Phase 3 · Democratise Invest

Everyday Australians, the same assets, the same discipline

A launch-ready retail layer over the institutional spine: civic bonds issued with councils, A$500 access notes into the assets sovereign funds already hold, and a conservative entry product — built to a Year 8 reading level, with exit timing treated as uncertain on every screen.

Illustrative Demonstration Data Only — Not Live Market Information.

DemoRegistered MIS / retail CCIVPDS · Pt 7.9DDO + TMDAFCA + CSLRRG 234 marketingDAF Act 2026 — commences 9 Apr 2027

A$250

Minimum first investment

A$500 on single-asset access notes

H2 2028

Earliest retail go-live

Gated on ≥A$250m institutional tokenised

~21 hrs

BrickX median time-to-sell

The honest benchmark we must beat or disclose

Crypto signals on retail surfaces

No tickers, no candlesticks, no wallet-first UX

Executive summary

What this document concludes

Retail is not the growth engine for Democratise in years one to three — it is the political and licence-to-operate asset that makes an institutional, foreign-capital venue defensible in Australian public debate. The unit economics below break even at roughly 38,000–42,000 funded accounts. That is achievable, but not on a three-year horizon without a distribution partner doing the acquisition work for free. Councils are that partner.

The strongest product is the one that looks least like tokenisation: a small-denomination civic bond for a named local project, sold by a Mayor to residents who can see the thing being built. It has a working precedent in the UK Community Municipal Investment market, where Abundance-issued CMIs have run at sub-2% default framing across typical 5–7 year tenors, and it converts an abstract yield decision into a civic one.

Where we challenge the brief: Green Saver as specified fails an honest viability test. At an indicative 4.2–4.8% p.a. before fees it sits inside the noise band of at-call and 12-month term deposits, which carry the Financial Claims Scheme guarantee that Green Saver cannot. Selling a non-guaranteed, gate-able product against a guaranteed one on a 20–60bps edge is a conduct problem waiting to happen. The nearest viable alternative is to launch Green Saver only when the modelled net band clears prevailing 12-month term deposits by ≥150bps, and until then use a A$250 civic bond parcel as the on-ramp product instead.

Retail secondary trading is assumed to require an Australian Market Licence. Every liquidity mechanism specified here — quarterly and monthly exit windows, matched-buyer auctions, capped sponsor buy-backs — is deliberately designed as scheme redemption machinery rather than a market, and is disclosed as such.

The five decisions

Lead with civic bonds, not access notes — the Mayor is the acquisition channel.
Gate retail on ≥A$250m institutional tokenised and ≥12 completed wholesale secondary trades.
Hold Green Saver until it clears term deposits by 150bps net.
Publish realised time-to-exit per product, quarterly, including bad quarters.
Never buy finfluencer promotion, never gamify, never show a chart that looks like a market.

Part A · 1

The Australian retail investor landscape

Roughly 7.7 million Australians hold investments outside super, of whom about 1.3 million began investing in the last five years — a young, self-directed, app-native cohort. Micro-investing has normalised small balances: Raiz, Spaceship and CommSec Pocket together account for well over two million funded accounts with median balances in the low thousands. That cohort is reachable and cheap to service, but it is not the cohort that funds a 6-year infrastructure bond.

The real competitor is not another platform. It is A$1.6 trillion of household deposits earning 4.0–4.9% on 12-month term deposits with a government guarantee to A$250,000. Any retail product must be explained against that benchmark, honestly, on the product page.

Superannuation engagement remains low — most members have never changed an investment option — which is precisely why civic and place-based framing outperforms rate framing. And the trust deficit toward crypto-branded products is severe enough that the word "token" appears in our disclosure documents only, never in retail marketing.

