ASIC reiterates warning on adviser education and register compliance

New guidance details steps to review and correct records

ASIC reiterates warning on adviser education and register compliance

Insurance News

By Roxanne Libatique

The Australian Securities and Investments Commission (ASIC) has issued what it describes as a final warning to the financial advice industry, urging existing providers and their Australian financial services (AFS) licensees to take urgent steps to meet education standards and correct records on the Financial Advisers Register before key deadlines take effect from Jan. 1, 2026.

ASIC’s message is directed at “relevant providers” who intend to continue providing personal advice to retail clients on relevant financial products after Dec. 31, 2025. These advisers generally have until Jan. 1, 2026, to meet the qualifications standard under section 921B(2) of the Corporations Act 2001 if they wish to keep advising without interruption.

The regulator has warned that advisers who are existing providers are running out of time to confirm they meet the education and training requirements, verify the accuracy of their Financial Advisers Register entries, and ensure their AFS licensees have notified ASIC of their qualifications or, where applicable, reliance on the experienced provider pathway.

New instructions for checking and correcting register data

ASIC has released an updated webpage, “Updating the Financial Advisers Register – Qualifications and training details,” which sets out step-by-step instructions on how licensees and advisers can review ASIC’s one-off dataset and identify gaps or errors in qualifications and training information. The guidance explains how to lodge a Maintain (Update) transaction via ASIC Connect to correct incomplete or inaccurate data and includes troubleshooting information for common issues.

Relevant providers cannot amend the register themselves and must work through their AFS licensees. Licensees remain responsible for ensuring records for all relevant providers they authorise are accurate and current on the Financial Advisers Register. 

ASIC has reminded licensees that they must notify ASIC of changes to advisers’ details within 30 business days of a change to avoid a late fee. The regulator has also signalled that it will continue to monitor register data in the lead-up to January 2026 and may consider further regulatory responses if needed.

Consequences where education standards are not met

ASIC has outlined distinct consequences for existing providers who do not satisfy the qualifications standard by Jan. 1, 2026. If an adviser has not met the standard and their AFS licensee ceases their authorisation on or before Dec. 31, 2025, this may preserve the adviser’s existing provider status for the purposes of future pathways. However, if the adviser remains authorised and that authorisation ceases automatically on Jan. 1, 2026, by operation of law, the adviser will be treated in effect as a new entrant. 

In that scenario, the adviser would need to complete a professional year and obtain an approved degree or equivalent qualification as set out in Schedule 1 of the Corporations (Relevant Providers Degrees, Qualifications and Courses Standard) Determination 2021 before they could resume providing personal advice to retail clients. They would not be able to use the existing provider pathways in Part 3 of the determination to meet the standard. 

Tax (financial) advice obligations run in parallel

Existing providers who provide tax (financial) advice services face additional requirements. Unless exempt, they must complete specified commercial law and taxation law courses by Dec. 31, 2025, in order to continue offering tax (financial) advice services to retail clients on relevant financial products from Jan. 1, 2026.

Once those courses are completed, AFS licensees are required to update the Financial Advisers Register to reflect the adviser’s eligibility to provide tax (financial) advice services. ASIC’s latest figures show that many existing providers still need either to complete these courses or to have their completion properly recorded. 

Spot checks show large cohort still not meeting standards

ASIC’s most recent spot check of the Financial Advisers Register, based on data as at Nov. 20, 2025, identified 15,469 relevant providers on the register. Of these, licensees had notified ASIC that 7,959 advisers hold an approved degree or qualification, 4,212 are relying on the experienced provider pathway, and 972 are recorded as both holding an approved qualification and relying on that pathway. 

The remaining 2,326 relevant providers are recorded as not yet having met the qualifications standard. Within this group, ASIC has identified 836 advisers who may be eligible for the experienced provider pathway but whose AFS licensees have not yet notified ASIC of that status.

ASIC also found that 827 relevant providers who are existing providers, unless exempt, would need to complete the specified commercial law and taxation law courses to continue providing tax (financial) advice services from Jan. 1, 2026. 

Earlier data from Sept. 16, 2025, showed a similar pattern. At that time, the Financial Advisers Register recorded 15,432 relevant providers. Of these, 7,081 were reported as holding an approved degree or qualification, 3,966 as relying on the experienced provider pathway, and 926 as both. The balance of 3,459 advisers had not yet met the qualifications standard, with 1,371 of them potentially eligible for the experienced provider pathway but not recorded as such. 

Data quality expectations and implications for insurers

ASIC has highlighted recurring data issues on the Financial Advisers Register, including advisers being flagged as relying on the experienced provider pathway despite not meeting the criteria, training, or qualifications being coded as contributing to the standard when courses are incomplete or not approved, and advisers who have met the standard but whose courses are not marked as “going towards meeting the qualifications standard.” 

AFS licensees can correct these errors by lodging a Maintain (Update) transaction via ASIC Connect. ASIC has reiterated that it is an offence to knowingly provide false or misleading information to the regulator or to fail to take reasonable steps to ensure information is true and correct, and that it is also an offence not to update the register within 30 business days of a relevant change. 

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