Can I hold both an AFSL and an ACL?

Yes. Many businesses that provide both financial-product services and credit services hold both licences, or operate as an authorised representative under both. They are separate authorisations under separate Acts.

Is becoming an authorised representative cheaper than holding a licence?

Usually, yes — you avoid application fees, responsible-manager requirements, PI insurance in your own name, and ongoing compliance overhead. The trade-off is that the licensee controls your authorisations and supervises your conduct.

What happens if I provide financial services without a licence?

Providing financial or credit services without the required authorisation is an offence carrying civil penalties and potential criminal liability. ASIC actively enforces unlicensed-conduct cases.

AFSL vs ACL vs authorised representative: which licence do you need?

A plain-English guide to the three financial-services licensing paths in Australia — Australian Financial Services Licence, Australian Credit Licence, and becoming an authorised representative — and how to choose.

The three paths

If you provide financial or credit services in Australia, you almost certainly need to operate under one of three arrangements regulated by ASIC:

Australian Financial Services Licence (AFSL) — to provide financial product advice, deal in financial products, make a market, operate a registered scheme, or provide custodial services.
Australian Credit Licence (ACL) — to engage in credit activities (lending, credit assistance, acting as an intermediary) regulated by the National Consumer Credit Protection Act.
Authorised representative (AR) — operate under someone else's AFSL or ACL rather than holding your own.

Choosing the wrong path — or operating without authorisation — is a serious offence with both civil and criminal exposure.

Do I need an AFSL?

You generally need an AFSL if you:

Provide financial product advice (personal or general) to retail or wholesale clients
Deal in a financial product (issue, apply for, vary or dispose of)
Make a market for a financial product
Operate a registered managed investment scheme
Provide a custodial or depository service
Provide a crowd-funding service or claims-handling service

"Financial product" is broad — securities, derivatives, super, insurance, managed funds, and some crypto-asset arrangements. Holding an AFSL brings ongoing obligations: the general obligations under s 912A, responsible managers, PI insurance (RG 126), breach reporting (the reportable situations regime, RG 78), and a dispute-resolution membership (AFCA).

Do I need an ACL?

You need an ACL if you engage in credit activities — providing credit, benefiting from a credit contract, or providing credit assistance (suggesting or assisting a consumer to apply for a particular credit product). Mortgage brokers, lenders, lessors and buy-now-pay-later providers (now in scope) all sit here. Credit licensees carry a best interests duty for brokers (s 158LA) plus responsible-lending obligations.

Authorised representative

Becoming an authorised representative lets you provide financial or credit services under another entity's licence (the "licensee"). The licensee takes on responsibility for your conduct, training and supervision. This is the faster, lower-cost path for advisers and brokers who don't want the overhead of holding and maintaining their own licence — but you give up independence and the licensee controls your authorisations.

How to choose

If you...	Path
Advise on or deal in financial products + want independence	Hold your own AFSL
Provide credit / broking services + want independence	Hold your own ACL
Want to start advising/broking quickly with less overhead	Become an authorised representative
Do both financial-product + credit work	You may need both an AFSL and an ACL (or AR arrangements under both)

Whichever path you take, the directors carry personal duties — run the director duties self-check — and the licence brings a calendar of recurring obligations you can map with the compliance calendar tool.

This is general information, not legal or licensing advice. Confirm your specific authorisation requirements with ASIC or a financial-services lawyer before you start providing services.