Compliance playbook for financial advisers — post-DBFO
The whole stack after the Delivering Better Financial Outcomes reforms: AFSL and relevant-provider status, the Financial Planners and Advisers Code of Ethics 2019 (5 Values + 12 Standards), best interests duty under s 961B + the 7-step safe harbour, Statement of Advice + Record of Advice, the CSLR levy, FASEA-equivalent education + ethics, 40 hours CPD per year (9 hours ethics), and TPB registration plus the 2024 additional obligations if you provide tax-related financial advice.
Key deadlines — next 12 months
- Annual (12 months from last)Ongoing fee arrangement renewal + consent
- Annual40 hours CPD (incl. 9 hours ethics)
- AnnualCSLR levy assessment
- Within 30 daysBreach report to ASIC under s 912D
- ContinuousBest interests duty + Code of Ethics
Does this apply to me?
Answer yes to any of the below and the obligations in this playbook are likely relevant.
- 1Do you provide personal advice to retail clients about financial products (i.e. you are a relevant provider)?
- 2Are you registered on the ASIC Financial Adviser Register?
- 3Are you authorised under an AFS Licence (yours or an Australian Financial Services Licensee's)?
- 4Do you provide tax (financial) advice services as part of your advice — triggering TPB registration?
- 5Do you give advice on superannuation, retirement, or insurance products subject to the CSLR levy?
- 6Are you transitioning to or maintaining the bachelor-degree-or-equivalent + ethics-unit education + Financial Adviser exam standard?
Plain English summary
The 2024 Delivering Better Financial Outcomes (DBFO) reforms (Pt 1 of the Financial Services Reform Act 2024 + Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024) reshaped the compliance stack for personal advice to retail clients. The Statement of Advice (SOA) requirement remains but the content rules have been substantially modernised: the 'reasons-for-advice' obligation is now principles-based, ongoing-fee renewals (every 12 months) and consent rules were simplified, and the structure of advice records is closer to the substance of the advice given.
What did not change: the best interests duty in s 961B of the Corporations Act 2001 + the 7-step safe harbour in s 961B(2); the Code of Ethics 2019 (5 Values + 12 Standards) administered by the Compliance Scheme Monitoring Body; the relevant-provider regime (registration on the FAR, exam-passed, ethics-unit-completed, bachelor-degree-or-equivalent); and the 40 hours CPD/year minimum including 9 hours ethics. The Compensation Scheme of Last Resort (CSLR) commenced 2 April 2024 with industry-funded levy.
The TPB additional obligations introduced by Tax Agent Services (Code of Professional Conduct) Determination 2024 (Determination 8 — sometimes called the 'Det 8' obligations) apply to financial advisers who provide tax (financial) advice service as a 'qualified tax relevant provider' (QTRP). The 'Det 8' obligations layer on top of the existing Code of Professional Conduct — covering false/misleading statements, breach reporting, client-information requirements, and disclosure of professional/personal matters.
This playbook lists every obligation that sits on a relevant provider operating under an AFSL today, the section of the Act it sits under, who is accountable, the cadence, the maximum penalty, and a regulator-direct source. Tailor down for general-advice-only or wholesale-only providers (the personal-advice + retail-client stack does not apply).
Obligation checklist
Every obligation cites the Act and section. Source URLs link to the regulator's portal — Rules Mate does not republish statutory text.
- 1
Corporations Act 2001 (Cth), s 911A — AFSL requirement
Hold an Australian Financial Services Licence (AFSL) — or be an authorised representative of an AFS Licensee — to provide financial services. Authorisations on the licence must match the services provided.
- Who's responsible
- AFS Licensee (and authorised reps)
- Frequency
- Continuous
- Penalty
- Up to ~$15.65M (corporate) + criminal offence; ASIC enforcement; AFCA jurisdiction.
- Source
- Regulator-direct link
- 2
Corporations Act 2001 (Cth), s 912A — AFSL general obligations
Comply with general obligations: do all things necessary to ensure the financial services are provided efficiently, honestly and fairly; manage conflicts of interest; comply with the conditions of the licence; have adequate human resources, competence, financial resources and compensation arrangements; comply with the dispute resolution requirements; maintain risk management systems.
- Who's responsible
- AFS Licensee + Responsible Managers
- Frequency
- Continuous
- Penalty
- Civil penalty up to ~$15.65M (corporate) per breach; licence revocation; banning orders.
- Source
- Regulator-direct link
- 3
Corporations Act 2001 (Cth), s 921B — relevant provider registration
Every relevant provider (personal advice to retail clients on relevant financial products) must be registered on the ASIC Financial Adviser Register. AFS Licensee responsible for registration; relevant provider responsible for maintaining standards.