Cohort	Scale	What it means for us
Self-directed investors	~7.7m	Large, but yield-shopping and impatient
Micro-investing accounts	>2m funded	Cheap to reach, small tickets, short horizons
Household deposits	~A$1.6t	The true competitor; guaranteed to A$250k
12-month term deposit	4.0–4.9% p.a.	Our honest hurdle rate
Engaged super members	<20%	Civic framing beats rate framing

Source: ASX Australian Investor Study and Investment Trends 2025–26 cohort estimates; APRA monthly banking statistics and RBA retail deposit series, 2026. Figures rounded and shown for demonstration.

Part A · 2

Retail product set

Three products, each with a target market determination logic, a fee stack, an exit mechanism and the three biggest ways it could hurt someone.

2.1 Civic bonds

NSW · Civic bond5.6%

Wagga Wagga Community Energy Hub

Wagga Wagga City Council

A 4.2 MW solar array and 8 MWh battery on council land beside the livestock exchange, cutting the council's grid bill and keeping the pool, library and depot running through summer outages.

Term: 6 years
From: A$250
Income: Quarterly
Raise: A$6.50m

64% funded · A$4.18m of A$6.50m

Construction milestones

Council resolution and MOU — Complete, Mar 2028
Grid connection agreement — Complete, Jul 2028
Construction start — In progress, Nov 2028
Energisation — Planned, Sep 2029

Community impact

Homes-equivalent powered1,600

Council emissions cut38%

Local residents invested612

Getting your money out

Typical 4–12 weeks via a quarterly exit window; longer if demand is thin

Council revenue covenant, first-ranking charge over the asset

VIC · Civic bond4.9%

Ballarat Active Transport Link

City of Ballarat

An 11 km separated walking and cycling link joining Sebastopol, the CBD and the hospital precinct, funded alongside a state grant and repaid from council's transport levy.

Term: 7 years
From: A$250
Income: Semi-annual
Raise: A$3.20m

93% funded · A$2.96m of A$3.20m

Construction milestones

Community consultation closed — Complete, Feb 2028
State co-funding confirmed — Complete, Jun 2028
Stage 1 construction — In progress, Oct 2028
Full link open — Planned, Mar 2030

Community impact

Kilometres delivered4.1 / 11

Schools connected9

Local residents invested388

Getting your money out

Typical 6–16 weeks; civic bonds are held to maturity by most investors

General obligation of the council, unsecured, ranks with other council debt

NSW · Civic bond5.1%

Lake Macquarie Foreshore Resilience

Lake Macquarie City Council

Seawall renewal, living shoreline planting and stormwater upgrades across four low-lying foreshore suburbs identified in the council's coastal management programme.

Term: 5 years
From: A$250
Income: Quarterly
Raise: A$4.75m

26% funded · A$1.24m of A$4.75m

Construction milestones

Coastal management certification — Complete, Jan 2029
Contractor appointed — In progress, May 2029
Stage 1 seawall — Planned, Nov 2029
Revegetation complete — Planned, Aug 2031

Community impact

Properties protected2,300

Shoreline restored1.8 km

Local residents invested141

Getting your money out

Typical 6–20 weeks; the newest projects have the thinnest secondary demand

Special rate variation revenue, unsecured

Why civic bonds work

The Mayor is the marketing engine

The UK Community Municipal Investment market — Abundance-issued, five to seven year tenors, small denominations, no defaults recorded across the programme to date — proves that a named local project sold by an elected official converts at a cost of acquisition no fintech can match. Sold politically upward to Mayors and councillors, civically outward to residents. The product is a bond; the purchase decision is about the town.

2.2 Retail access notes and 2.3 Green Saver

Retail access note

Mallee Solar Access Note

Feeder into the Mallee Solar Green Notes held by institutional investors

Indicative, not guaranteed

5.4–6.2% p.a. before fees, not guaranteed

From: A$500
Term: 5 years, no early redemption right
Income: Quarterly income
Fees: 0.85% p.a. management, 0.10% RE fee, nil entry, nil exit within a window
Exit mechanism: Quarterly exit window with matched buyers, then sponsor buy-back facility
Modelled time to exit: Median 5 weeks modelled; 10th–90th percentile 2–22 weeks

Target market determination

Investors seeking income over a 5-year horizon, able to lose some or all capital, who do not need access to the money before maturity.

