A PAMM account is likely to require a financial services licence with either a managed discretionary account service (MDA) or managed investment scheme (MIS) authorisation. Some managed funds that operate as MDAs or MIS’ may qualify for an exemption from licensing under the Corporations Act 2001 and accompanying regulations. Each exemption has detailed requirements and requires the PAMM account operator to stay within strict parameters. You would need to look at these exemptions in detail and/or seek legal advice to determine whether the fund you intend to operate meets these exemptions. This would help determine your licencing requirements.