- Who's responsible
- AFS Licensee + relevant provider
- Frequency
- Continuous
- Penalty
- Operating as a relevant provider while unregistered — civil penalty + ASIC banning power.
- Source
- Regulator-direct link
- 4
Corporations Act 2001 (Cth), s 921B(2) — education + exam standards
Bachelor-degree-or-equivalent qualification (FASEA standard) + completion of approved ethics unit + passed the Financial Adviser Exam. Existing-provider transitional pathways have substantially closed; new providers must meet the standard before authorisation.
- Who's responsible
- Relevant provider personally
- Frequency
- One-off + maintain (no re-sit of exam required)
- Penalty
- Inability to act as relevant provider; ASIC banning power; AFCA exposure.
- Source
- Regulator-direct link
- 5
Corporations (Relevant Providers — Continuing Professional Development Standards) Determination 2018
Complete 40 hours CPD/year — minimum 5 hours technical competence; 5 hours client care and practice; 5 hours regulatory compliance and consumer protection; 9 hours professional development including ethics; balance of 16 hours flexible.
- Who's responsible
- Relevant provider + AFS Licensee (oversight)
- Frequency
- Annual
- Penalty
- Inability to act as relevant provider; ASIC banning.
- Source
- Regulator-direct link
- 6
Corporations Act 2001 (Cth), s 961B — best interests duty + 7-step safe harbour
Act in the best interests of the client when providing personal advice. The 7-step safe harbour: (1) identify objectives, needs, circumstances; (2) identify subject matter of advice; (3) make reasonable inquiries; (4) assess client's information; (5) consider product replacement; (6) act on reasonable basis; (7) other reasonable steps.
- Who's responsible
- Relevant provider personally
- Frequency
- Per advice
- Penalty
- Civil penalty up to ~$15.65M (corporate); ASIC banning; AFCA exposure; client civil action.
- Source
- Regulator-direct link
- 7
Corporations Act 2001 (Cth), s 961G + s 961H — appropriate advice
Only give advice if reasonable to conclude advice is appropriate to the client. Warn client if advice is based on incomplete or inaccurate information.
- Who's responsible
- Relevant provider personally
- Frequency
- Per advice
- Penalty
- Civil penalty regime; ASIC banning.
- Source
- Regulator-direct link
- 8
Corporations Act 2001 (Cth), s 961J — prioritise client interests
Give priority to the client's interests when providing personal advice if you know or reasonably ought to know of a conflict between your interests and the client's interests.
- Who's responsible
- Relevant provider personally
- Frequency
- Per advice
- Penalty
- Civil penalty up to ~$15.65M; ASIC banning.
- Source
- Regulator-direct link
- 9
Corporations Act 2001 (Cth), Pt 7.7 + s 946A — Statement of Advice
Provide a Statement of Advice (SOA) when first giving personal advice that recommends a product to a retail client. SOA content must reflect the substance of the advice. Record of Advice (ROA) may be used for subsequent advice where the basis has not materially changed.
- Who's responsible
- Relevant provider
- Frequency
- Per advice instance
- Penalty
- Civil penalty regime; ASIC enforcement.
- Source
- Regulator-direct link
- 10
Corporations Act 2001 (Cth), Pt 7.7A — ongoing fee arrangements + consent
Renew ongoing fee arrangements every 12 months with client written consent. From DBFO reforms: consent rules simplified into a single annual consent. Anti-hawking provisions strengthened.
- Who's responsible
- Relevant provider + AFS Licensee
- Frequency
- Annual
- Penalty
- Civil penalty for unauthorised continuing fee deductions; AFCA and ASIC enforcement.
- Source
- Regulator-direct link
- 11
Corporations Act 2001 (Cth), Pt 7.7 + s 942B — Financial Services Guide
Provide a Financial Services Guide (FSG) before financial services are provided to a retail client. FSG to set out services, remuneration, associations, complaints process, EDR scheme.
- Who's responsible
- Relevant provider + AFS Licensee
- Frequency
- Per relationship onset
- Penalty
- Civil penalty regime; ASIC enforcement.
- Source
- Regulator-direct link
- 12
Corporations (Relevant Providers — Code of Ethics) Determination 2018 — Code of Ethics 2019
Comply with the Code of Ethics — 5 Values (Trustworthiness, Competence, Honesty, Fairness, Diligence) and 12 Standards. Code is enforceable; serious breach informs ASIC banning.
- Who's responsible
- Relevant provider personally
- Frequency
- Continuous
- Penalty
- ASIC banning; AFCA exposure; client compensation claims.