What could go wrong

Investor treats the note like a term deposit and needs cash early.
Mitigation: Exit window calendar shown before order, hard-coded suitability question on time horizon, and cooling-off with full refund.
Single-project construction or offtake failure wipes value.
Mitigation: Per-investor cap of 10% of investable assets, concentration warning at point of sale.
Indicative range is read as a promise.
Mitigation: RG 234-compliant copy: ranges shown only with 'not guaranteed', no past-performance graphs.

Retail access note

Hunter Valley Battery Access Note

Feeder into the Hunter Valley Battery Mezzanine tranche

Indicative, not guaranteed

7.0–8.4% p.a. before fees, not guaranteed

From: A$500
Term: 4 years
Income: Quarterly income, may be deferred if the project defers
Fees: 0.95% p.a. management, 0.10% RE fee
Exit mechanism: Quarterly window only, no sponsor buy-back on mezzanine risk
Modelled time to exit: Median 9 weeks modelled; 10th–90th percentile 4–30 weeks

Target market determination

Experienced income investors with a diversified portfolio who understand mezzanine debt ranks behind senior lenders.

What could go wrong

Mezzanine subordination misunderstood as senior security.
Mitigation: Capital-stack diagram and a mandatory acknowledgement before the order can be placed.
Distribution deferral read as a default.
Mitigation: Deferral is explained in plain English up front and flagged in the portfolio view.
Over-allocation chasing the highest rate on the platform.
Mitigation: Hard per-investor cap of A$25,000.

Retail access note

Barangaroo Senior Credit Access Note

Feeder into the Barangaroo Senior Credit facility

Indicative, not guaranteed

4.8–5.4% p.a. before fees, not guaranteed

From: A$500
Term: 3 years
Income: Monthly income
Fees: 0.70% p.a. management, 0.10% RE fee
Exit mechanism: Monthly exit window, sponsor buy-back facility capped at 2% of the pool per quarter
Modelled time to exit: Median 3 weeks modelled; 10th–90th percentile 1–12 weeks

Target market determination

Conservative income investors who can still bear loss of capital and a multi-week exit.

What could go wrong

Deposit substitution.
Mitigation: Side-by-side comparison with term-deposit rates and the guarantee that is absent here.
Property downturn erodes the security margin.
Mitigation: LVR disclosed on every screen and re-tested each valuation cycle.
Buy-back cap is assumed to be a guarantee.
Mitigation: Cap stated wherever the buy-back is mentioned.

Entry product

Green Saver

Diversified pool across senior infrastructure debt, civic bonds and cash

Indicative, not guaranteed

4.2–4.8% p.a. before fees, not guaranteed

From: A$250
Term: Open-ended
Income: Monthly income, optional reinvestment
Fees: 0.55% p.a. all-in, nil entry, nil exit
Exit mechanism: Monthly window with a cash buffer of 5–8% of the pool
Modelled time to exit: Median 8 days modelled; 10th–90th percentile 3 days–6 weeks

Target market determination

First-time investors making their first investment outside a bank account, with at least a 2-year horizon.

What could go wrong

Read as a savings account.
Mitigation: 'Not a bank account, not government guaranteed' banner on every screen for this product.
Cash buffer exhausted in a stress event.
Mitigation: Gating policy pre-disclosed with worked examples.
Vulnerable customer invests emergency savings.
Mitigation: Onboarding hardship screen and a kind decline path with no upsell.

Viability challenge — Green Saver

Green Saver as briefed does not pass an honest test against guaranteed 12-month term deposits at 4.0–4.9%. Launch it only when the modelled net band clears prevailing deposit rates by ≥150bps; otherwise use a A$250 civic bond parcel as the first-investment on-ramp, where the value proposition is civic rather than a marginal rate advantage.

Part A · 3

Distribution — and the channels we refuse

Primary

Council partnerships

An MOU, a council resolution, a Mayor's launch event, rate-notice inserts and the council's own newsletter. Democratise supplies the compliance and the platform; the council supplies the audience and the credibility.

