AFSL Applications
End-to-end support to scope, prepare and lodge your Australian Financial Services Licence application—built for fintechs, broker/dealers and financial advice businesses that want a clear pathway and a submission pack that stands up to scrutiny.
Applying for an Australian Financial Services Licence requires a comprehensive understanding of ASIC’s expectations, the general obligations imposed under Part 7.6 of the Corporations Act 2001, and the evidentiary standard required to demonstrate that the applicant has the organisational competence, compliance arrangements and financial resources to operate a licensed business. AFSL Advisory provides end-to-end support through every stage of the application process.
What we do
End-to-end AFSL application support, built for operational readiness
We help you turn your business model into a clear licensing scope, a coherent submission pack and a practical compliance framework—so you can reduce rework, respond to information requests efficiently and move through the process with confidence.
Scope & licensing strategy
AFSL Advisory begins each application engagement by defining the precise authorisations the applicant requires. The scope of an AFSL is not generic — it reflects the specific financial services and financial products the licensee is authorised to provide, and any mismatch between the licence scope and the business’s actual activities creates regulatory risk from day one.
We assess the applicant’s proposed business model, intended client base (retail, wholesale, or both), and product and service offering against the financial service and financial product definitions in the Corporations Act 2001. We then prepare a recommended authorisation schedule and confirm the appropriate licence conditions before any application documentation is drafted.
Where the applicant is considering both a de novo application and an acquisition of an existing licence, we provide a comparative assessment of both pathways, including estimated timeframes, cost, and regulatory risk.
Readiness & evidence pack
ASIC assesses each application against the general obligations in section 912A of the Corporations Act and the grounds for refusal in section 913B. A common reason for delay or refusal is insufficient evidence that the applicant has the organisational competence to provide the financial services covered by the licence.
Organisational competence is assessed primarily through the responsible managers nominated in the application. Under RG 105, each responsible manager must satisfy one of five prescribed pathways combining relevant experience and qualifications. ASIC scrutinises the evidence carefully — generic CVs and broad claims of experience are routinely queried.
We assess each proposed responsible manager against the RG 105 competency standards before the application is lodged. Where gaps exist, we identify them early and work with the applicant to address them, whether through additional evidence, supplementary appointments, or structured remediation.
We also assess the applicant’s financial position against the financial requirements applicable to the proposed authorisations, including the cash needs requirement and net tangible assets calculation under RG 166.
Policies, procedures & governance
A complete AFSL application requires a suite of compliance policies and governance documents that demonstrate the applicant has arrangements in place to meet its obligations as a licensee from the date the licence is granted. Under RG 104, ASIC expects these documents to be substantive and tailored — not templated documents that do not reflect the applicant’s actual operating model.
AFSL Advisory drafts all required compliance documentation as part of the application engagement. This includes:
- Compliance framework and compliance plan — setting out the licensee’s compliance obligations, monitoring program, breach reporting process and annual review arrangements
- Risk management framework — identifying the key regulatory and operational risks applicable to the business and the controls in place to manage them
- Conflicts of interest policy — addressing the identification, management and disclosure of conflicts relevant to the applicant’s business model
- Complaints handling policy and procedure — consistent with the requirements of RG 271 and the obligation to be a member of AFCA
- Outsourcing policy — covering oversight of material service providers and the obligations that cannot be outsourced
- Training and competency policy — covering CPD obligations, responsible manager maintenance, and staff training requirements
- Record-keeping policy — addressing the specific record-keeping obligations applicable to the authorisations sought
- Financial requirements monitoring — procedures for tracking ongoing compliance with net tangible assets and cash needs obligations
Each document is drafted to reflect the applicant’s specific authorizations, client base and operating model. We do not provide generic templates.
Lodgement & information requests
AFSL applications are lodged through ASIC’s online portal. Once lodged, ASIC may issue one or more requests for further information before making a determination. The quality and responsiveness of replies to these requests is a significant factor in overall processing time.
We manage the lodgement process and all post-lodgement correspondence on behalf of our clients. This includes:
- Reviewing the completed application in its entirety before lodgement to identify and address any inconsistencies
- Preparing the financial projections and cash flow statements required to support the financial requirements assessment
- Coordinating execution of the required declarations by the applicant’s responsible officers
- Lodging the application and paying the applicable ASIC fee ($3,721 for a body corporate applicant under standard authorisations)
- Drafting all responses to ASIC information requests, with the objective of resolving each query in a single exchange
- Maintaining a matter register tracking the status of the application, outstanding items and target dates
Typical ASIC processing times for a new AFSL application range from 12 to 24 months. Incomplete applications, inadequate responsible manager evidence, and poorly drafted compliance documentation are the primary causes of extended processing times. A well-prepared application materially reduces this risk.