- Source
- Regulator-direct link
- 13
Corporations Act 2001 (Cth), Pt 7.8A — Design and Distribution Obligations (DDO)
Issuers of retail financial products: prepare and publish a Target Market Determination (TMD). Distributors (advisers): comply with TMD-related reasonable-steps obligation when distributing.
- Who's responsible
- Issuer + distributor (AFS Licensee + relevant provider)
- Frequency
- Continuous; TMD review at trigger events
- Penalty
- Civil penalty up to ~$15.65M (corporate); ASIC stop orders.
- Source
- Regulator-direct link
- 14
Corporations Act 2001 (Cth), s 912D — breach reporting
AFS Licensee must report 'reportable situations' (significant breaches of core obligations) to ASIC within 30 days of becoming aware. Threshold post-2021 reforms is lower than the previous 'significant breach' standard.
- Who's responsible
- AFS Licensee + responsible managers
- Frequency
- Event-driven
- Penalty
- Civil penalty for failure to report; ASIC enforcement; loss of trust.
- Source
- Regulator-direct link
- 15
Financial Sector (Collection of Data) Act 2001 — CSLR levy
Pay the Compensation Scheme of Last Resort levy. Industry-funded; sub-sector apportioned (personal advice, credit intermediation, securities dealing, credit provision). First-cycle levy from 2 April 2024.
- Who's responsible
- AFS Licensee (financial responsibility)
- Frequency
- Annual
- Penalty
- Late-payment penalty; AFS Licence consequences.
- Source
- Regulator-direct link
- 16
Tax Agent Services Act 2009 + Tax Agent Services Regulations 2022 — TPB registration
If providing a 'tax (financial) advice service' as a qualified tax relevant provider (QTRP), comply with the streamlined TPB regime — registration via AFS Licensee notification, comply with TPB Code of Professional Conduct.
- Who's responsible
- Relevant provider + AFS Licensee
- Frequency
- Continuous
- Penalty
- TPB sanctions: termination; civil penalty up to ~$1.65M for body corporate; AFS Licence consequences.
- Source
- Regulator-direct link
- 17
Tax Agent Services (Code of Professional Conduct) Determination 2024 ('Det 8' additional obligations)
Comply with the 8 additional obligations: (1) maintain confidentiality of client information; (2) not make false or misleading statements; (3) keep proper client records; (4) keep clients informed of any material matter; (5) keep clients informed of investigations by the TPB; (6) comply with TPB information requests; (7) supervise; (8) act within scope of agency.
- Who's responsible
- Relevant provider personally + AFS Licensee oversight
- Frequency
- Continuous
- Penalty
- TPB sanctions; civil penalty regime; AFS Licence consequences.
- Source
- Regulator-direct link
- 18
Corporations Act 2001 (Cth), Pt 7.7 + ASIC RG 175 — anti-hawking
Do not make unsolicited contact to offer a financial product. Hawking prohibitions strengthened from 5 October 2021 reforms — consent must be positive, clear and informed.
- Who's responsible
- Relevant provider + AFS Licensee
- Frequency
- Per outreach
- Penalty
- Civil penalty regime; ASIC enforcement.
- Source
- Regulator-direct link
- 19
AFCA scheme rules — internal + external dispute resolution
Maintain internal dispute resolution (IDR) process under ASIC RG 271 — 30-day response standard for financial-product complaints. Be a member of AFCA for external dispute resolution.
- Who's responsible
- AFS Licensee + compliance manager
- Frequency
- Continuous; per complaint
- Penalty
- AFS Licence breach; AFCA determinations; reputational.
- Source
- Regulator-direct link
- 20
Corporations Act 2001 (Cth), s 912B — professional indemnity insurance
Hold compensation arrangements (typically PI insurance) under ASIC RG 126. Cover for own and authorised representatives' activities.
- Who's responsible
- AFS Licensee
- Frequency
- Continuous; annual renewal
- Penalty
- AFS Licence cancellation.
- Source
- Regulator-direct link
- 21
Corporations Act 2001 (Cth), s 963A-963K — conflicted remuneration ban
Do not accept conflicted remuneration. Defined as benefits given to a financial services provider that could reasonably be expected to influence the choice of product recommended or the advice given. Limited exceptions (insurance commissions in personal-risk advice).
- Who's responsible
- AFS Licensee + relevant provider
- Frequency
- Continuous
- Penalty
- Civil penalty up to ~$15.65M (corporate); ASIC enforcement.
- Source
- Regulator-direct link
Deadlines
Pulled from the Rules Mate compliance calendar. Click through for the full deadline page.
