a managed investment scheme, fund or pooled investment vehicle;
• issue any debit card, credit card or merchant-acquiring product;
• deal in derivatives, margin lending facilities, securities, interests in managed investment schemes, or any other financial product outside the Canvas Prime NCPF and FX scope set out above;
• make a market in any financial product; or
• carry on a banking business or hold an Australian banking licence.

Limits that apply because we operate under the exemption

Because Canvas Digital operates Canvas Prime under the ERS exemption, the following statutory limits apply:

• Scope limit (wholesale only). Canvas Digital may only provide the Canvas Prime service to wholesale clients, within the categories permitted by reg 10 of the ERS Regulations. Retail clients are out of scope.
• Aggregate exposure cap (A$5 million). Across all clients (and any related body corporate relying on an ERS-equivalent exemption), the aggregate exposure cap of A$5 million in reg 13 of the ERS Regulations applies. For Canvas Prime, this is measured against the value of NCPF arrangements issued.
• Testing period. The exemption is available only during the testing period (30 May 2026 to 29 May 2028). The testing period cannot be extended.

Consequences of exceeding a limit

If the aggregate cap is exceeded, or any other condition of the ERS exemption is not met, the exemption ceases automatically (see cease-events below).

Cease-events and notification

The following events are the "cease-events" referred to in Part 3(e) of this FSG. If any of these events occurs, Canvas Digital will notify you in writing within 10 business days (reg 19 of the ERS Regulations):

• 1. Canvas Digital fails to meet a scope limit in reg 10, causing the exemption to cease automatically (regs 9 and 10).
• 2. Canvas Digital fails to meet the aggregate A$5 million exposure cap in reg 13 (regs 9 and 13).
• 3. Canvas Digital ceases to be an "eligible person" for the service, for example by becoming licensed for the service or by becoming an authorised representative for the service (reg 6, Note 2 / definition of "eligible person" in reg 5).
• 4. ASIC decides under reg 14 to cancel the exemption.
• 5. Canvas Digital lodges a notice with ASIC under reg 15 cancelling the exemption from a specified date.

AFSL grant and contact details

If Canvas Digital is granted an AFSL covering the Canvas Prime service before the testing period ends, the exemption will cease automatically under the eligible-person test in reg 5 and we will notify you in writing.

We will send the notice to the postal or email address you have most recently given us in writing. It is your responsibility to keep your contact details up to date.

6.1 Remuneration

Canvas Digital is remunerated for the Canvas Prime service as follows:

• The current fee schedule will be provided to you at onboarding and is available on request at compliance@canvas.co.
• We do not receive commissions or other benefits from any third party in connection with the service.
• We do not pay referral fees to any third party in connection with the service.
• Our employees are remunerated by salary and may receive performance-linked variable remuneration. They do not receive product-specific commissions.
• A copy of our current fee schedule is available on request.

6.2 Associations and relationships

• Canvas Digital is a wholly-owned subsidiary of Canvas Technology Group Pty Ltd.
• National Australia Bank (NAB), holding AUD client funds in an omnibus client trust account;
• Banking Circle, providing cross-border settlement infrastructure with segregated client accounts;
• Fireblocks as wallet infrastructure for the USDT leg of Canvas Prime; and
• Bridge Ventures LLC, providing API and orchestration infrastructure for stablecoin on-ramp / off-ramp and conversion.
• None of these relationships changes the basis on which we provide Canvas Prime under the ERS exemption.

Internal dispute resolution (reg 20)

Canvas Digital maintains an internal dispute resolution process (see Part 8).

Compensation arrangements (reg 20)

The compensation-arrangements requirement under s912B of the Corporations Act applies only to financial services provided to retail clients. It is not statutorily required while Canvas Digital provides Canvas Prime to wholesale clients only under the ERS exemption. As a matter of good practice, Canvas Digital maintains professional indemnity insurance covering the Canvas Prime service.

Client money obligations (reg 22)

Canvas Prime client AUD is held in a client trust account in compliance with Division 2 of Part 7.8 of the Corporations Act (as modified by reg 22). AUD held with National Australia Bank (NAB) is held in an omnibus client trust account, with Canvas Digital maintaining the internal client ledger and reconciliation cadence. AUD held with Banking Circle for cross-border settlement is held in segregated client accounts on a per-client basis. Client USDT is held in Fireblocks wallet infrastructure operated by Canvas Digital.

Financial product disclosure obligations (reg 23)

A Product Disclosure Statement is not applicable. Canvas Prime is offered to wholesale clients only, who are excluded from the PDS regime under s1012D and related provisions of Part 7.9 of the Corporations Act. Wholesale-client information is provided through the Canvas Prime terms of service and onboarding materials.

Make-good orders (reg 24)

Canvas Digital will comply with any make-good order made by a court under reg 24.

External dispute resolution

Canvas Digital is a member of the Australian Financial Complaints Authority (AFCA). Canvas Digital's AFCA Member Number is 123536 and membership commenced on 24 June 2026.

AFCA membership under s912A(2) of the Corporations Act is required only for financial services provided to retail clients. Because Canvas Digital provides Canvas Prime to wholesale clients only under the ERS exemption, AFCA membership is not statutorily required at this stage. Canvas Digital has obtained AFCA membership in connection with its AFSL application and to support a consistent external dispute resolution posture from grant of the AFSL.

Under the AFCA Rules, AFCA's jurisdiction in respect of a complaint by a wholesale client about a financial service provided to that client in its wholesale capacity is limited. Accordingly, while Canvas Digital is an AFCA member, AFCA may not be available to you as an external dispute resolution forum in respect of the Canvas Prime service while you receive that service as a wholesale client under the ERS exemption.

If you remain dissatisfied with our response, you may pursue any other rights you have at law or under your Canvas Prime terms of service.

AFCA contact details

• Australian Financial Complaints Authority
• GPO Box 3, Melbourne VIC 3001
• Telephone: 1800 931 678
• Email: info@afca.org.au
• Website: www.afca.org.au

Tax File Number and Australian Business Number collection

Canvas Digital is authorised under Part VA of the Income Tax Assessment Act 1936 (Cth), the Taxation Administration Act 1953 (Cth) and the Tax File Number Guidelines 2011 to ask you to quote a Tax File Number (TFN) or, where applicable, an Australian Business Number (ABN) in connection with the Canvas Prime service. You will be asked to do so during onboarding through the Canvas Prime Wholesale Investor Questionnaire. Quotation is voluntary. If you do not quote a TFN, an ABN where applicable, or claim a valid exemption category, Canvas Digital is required to withhold tax from any payment to which TFN withholding applies at the top marginal tax rate plus the Medicare levy and to remit the amount withheld to the Australian Taxation Office. If you are a non-resident for Australian tax purposes, you are not required to quote a TFN; non-resident withholding tax may apply to payments to you under Subdivisions 12-F and 12-FB of Schedule 1 to the Taxation Administration Act 1953 (Cth) instead. Canvas Digital handles TFN information in accordance with the Privacy (Tax File Number) Rule 2015 and the Canvas Group Privacy Policy.

For privacy queries, please contact privacy@canvas.co.