Secondary

Community energy groups and employers

Community energy co-ops convert at high rates on renewable civic bonds. Employer and payroll channels suit access notes: opt-in, no default enrolment, no employer advice.

Enablement

Advisers and education

Adviser-ready TMD summaries, research-house ratings, APL submissions, and an owned Learn hub written at Year 8 reading level with no calls to action inside educational content.

Anti-strategy — channels we will not use

Paid finfluencer promotion of any kind, including 'organic' gifted arrangements.
Engagement-bait: streaks, badges, leaderboards, referral bounties tied to invested amounts.
Gamified UI — confetti on investment, portfolio 'levels', push notifications about price.
Performance-led advertising, forward yield in headlines, or any crypto-adjacent creative.
Lead-generation lists, cold outbound, or third-party data brokers.

Part A · 4

Unit economics

Contribution margin assumes a blended 0.80% p.a. net revenue on balances, A$4.60 per-account annual servicing cost, and no cross-sell credit.

Channel	CAC	Avg balance	Contribution / yr	CAC payback
Council civic bond campaign	A$38	A$1,450	A$11.6 p.a.	3.3 yrs
Community energy groups	A$62	A$2,100	A$16.8 p.a.	3.7 yrs
Employer / payroll	A$95	A$3,400	A$27.2 p.a.	3.5 yrs
Financial adviser referral	A$140	A$5,000	A$40.0 p.a.	3.5 yrs
Owned content / education	A$210	A$900	A$7.2 p.a.	>10 yrs

~40,000

Funded accounts to break even

At a A$2,050 blended balance and A$1.1m retail cost base

3.3–3.7 yrs

CAC payback, council-led channels

Owned-content acquisition does not pay back and should not be scaled

Strategic

Retail's role, years 1–3

A political and licence-to-operate asset, not a profit centre

Part A · 5

Conduct-risk register and the institutional interaction

Risk	How it shows up	Control
Mis-selling	Retail buys mezzanine risk believing it is senior secured	Capital-stack acknowledgement gate; TMD questionnaire hard-blocks out-of-market applicants
Vulnerable customers	Emergency savings or hardship-driven investment	Hardship screen at onboarding, kind decline with no upsell, referral to free financial counselling
Liquidity mismatch	Investor expects days, experiences months	Published realised time-to-exit per product, queue position shown, no 'liquid' language anywhere
Complaint handling	IDR breaches or unresolved disputes escalate to AFCA	30-day IDR clock instrumented in the platform; AFCA and CSLR disclosures on every product page
Marketing breach	A social post implies a guaranteed return	Marketing-approval workflow with RE sign-off; no asset published without an approval record
Reputational bleed to institutional	A retail failure damages sovereign-investor confidence	Separate RE, separate brand surface, ring-fenced disclosure; retail never sells the institutional franchise's risk

Part A · 6

Phased retail roadmap with go/no-go gates

H1 2027

R0 — Evidence

Gate: Go/no-go on retail at all

3 council MOUs signed, 8,000-deep waitlist with verified emails, 25 advisers committed in writing.

H2 2027 – H1 2028

R1 — Civic pilot

Gate: Proceed to a second council

First civic bond fully subscribed within 90 days, ≥60% of investors resident in the LGA, zero upheld complaints.

H2 2028

R2 — Access notes

Gate: Open feeder notes

Institutional spine ≥A$250m tokenised, ≥12 completed wholesale secondary trades, RE and PDS lodged.

2029

R3 — Green Saver + scale

Gate: National marketing spend

Median realised time-to-exit inside the disclosed range for 3 consecutive quarters, CAC payback <4 years.

Demand before supply. No gate is passed on qualitative confidence alone.

Part B · 1

Information architecture — Democratise Invest

A distinct retail surface sharing the navy-and-gold design system in a warmer register: larger type, photography of real Australian places, plain English throughout.

