CPD: ASIC’s 2026 review of qualification compliance – practical implications

ASIC’s review of the FAR demonstrates that meeting the qualification standard is only half the compliance task.

Imagine you were qualified but nobody told ASIC

Imagine you had met the exacting educational standards to practice as a financial adviser, but someone didn’t tell ASIC, or at least, didn’t tell them correctly, and as a result you weren’t authorised to give advice.

Incredibly, that happened to over 100 advisers in the middle of 2026, following the 1 January Financial Adviser Register (FAR) deadline for adviser qualifications, and a subsequent ASIC review into AFSL adherence.

To help readers avoid falling into the same trap, this article explores the legislative framework underpinning adviser and licensee obligations around adviser educational standards, the record-keeping failures identified by ASIC through their review, and the practical steps firms can take to ensure they would withstand similar regulatory scrutiny.

Education – the foundations of a profession

Foundational to the credibility of financial advice profession – in the eyes of the community, regulators, and policy makers – is the framework of professional standards within which advisers must operate. As with other professions, this framework includes both educational and conduct standards.

Financial advice made its first serious strides towards such a framework in 2017, when the Federal Government passed the Corporations Amendment (Professional Standards of Financial Advisers) Act^[1]. This Act introduced the standards we now take for granted, including the need to complete the national adviser exam and Professional Year, the Code of Ethics, continuing professional development (CPD) and of course the minimum education/qualification standards.

While the educational standards became effective 1 January 2019^[2], the quantum of the change, and advocacy on behalf of the profession, saw a number of transitionary arrangements put in place.

The 1 January 2026 qualifications deadline

After several years of these transitionary arrangements, 1 January 2026 finally saw a single, universal deadline by which every existing adviser had to meet the qualifications standard, (either through formal education or the permitted Experienced Provider pathway).

In the lead up to this deadline, ASIC was very active in reminding advisers about the need to not only meet these requirements, but to properly record their compliance with these requirements via the FAR^[3]. ASIC concerns were well founded – as late as 1 December 2025, their own figures showed 2,326 of the 15,469 relevant providers on the FAR had yet to meet the qualifications standard^[4], a gap IFA reported was leaving thousands of advisers “at risk” of missing the cutoff^[5].

ASIC’s review after the 1 January deadline

While ultimately that prediction didn’t come to pass, independent analysis published in Money Management in February 2026 suggested there were still around 200 advisers registered but not qualified^[6].

This was much closer to the figure uncovered by ASIC themselves when they conducted their own review in the first half of 2026.

Specifically, ASIC found 132 advisers had no record of any qualification or training course meeting the required standard, with some relying on nothing more than passing the adviser exam^[7].

As the responsibility for adviser records on the FAR sits with the licensee, ASIC intervened directly with the 82 AFS licensees responsible for these advisers (rather than the advisers themselves). Following this intervention, 106 of these records were corrected, while the remaining 26 advisers had their authorisation to provide personal advice withdrawn.

In its own guidance following the review, ASIC advised^[8] that licensees should check that “the financial adviser exam has not been incorrectly marked as going toward meeting the qualifications standard” – the specific error at the centre of the 132 flagged cases.

What is remarkable about this finding is that over 100 advisers were in breach of their compliance obligations – and operating without authorisation – not because they weren’t qualified, but because they (or more precisely their licensee) hadn’t recorded those qualifications properly.

ASIC’s review is thus a timely reminder that meeting the qualifications standard is only part of the compliance task. Advisers and licensees must also be able to demonstrate that compliance through accurate and up-to-date records.

What the law says about adviser qualifications

The adviser qualifications standards are legislated and defined in the s921B (2) of the Corporations Act, and in the Corporations (Relevant Providers Degrees, Qualifications and Courses Standard) Determination of 2021^[9].

New advisers

For new advisers (anyone entering the profession after the standard took effect on 1 January 2019), the educational requirements are straightforward. The legislation requires ‘relevant providers’, (advisers authorised to give personal advice to retail clients on relevant financial products), to hold an approved degree or an equivalent qualification.

Approved degrees and qualifications are clearly defined in Schedule 1 of the 2021 Determination, and in the vast majority of cases are traditional business degrees, including commerce, accounting, finance, and financial planning. Schedule 1 goes to a further level of granularity, listing approved courses by institution, enrolment date, and even specific units required within that course.

