Supplementary Report: Registration as an alternative to licensing

Abstract

This supplementary report adds to the University of Sydney Centre for AI, Trust, and Governance report of 4 February 2026. That report (Report) had the title “Australia’s Right to Regulate Technology: A proposal for reform”. The Report proposed licensing of platforms as a key mechanism. Feedback on the Report has suggested that the appetite for a licence regime would be greater if there was a simpler first step. It would be essential that this step could achieve the same outcomes as a licensing regime. These are: (a) an entity in Australia that can sue or be sued; (b) a link between that entity and products and services provided in Australia; and (c) an assurance that the entity has the financial capacity to pay for the consequences of any legal or regulatory action taken against it. This supplementary report outlines an approach to registration as an alternative to licensing.