Surface	Purpose	Key components
Home	Establish who we are and what we are not	Hero, three product cards, 'not a bank account' band, council logos
How it works	Explain the structure without jargon	Four-step diagram, fee explainer, what happens to your money
Projects near you	Map-led civic bond discovery	Postcode search, LGA map, project cards, distance-to-you label
Product pages	Decide	Plain-English term/rate/risk labels, 'What could go wrong' panel, time-to-exit history
Learn hub	Educate without selling	Year 8 reading level articles, glossary, no CTAs inside content
Portfolio	Hold	Positions, income received, next distribution date, exit window countdown
Statements & tax	Comply	Annual tax statement pre-fill ready, AMIT attribution, distribution history
Support	Recover	IDR clock, AFCA pathway, hardship, scam reporting, phone-first for over-65s

Part B · 2

Page-by-page copy specification

Home — hero

Own a piece of what gets built here.

From A$250 you can help fund a solar hub, a battery or a seawall in an Australian town — and be paid income while it runs. Your money is invested, not deposited. You can lose it, and you may not be able to get it out quickly.

Buttons: "See projects near you" (primary) · "How this works" (secondary). No rate in the hero. No countdown timers.

Standard panel — every product page

What could go wrong

You could get back less than you put in, or nothing at all.
This is not a bank account. There is no government guarantee.
Getting your money out takes time. Here is how long it has actually taken.
Income can be reduced, deferred or stopped.
The project can be delayed. Construction risk is real.

Always above the invest button, never collapsed, never behind a tab.

Product card — plain-English labels

Label	Copy
Term	Your money is committed for about 6 years
Income	Paid every 3 months, not guaranteed
Risk	Higher risk than a term deposit
Getting out	Usually 4–12 weeks, sometimes longer

Civic bond project page template

Project story in under 120 words, written by the council, edited to Year 8 reading level.
Council partner block: Mayor's statement, resolution date, link to council papers.
Construction milestones with real dates and honest status labels.
Community impact meter — homes powered, kilometres built, residents invested.
What could go wrong panel, then the disclosure pack, then the invest button.

Part B · 3

Onboarding flow

Who you are

Australian identity verification against AUSTRAC requirements, in under four minutes, with a phone-assisted path for anyone who needs it.

Is this right for you

The DDO target-market questionnaire. Out-of-market answers end the flow kindly: no retry loop, no upsell, a link to free financial counselling where hardship is indicated.

What you are agreeing to

PDS and TMD presented with version binding; the version ID is stamped onto the order record.

Cooling-off

Plain-English explanation of the 14-day cooling-off right, with a visible countdown in the portfolio afterwards.

Fund your investment

PayTo or bank transfer only. No card funding. No credit. No leverage, ever.

The ceremony

"You now own part of the Mallee Solar Farm." A photograph of the site, the number of panels your money represents, the date of your first income payment. Pride, not hype — no confetti, no share-to-social prompt.

Part B · 4

The liquidity UX

Exit windows are scheme redemption machinery, not a market. The interface must never imply otherwise.

Exit window display

Element	Behaviour
Window calendar	Next three windows shown with dates, before the invest button
Queue position	"You are 18th of 43 requests" — updated daily, never hidden
Realised history	Median and 10th–90th percentile time-to-exit for the last 8 windows
Partial fills	Shown as an amount and a remaining balance, not a percentage bar
Gating	If a window is gated, the reason and the policy are shown on the same screen

Exact language when an exit takes longer than hoped

"Your request to sell is still in the queue. In the last window, requests like yours took 9 weeks. We cannot tell you a date, because it depends on other investors buying. If you need the money urgently, please call us on 1300 000 000 — we cannot speed up the queue, but we can talk through your options and point you to free financial counselling."

Benchmarks disclosed in the Learn hub: DomaCom's sub-fund freeze and 2024 delisting, RealT's 2026 liquidation, the closures of Here.co and Landa, PeerStreet's bankruptcy, and BrickX's ~21-hour median time-to-sell. Retail investors are told what has gone wrong elsewhere, by name.