Forms and regulator portals
Direct links to the lodgement forms and regulator portals. Rules Mate does not host copies — we link to the official source.
ASIC Financial Adviser Register
Register relevant providers and check professional standards status.
Open portal →ASIC Connect — AFS Licence portal
AFSL applications, variations, breach reporting, annual statements.
Open portal →Financial Adviser Exam (ASIC)
Mandatory exam for relevant providers — administered through ASIC.
Open portal →CSLR — levy administration
Information on the Compensation Scheme of Last Resort levy.
Open portal →TPB qualified tax relevant providers portal
Registration and obligations for QTRPs under TASA + Det 8.
Open portal →AFCA — Australian Financial Complaints Authority
External dispute resolution scheme for AFS Licensees.
Open portal →
Free tools that help
Interactive Rules Mate tools matched to this persona.
What changes 2025–2026
2 April 2024 — CSLR commenced
The Compensation Scheme of Last Resort began operating, funded by an industry levy. First-year levy paid by personal-advice sub-sector covered legacy unpaid AFCA determinations.
2024 — Delivering Better Financial Outcomes (Tranche 1)
The Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024 commenced. Ongoing-fee renewal consent simplified; SOA content modernised toward principles-based; fee-deduction consents streamlined; safe harbour for record-keeping clarified.
2024 — TPB 'Det 8' additional obligations
The Tax Agent Services (Code of Professional Conduct) Determination 2024 introduced 8 additional obligations applying to all TPB registrants including QTRPs.
Late 2024 onwards — Delivering Better Financial Outcomes (Tranche 2)
The proposed second tranche covers superannuation advice for retirement, scaled advice expansion, and the new 'qualified adviser' class. Watch for legislation in 2025.
Ongoing — Education + ethics standard
The bachelor-degree-or-equivalent + ethics-unit standard + Financial Adviser Exam continue to be the qualifying standards. New-entrant pathway requires meeting standard before authorisation; existing-provider transitional pathways have substantially closed.
Ongoing — ASIC enforcement priorities
ASIC's enforcement priorities consistently include personal-advice quality, conflicted remuneration, advice to vulnerable consumers, and breach-reporting compliance.
In-depth reading
21 Rules Mate articles tagged to this playbook.
Best interests duty under section 961B Corporations Act and the safe harbour
The best interests duty for personal advice providers in s 961B Corporations Act, the seven-step safe harbour, and the related duties in s 961G and s 961J.
Financial Planners and Advisers Code of Ethics 2019
The 5 Values and 12 Standards in the Financial Planners and Advisers Code of Ethics 2019, made under section 921E Corporations Act and binding on all relevant providers.
Personal vs general financial product advice under section 766B
How section 766B Corporations Act distinguishes personal from general financial product advice and why personal advice triggers the best interests duty.
AFSL Responsible Managers: ASIC Regulatory Guide 105 explained
An AFS licensee must demonstrate organisational competence through Responsible Managers. RG 105 sets the qualifications and experience expected. Here's the framework.
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.
CSLR — Compensation Scheme of Last Resort explained
How the Compensation Scheme of Last Resort pays unpaid AFCA determinations against financial firms, and how subsector levies are calculated and capped.
TPB breach reporting — TASA 2024 reforms for tax practitioners
When registered tax practitioners must self-report or report another agent under the TPB's breach reporting regime that began on 1 July 2024.
TASA Code of Professional Conduct: 2024 Determination's 8 new obligations
The eight additional obligations in the Tax Agent Services (Code of Professional Conduct) Determination 2024, including false/misleading statement rules and QMS.
Compensation Scheme of Last Resort (CSLR) - eligible AFCA determinations and firms
Which unpaid AFCA determinations are covered by the CSLR: personal advice, credit intermediation, securities dealing and credit provision; caps and the post-Dixon levy outlook.
AUSTRAC enrolment for Tranche 2: a step-by-step (enrolment opens 31 March 2026)
AUSTRAC enrolment opens 31 March 2026 and closes 29 July 2026 for Tranche 2 entities. Step-by-step walkthrough of who, when, what you need, and how to lodge.
CPS 230 vs CPS 234: how APRA's operational risk and information security standards differ
A side-by-side of APRA's CPS 230 (Operational Risk Management) and CPS 234 (Information Security) — what each covers, who they apply to, commencement dates, and how they fit together.
Reportable situations (RG 78): the 30-day breach reporting regime explained
AFS and credit licensees must report certain breaches to ASIC within 30 days under the reportable situations regime. Here's what's reportable, the deemed-significant breaches, and the timeframe.
