AFSL Acquisitions
Acquiring an AFSL can accelerate market entry, but only when the licence scope, governance and operating model are aligned to how you intend to run the business. We support buyers through due diligence, transition planning and post-completion change—so you can operate with confidence from day one.
Acquiring an existing Australian Financial Services Licence through a change of control
of the licence-holding entity is an established pathway to market. The transaction is effected by a
transfer of the shares in the entity that holds the AFSL. The licence itself is not transferred; rather, the
entity retains its licence and the new controllers assume responsibility for ensuring compliance with all
licensee obligations. ASIC must be notified within the timeframe prescribed by section 912DA of the
Corporations Act 2001.
The acquisition pathway can offer material advantages over a de novo application, including a shorter
time to market, the ability to leverage existing authorisations and compliance infrastructure, without
needing to go through an application assessment process. However, these advantages are only realised
when the target licence is properly assessed, the transition is carefully planned, and the acquiring entity
is prepared to operate the licence from the date of completion.
What we cover
Key acquisition workstreams
We run acquisition workstreams like a project: clear scope, evidence-based findings, and a practical transition plan. The objective is to reduce uncertainty before completion and ensure the AFSL can support your intended services immediately after.
Typical outcomes: a documented risk view, a prioritised remediation plan, and a 30/60/90-day operating roadmap aligned to your governance and reporting cadence.
Target screening & scope fit
Confirm the AFSL authorisations, conditions and business profile align to your intended products, distribution model and client base. Identify where a variation, restructure or staged approach is required.
Due diligence (regulatory & operational)
Review licence scope, compliance frameworks, outsourcing arrangements, financial position, governance, incident history and key registers to identify remediation effort and integration risk.
Governance, controls & reporting
Assess board oversight, compliance reporting, decision records, monitoring, and breach/incident processes. Define the control uplift required to support your operating model post-completion.
Responsible manager coverage & evidence
Validate capability, time allocation and documentation for current and proposed responsible managers. Identify gaps early and prepare an evidence and uplift plan to reduce key-person risk.
Transition plan & first 90 days
Build a practical 30/60/90-day plan covering governance cadence, policy uplift, monitoring, training, outsourcing oversight and reporting. Establish owners, timelines and artefacts required for a smooth handover.
Post-completion changes & variations
Support changes to licence scope, business description, key people and control environment. Prepare documentation and coordinate sequencing so the AFSL remains compliant while you scale.
Common acquisition risks we help you manage
A clear risk view and a credible uplift plan can protect valuation, reduce surprises, and support a smoother transition after completion.
Licence scope mismatch
Confirm authorisations align to your intended products and services, and identify where a variation or staged approach is required.
Governance & control gaps
Assess oversight, compliance reporting, incident management and decision records to ensure the AFSL can support your operating model.
RM coverage & evidence
Validate responsible manager coverage and documentation, and plan enhancements to reduce key-person dependency.
Legacy compliance debt
Surface policy and register gaps, monitoring weaknesses and training uplift required—then prioritise actions for the first 30/60/90 days.