Existing advisers

For advisers already practising before the standard took effect, the requirements are/were more complex. Existing advisers were able to meet the same standard required of new entrants (a matching Schedule 1 degree) or use one of two transitional pathways. In total that meant three routes to complying:

1. A formal degree
   Completing a bachelor’s degree or higher that matches exactly a qualification listed in Schedule 1 of the Determination (see above).
2. An equivalent qualification under Part 3 of the Determination
   A separate route for existing providers, allowing them to meet the standard by giving them credit for existing qualifications, including those offered by professional associations (such as the FAAA). In many cases the standard was able to be met by supplementing these ‘equivalent qualifications’ with one or more recognised bridging units (including Ethics, Behavioural Finance, and Regulatory & Legal obligations). 1 January 2026 was a hard deadline for this route.
3. The Experienced Provider pathway
   One of the more substantive decisions regarding adviser education standards related to the treatment of the many advisers already in the profession, who had been successfully serving their clients for years. After much lobbying^[10], an ‘Experienced Provider’ definition was introduced in 2023, and advisers meeting this definition (see below) can access this pathway by making a written declaration to their AFS licensee confirming they satisfy this requirement. There is no fixed deadline for making this declaration, however advisers who wished to continue providing personal advice without interruption from 1 January 2026 needed to have made the declaration before that date if they were relying on this pathway. Advisers who failed to do so lost their relevant provider status from 1 January 2026. ASIC’s INFO 281^[11] makes clear, however, that they may subsequently regain that status if they make the declaration before being re-authorised and otherwise satisfy the legislative requirements.

Definition of Experienced Provider

To satisfy the definition, an adviser must have had at least ten years’ cumulative experience giving personal advice to retail clients between 2007 and 2021, a clean disciplinary record as of 31 December 2021, and a pass in the financial adviser exam by their cut-off date of either January or October 2022^[12].

The recording of qualifications on the FAR continues to be problematic

Interestingly, the problems identified by ASIC in the 2026 FAR review were also discovered in 2024^[13], when their spot-check found the same category of error occurring frequently enough to be concerning.

Common errors uncovered in 2024 included:

• some of the qualifications marked as ‘approved’ did not accurately match the wording of the course in the 2021 Determination
• some of the qualifications marked as ‘approved’ were not approved qualifications, they were professional designations (e.g. ‘Certified Financial Planner’)
• some of the qualifications marked as ‘approved’ were not, in isolation, approved qualifications, they were bridging courses. These may be listed in the Determination but are required to be coupled with another qualification to meet the requirements of the professional standard, and
• some of the qualifications marked as ‘approved’ were not approved qualifications under the Determination (examples included: the Financial Adviser Exam, Australian Qualifications Framework 1-5 qualifications, and Regulatory Guide 146 training/qualifications).

Following that process, ASIC called on AFS licensees to assess the accuracy of what they had recorded on the FAR in relation to their advisers.

The FAAA had raised near-identical concerns with its own members a month before the deadline^[14], flagging two of the most common issues it was seeing – advisers who hadn’t flagged which pathway they intended to use, and Experienced Provider pathway advisers who either began advising too late to qualify or hadn’t passed the exam before their cut-off.

Is qualification granularity part of the problem?

Advisers typically value concrete – as opposed to vague – guidance from the regulator, however when it comes to complying with the qualifications standard, this specificity may actually be contributing to non-compliance through inaccurate recording.

As explained earlier, Schedule 1 of the Determination lists specific degree titles, from specific universities, often tied to a specific enrolment date range and a specific list of named units. The same degree name can appear multiple times as different versions of itself, because the unit structure changed over the years, and each version carries its own conditions. Some versions may require an ethics bridging unit, while others will explicitly exempt from that requirement.

What is challenging is that none of this is visible just from looking at a degree certificate or someone’s CV. A licensee who recognises a familiar degree name can easily miss that the adviser enrolled outside the approved window or completed a different combination of units to the one that particular version requires. This can lead to the situation where the adviser appears qualified on paper, while on the FAR the qualification recorded doesn’t actually satisfy the law.

What does the right evidence actually look like?

Acting in good faith is not, in itself, sufficient. Licensees, as those responsible for completing FAR records, need to ensure they have the right documentary evidence to (1) support any entry they make on the FAR, and (2) rely on in the event that ASIC knocks on the door.

The most obvious starting point is of course the adviser’s final academic transcript, not a degree certificate, and not a CV listing the qualification by name. A transcript shows the actual units completed, the dates they were completed, and the specific course code, which is what needs to be checked against the relevant item in Schedule 1 of the Determination. Where an adviser’s academic transcripts or other records do not demonstrate that a listed degree satisfies all of the conditions specified in the Determination, the licensee should obtain either written confirmation from the education provider that those conditions have been met, or written approval from the Minister that the qualification is equivalent to the approved qualification.

A pass in the financial adviser exam is not, on its own, sufficient evidence of anything beyond the exam itself. As ASIC’s own review made clear, this was one of the most common errors: an exam pass recorded as though it satisfied the qualifications standard in isolation. The exam is a separate requirement, and while it’s necessary for most pathways, it should be treated as an addition to – not instead of – an equivalent qualification, or an Experienced Provider declaration.

For advisers relying on the Experienced Provider pathway, the relevant evidence is the written declaration itself, correctly dated and held by the licensee, confirming the adviser meets the definition – ten years’ experience within the specified window, a clean disciplinary record as at the specified date, and an exam pass by the applicable cut-off.

At a high level, the evidence threshold is therefore quite simple – there needs to be a specific document, matched against a specific requirement.