Financial Accountability Regime: who is an 'accountable person'?
FAR makes named senior executives personally accountable for the conduct of APRA-regulated entities. Here's who counts as an accountable person and what their accountabilities are.
ASIC RG 271 internal dispute resolution: what AFS and credit licensees must do
ASIC's Regulatory Guide 271 sets the binding internal dispute resolution standards for AFS and credit licensees. Here are the response timeframes, the IDR data reporting obligation, and the AFCA handoff.
Australian sanctions compliance: the DFAT regime explained
Australia implements UN Security Council sanctions and runs its own autonomous sanctions regime. Both are administered by DFAT's Australian Sanctions Office, with criminal penalties for breach.
NCCP responsible lending obligations explained
The National Consumer Credit Protection Act requires credit licensees to make reasonable inquiries, take reasonable steps to verify, and assess whether a credit contract is unsuitable. Here's what 'reasonable' means and where the duty starts.
Consumer Data Right (CDR) in Australia: open banking, open energy and what's coming
The Consumer Data Right lets consumers share their banking, energy and (progressively) other data with accredited third parties. Here's the framework, the participants and the Privacy Safeguards.
Foreign bribery offence under the Criminal Code: what changed in 2024
The foreign-bribery offence in Division 70 of the Criminal Code was broadened and a 'failure to prevent' corporate offence was added by the Combatting Foreign Bribery Act 2024.
The ABA Banking Code of Practice: what it covers and how it's enforced
The Australian Banking Association's Banking Code of Practice binds subscribing banks to standards that go beyond the law. Here's the framework, the BCCC oversight, and how customers use it.
APRA CPS 511 Remuneration: deferral, malus and clawback explained
APRA's Prudential Standard CPS 511 sets remuneration design + governance rules for APRA-regulated entities. Here's the deferral percentage, the malus/clawback regime, and who is in scope.
Australia's proposed beneficial ownership register
A public beneficial-ownership register has been federal-government policy since 2022 and is in Treasury consultation. Here's where it stands today and what the existing partial disclosures cover.
Frequently asked
Does the 7-step safe harbour in s 961B(2) protect every adviser?
Only if all 7 steps are completed. Courts have read the steps strictly — missing or perfunctory completion of any step removes safe-harbour protection and the broader best-interests test under s 961B(1) applies. The safe harbour is not a checklist exercise; it documents the substantive analysis.
Does the DBFO 'principles-based' SOA mean we can write shorter advice?
Shorter, more focused — yes. The reforms modernised the SOA content rules toward the substance of advice given. The best-interests duty + Code of Ethics + record-keeping standards still drive the depth of analysis. The reforms reduce formal-content padding, not analytical rigour.
If I provide tax-related advice as a relevant provider, do I need to register with the TPB separately?
Streamlined post-2024. The AFS Licensee notifies TPB of QTRP status via the simplified mechanism. The QTRP is then subject to the TPB Code of Professional Conduct (including the 8 additional 'Det 8' obligations) alongside the Corporations Act Code of Ethics.
How is CSLR levy calculated?
The levy is determined by ASIC annually after consultation with the CSLR Operator. It is sub-sector apportioned (personal advice, credit intermediation, securities dealing, credit provision) and within sub-sector apportioned on the basis of relevant-provider headcount and other risk indicators. First-year levy was material for personal advice — monitor each levy round.
What does the Code of Ethics Standard 3 'conflicts of interest' mean in practice?
Standard 3 prohibits acting where a conflict exists between your interests and the client's interests. The Code is stricter than the Corporations Act conflict rules — disclosure does not cure the Standard 3 issue. Common Standard 3 trigger areas: in-house product preference; vertically-integrated structures; commission-driven insurance; SMSF-property advice.
What's the breach-reporting threshold under s 912D as of today?
Post-2021 reforms expanded reportable situations to include any 'reportable situation' — a deemed-significant breach under s 912D(4) (specified breaches of core obligations) plus any breach of a 'core obligation' that is significant. The threshold is materially lower than pre-2021. ASIC INFO 259 sets the practical guide.
Do general-advice-only providers need to comply with this whole stack?
No. Best-interests duty, SOA, ongoing-fee consent, CSLR levy (for personal-advice sub-sector), TPB QTRP — none apply to general-advice-only providers. General-advice providers face AFSL general obligations + DDO + anti-hawking + AFCA. Personal-advice-to-retail is the dividing line.
Free assessment
Get a personalised obligation list
2-minute structured check tailored to your business.
AI advisor (waitlist)
Ask any compliance question
Coming Phase 2 — grounded answers with citations.