Australian Gift Card
Market Opportunity
Capturing Market Share in Regulatory Chaos
The $10.9 Billion Market in Panic
AML/CTF Amendment Bill 2024 — Effective March 2026
Gift cards designated as “value transfer services” with mandatory KYC for all purchases. Non-compliant providers will be forced to exit.
Industry Unprepared
12-18 months needed to build compliance infrastructure. Most providers calling it “impractical and unnecessary.”
Products Affected by New Regulations
Open-Loop Prepaid
Visa/Mastercard Gift Cards
Semi-Open Loop
Mall/Shopping Centre Cards
Corporate Incentive
Employee Rewards & Loyalty
Reloadable Cards
Multi-use stored value cards
All products require full KYC compliance by March 31, 2026
The Opportunity
Market Segments
Why Now: Blood in the Streets
“Make hay while there is chaos and blood on the streets.”
Market Tailwinds
Digital-First Consumer Shift
69% of gift cards are now digital. Post-COVID acceleration in e-gifting creates perfect timing.
Corporate Market Expansion
54% B2B segment growing rapidly for employee rewards, incentives & loyalty programs.
Regulatory Moat
AML/CTF compliance creates 12-18 month barrier to entry. First movers capture share from exiting players.
Competitor Chaos
Blackhawk Network
Physical card focus, legacy technology, no KYC infrastructure built
Digital-first platform, KYC-ready
Prezzee
10% workforce reduction, signalling potential exit from Australia
Committed to AU market, compliance-ready
InComm / TCN
Retail distribution model incompatible with KYC requirements
Direct digital delivery, no retail dependency
Incumbent Landscape
Blackhawk Network (BHN)
- •Global leader, 400K+ consumer touchpoints
- •Revenue: Retailer fees + $2.95/card activation
- •Foreign transaction fees: 3%
EML Payments (ASX: EML)
- •$227M revenue (FY25), $1.8B+ gross debit volume
- •Revenue: 4.5% yield on volume (fees, breakage, interest)
- •ASX-listed, recent board turmoil and CEO turnover
InComm Payments
- •Acquired TCN for ~$70M
- •Revenue: Retailer distribution + transaction fees
Physical Card Providers
- •Shopping centre cards, retail chains
- •No digital infrastructure
Shouta + Kobble: The Only Compliant Solution
Shouta
B2C Platform
- 55,000+ customers
- 300+ B2B clients
- Best-in-class reloadable gift card product
- 100% breakage retention on direct B2C
Kobble
Infrastructure
- Built to power Shouta-style clients
- Mastercard Principal Issuer
- AFSL 545391 & AUSTRAC registered
- Full KYC/AML infrastructure ready
- 4-12 week deployment for new clients
Why We Win
Regulatory-First Architecture
Built as regulated financial infrastructure from day one — KYC, AML and controls are native, not retrofitted. Compliance is our foundation, not an afterthought.
Digital-First Experience
Virtual cards, instant issuance, Apple Pay enabled, and fully digital user journeys — not constrained by physical card legacy systems.
Speed to Market
Deploy in 4–12 weeks, compared to 12–18 months with incumbent program managers and sponsor-bank models. Faster time-to-revenue for clients.
Proven Execution & Migration
Successfully migrated Shouta from EML to Kobble — demonstrating production-grade capability and reduced dependency on legacy providers.
Structural Regulatory Moat
AFSL, AUSTRAC registration, and Mastercard Principal Issuer status enable direct control, faster decisions, and long-term regulatory resilience.
White Label Solution
Enable clients to launch their own branded gift card programs using our compliant infrastructure — expanding reach without building from scratch.
Multiple Revenue Streams
| Revenue Line | Description | Typical Rate |
|---|---|---|
| Load Fees | Fee per card load | $2-5 per card |
| Transaction Fees | % of transaction value | 1.5-2.5% |
| Platform Fees | Monthly SaaS fee per client | $5K-25K/month |
| Breakage | Unredeemed balances | 17.5% |
| Setup/Integration | One-time onboarding | $25K-100K |
| Card Issuance | Per-card production (virtual) | $0.50-1.50 |
Breakage Opportunity
Breakage rate of 17.5% on total volume.
Breakage revenue at $1.09B volume (Base scenario) with 17.5% breakage
Year 1 Financial Projections
Annual revenue projections at maturity (approx. 18 months from investment)
| Metric | Conservative | Base | Aggressive |
|---|---|---|---|
| Market Share | 3% | 10% | 20% |
| Annual Volume | $327M | $1.09B | $2.18B |
| Total Card Balance (Float) | $57M | $191M | $381M |
| Transaction Revenue (2%) | $6.5M | $21.8M | $43.6M |
| Breakage Revenue (17.5%) | $57.2M | $190.7M | $381.5M |
| Float Yield (4.5%) | $2.6M | $8.6M | $17.2M |
| Platform/Other | $1.5M | $5M | $10M |
| Total Annual Revenue | $67.8M | $226.1M | $452.3M |
| Investment Required | $2.5M | $8.3M | $16.5M |
Revenue vs Investment by Scenario
Use of Funds
Execute Kobble & Shouta revenue strategy
Platform capabilities & AI integration
Migration & onboarding specialists
Key hires: Sales, integration, client success
Reserve & float requirements
Proven Track Record
Key Milestones
- Successful EML migration
- Multiple inbound enquiries post-regulation
- Insurance, payments & corporate clients onboarded
Regulatory Moat
AFSL 545391
Australian Financial Services Licence
AUSTRAC Registered
AML/CTF compliance
Mastercard Principal Issuer
Direct card issuing capability
Apple Pay Enabled
Full digital wallet support
“Kobble and Shouta are perfectly placed to be the saviour in this scrambling market. We have the core components and more out of the box.”
Investment Opportunity
Key Terms
Exit Optionality
Strategic Acquisition
Mastercard, Visa, major payments players
Industry Consolidation
InComm, Blackhawk or other incumbents seeking compliant infrastructure
IPO
Public listing as market leader in compliant gift card infrastructure
Continued Cashflow
Distributions from profitable operations
The Ask
To capture 3-20% market share in the 18-month regulatory window
“Make hay while there is chaos and blood on the streets.”