Part B · 5

Demo data pack

Three civic bond projects and four retail feeders are specified above with internally consistent raise sizes, coupons, tenors, distribution frequencies and modelled exit ranges. Aggregate retail pool at full subscription:

Civic bond raise: A$14.45m
Civic bond raised: A$8.38m
Weighted coupon: 5.3% p.a.
Retail feeders: 4 products
Min ticket range: A$250 – A$500
Residents invested: 1,141

Source: Illustrative demonstration data. Not an offer and not live pricing.

Part B · 6

Compliance engineering

Control	Extension of the existing engine	Audit artefact
DDO enforcement at point of sale	TMD rules evaluated server-side against the questionnaire response before an order can be created	Signed decision record with rule version
Per-investor caps	Same rule engine as FIRB thresholds, keyed on investor rather than jurisdiction	Cap evaluation log per order
Cooling-off timers	Order state machine holds funds in trust until the cooling-off clock expires	Timestamped state transitions
PDS version binding	Immutable PDS hash stamped to every order at creation	Hash + document snapshot retained 7 years
Marketing approval	No creative renders on a retail surface without an approval record signed by the RE	Approval ID rendered in page metadata
AML/CTF + travel rule	Existing AUSTRAC pipeline; retail adds enhanced due diligence triggers on source-of-funds anomalies	SMR-ready case file
Complaints	IDR clock starts on first contact and escalates automatically at day 25	AFCA-ready complaint dossier

Part B · 7

Accessibility and inclusion

WCAG 2.2 AA

Tested, not claimed

Contrast, focus visibility, target size, no drag-only interactions, screen-reader tested on every investment path.

Plain English

Year 8 reading level

Every retail sentence scored before publication. Jargon is either removed or defined in the same sentence.

Cultural review

Designed with, not for

First Nations and CALD review of civic project pages, with translated key-facts summaries in the five most spoken community languages in each LGA.

Vulnerability

Hardship and scams

Hardship pathway with no upsell, a scam-response line answered by a human, and account freeze on request within one hour.

Part B · 8

Build phasing and acceptance criteria

Phase	Scope	Acceptance criteria
RB1 — Retail shell	Design system fork, IA, Home, How it works, Learn hub	WCAG 2.2 AA audit passed; reading-level score ≤ Year 8 on 100% of published copy
RB2 — Onboarding	Identity, DDO questionnaire, cooling-off, funding	Out-of-market applicants blocked in 100% of test cases; every order carries a PDS hash
RB3 — Civic bonds	Projects near you map, project template, primary orders	One live council pilot fully subscribed; zero marketing assets published without approval ID
RB4 — Liquidity	Exit windows, queue transparency, realised history	Realised time-to-exit published for two consecutive windows; legal opinion that no market is operated
RB5 — Access notes and reporting	Feeder notes, portfolio, statements and tax	Annual tax statement validated against pre-fill format; AMIT attribution reconciled

Closing

Open questions for the founder

Is retail a profit centre or a political asset? On these numbers it is the latter until roughly 40,000 funded accounts — are you willing to fund three years of negative contribution for the licence-to-operate benefit?
Retail CCIV versus registered MIS: the CCIV is cleaner for offshore familiarity but adds corporate-director cost. Which do you want the RE conversation to start from?
Do you accept that a retail secondary order book almost certainly requires an Australian Market Licence, and that periodic auctions are therefore the ceiling until one is granted?
Which council relationship do you own personally? Civic bonds live or die on the Mayor, not on the platform.
Will the board tolerate publishing realised time-to-exit data even when it is bad? The strategy is not credible if that number is ever hidden.
Green Saver's 4.2–4.8% band sits close to term deposits without the guarantee. Is the honest answer that it should launch only if the band clears deposits by 150bps or more?

Retail is the layer that makes the institutional franchise politically durable. It should be built carefully, launched late, and never sold on yield.

See the phased roadmap Institutional assets

Nothing on this page is an offer of a financial product or financial product advice. All projects, councils, rates and figures are illustrative demonstration data.