Practical steps for licensees

Good governance requires robust processes, even around requirements that seem basic. There are a number of steps AFSLs should consider in order to strengthen their compliance with adviser qualification standards.

• Make verification continuous not one-off
  Qualification verification should not be a one-off compliance exercise, only to be completed when an adviser first joins a licensee. Advisers can expand their authorisations and change licensees. Periodically review qualification records to minimise the risk of FAR records gradually becoming out of date.
• Assign clear accountability
  Licensees, not advisers, are responsible for maintaining accurate FAR records. Firms that clearly assign responsibility for verifying adviser qualifications and require that supporting documentation is complete before authorisation is granted or renewed, are less likely to experience the issues identified by ASIC.
• Licensee transfers are an obvious verification point
  Every transfer between licensees should trigger the verification of qualifications from scratch. Under ASIC’s guidance on the Experienced Provider pathway, a new licensee should independently confirm an adviser’s eligibility rather than relying solely on checks performed by a previous licensee.
• Rely on primary documentation
  As previously discussed, the granularity with which approved courses are listed in the legislation means verification should rely on primary source documents rather than secondary evidence. Use full academic transcripts rather than CVs or certificates or even LinkedIn profiles. Formal documentation is preferable to self-reporting. Matching degree titles, enrolment periods, completed units and any applicable bridging requirements against Schedule 1 of the Determination helps minimise the types of recording errors identified during ASIC’s reviews.
• The Experienced Provider pathway is still open
  As explained earlier, missing the declaration required under the Experienced Provider pathway does not necessarily prevent an adviser from relying on that pathway in the future. As detailed in INFO 281, advisers who lost relevant provider status because they failed to make the declaration before 1 January 2026 may still be able to regain that status by making the declaration before being re-authorised, provided they continue to satisfy the legislative requirements.

Additionally, the ASIC website provides comprehensive guidance on assessing qualifications^[15] and updating the register^[16].

In summary

ASIC’s review of the FAR demonstrates that meeting the qualification standard is only half the compliance task. Licensees must also be able to prove, through accurate FAR records and appropriate documentary evidence, that each adviser meets the standard they are relying on. For many firms, that means shifting qualification verification from an administrative task completed once, to an ongoing compliance process capable of withstanding regulatory scrutiny.

There is some urgency with this task, with ASIC already signalling their scrutiny isn’t finished.

As Money Management reported^[17], ASIC may yet conduct a further review of the specific qualifications and training courses licensees have marked against the standard, rather than simply confirming that a qualification of some kind has been recorded. Meaning time, as always, is of the essence.

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References:
[1] https://www.asic.gov.au/regulatory-resources/financial-services/financial-advice/professional-standards/
[2] https://www.asic.gov.au/about-asic/news-centre/news-items/asic-issues-update-on-compliance-with-the-financial-adviser-qualifications-standard/
[3] https://www.asic.gov.au/about-asic/news-centre/news-items/asic-renews-warning-for-afs-licensees-ahead-of-deadline-for-financial-advisers/
[4] https://www.moneymanagement.com.au/asics-final-warning-shows-15-advice-industry-risk/
[5] https://www.ifa.com.au/the-final-countdown-2300-advisers-still-at-risk-of-missing-education-deadline/
[6] https://www.moneymanagement.com.au/registered-but-unqualified-far-records-reveal-advice-discrepancy/
[7] https://www.asic.gov.au/about-asic/news-centre/news-items/asic-issues-update-on-compliance-with-the-financial-adviser-qualifications-standard/
[8] https://www.asic.gov.au/about-asic/news-centre/news-items/asic-issues-update-on-compliance-with-the-financial-adviser-qualifications-standard/
[9] https://www.legislation.gov.au/F2021L01848/latest/text
[10] https://www.professionalplanner.com.au/2023/04/the-sun-wont-set-on-the-experience-pathway/
[11] https://www.asic.gov.au/regulatory-resources/financial-services/financial-advice/professional-standards/accessing-the-experienced-provider-pathway/
[12] https://www.asic.gov.au/regulatory-resources/financial-services/financial-advice/professional-standards/accessing-the-experienced-provider-pathway/
[13] https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2024-releases/24-142mr-asic-urges-afs-licensees-to-correct-records-on-the-financial-advisers-register/
[14] https://www.adviservoice.com.au/2025/12/faaa-calls-for-advisers-to-check-records-to-ensure-they-are-eligible-to-provide-financial-advice-into-2026/
[15] https://www.asic.gov.au/regulatory-resources/financial-services/financial-advice/professional-standards/qualifications-standard/assessing-relevant-provider-qualifications/
[16] https://www.asic.gov.au/regulatory-resources/financial-services/financial-advice/professional-standards/qualifications-standard/updating-the-financial-advisers-register-qualifications-and-training-details/
[17] https://www.moneymanagement.com.au/asic-reveals-adviser-qualification-review-outcome/