AI rewards authority. Financial services regulates communications.
Licensees and advisers may find Similarweb’s 2026 report on AI visibility particularly problematic. AI has made public authority commercially valuable, but many financial services firms still treat public communication as a compliance risk to be contained, rather than an asset to be managed.
That tension is becoming increasingly problematic. Similarweb’s 2026 report on AI visibility suggests that AI recommendations can influence real user behaviour even when no referral click is recorded. Users who received a ChatGPT brand recommendation were 2.5 times more likely to visit that brand’s website within seven days, with most AI-influenced visits later arriving through search rather than AI referrals. Those visitors also engaged more deeply, viewing nearly twice as many pages and spending about twice as long on site. AI citation drives search activity and engagement. Keywords and technical SEO remain important, but AI systems tend to surface sources that are accessible, relevant, corroborated and recognised across the wider information environment.
The data doesn’t prove that every AI citation becomes a client enquiry, but it does show why AI visibility should be treated as an upstream demand signal rather than a conventional referral source.
The implication is significant: AI visibility isn’t just a brand metric. It’s an upstream demand-generation channel that traditional attribution models often fail to measure.
For licensees and advisers, the implication is uncomfortable: authority may increasingly shape demand before traditional attribution systems can see it.
For financial services, this isn’t simply a visibility problem. It’s a governance problem. The firms most likely to benefit from AI-mediated authority won’t be those that let advisers publish freely or those that treat silence as compliance. The advantage will sit with licensees that can separate public expertise from regulated advice and supervise that distinction properly.
Governed authority means advisers can demonstrate expertise within defined boundaries: what they can explain, what they can promote, what requires review, what must be sourced, and what should not be published without advice-specific controls.
AI visibility has made public expertise commercially valuable. For financial services licensees, that raises an immediate compliance question: how can advisers publicly demonstrate expertise without crossing into regulated advice? The answer isn’t silence, it’s governed authority.
Editor’s note: An earlier version of this article was published by Professional Planner. This expanded edition has been updated for AFSL and ACL licensees and incorporates additional guidance on communication governance, ASIC’s updated Regulatory Guide 234 and practical implementation considerations.
Authority isn’t advice
Financial planning may be mired in misinterpretations, but one of the industry’s biggest misconceptions is that demonstrating expertise necessarily means providing financial advice.
Demonstrating expertise doesn’t automatically mean providing financial advice.
Whether a communication constitutes financial product advice depends on its content, context and overall impression. Educational material that explains regulatory obligations or industry issues is not automatically financial product advice. However, communications that are intended to influence, or could reasonably be regarded as influencing, a person in making a decision about a financial product may fall within the statutory definition.
Effective governance therefore focuses on controlling how information is communicated rather than preventing subject-matter experts from publishing altogether.
The answer isn’t to prohibit public communication. It is to classify communication properly.
Licensees that fail to distinguish these categories often adopt unnecessarily restrictive compliance arrangements that reduce visibility and restrain growth without materially reducing risk.
Regulation and communication
Success requires more than compliance approval. It requires clearly defined content categories, approval pathways, source standards, review criteria and ongoing monitoring. In other words, content governance becomes part of the licensee’s compliance infrastructure, not an obstacle to visibility.
For years, licensees have encouraged advisers to educate rather than sell. AI makes that principle more commercially important. The best visibility strategy is no longer simply about keywords and search volume. It is about being recognised as an authoritative source.
That outcome requires more than compliance approval. It requires clearly defined content categories, approval pathways, source standards, review criteria and ongoing monitoring.
In other words, content governance simply becomes another component of the licensee’s compliance infrastructure.
What does ASIC expect from public communications?
Demonstrating expertise does not remove a licensee’s regulatory obligations. Every public communication remains subject to the same legal requirements that apply regardless of whether it appears on a website, social media platform, webinar, podcast or AI-generated summary.
In June 2026 ASIC updated Regulatory Guide 234 to reflect modern digital marketing practices, including the increasing use of artificial intelligence in producing and distributing content. The updated guide reinforces that firms remain responsible for the overall impression created by their communications, even where AI tools assist with drafting or distribution.
ASIC expects promotional material to be accurate, balanced and capable of substantiation. Firms should not assume that because content is educational or AI-assisted it falls outside regulatory expectations.
This means communication governance is no longer simply a marketing issue. It forms part of a licensee’s compliance framework and should include documented approval pathways, review processes, monitoring and periodic refresh of published material.
The choice isn’t between visibility and compliance
This is where I think the industry has framed the issue incorrectly.
The choice isn’t binary. Licensees don’t need to choose between publishing freely and accepting regulatory risk, or publishing nothing and assuming silence is compliance.
The real choice is between unmanaged authority and governed authority.
Unmanaged authority leaves advisers publishing without clear boundaries, review standards, or accountability. Governed authority gives them a framework to demonstrate expertise safely, with content controls that reflect both the firm’s culture and its compliance obligations.
Effective communication governance begins before writing starts. By classifying content according to risk, intended audience, and regulatory context, licensees can apply proportionate review processes rather than treating every publication as though it presents the same compliance risk.
That’s the better compliance model. Not less communication, but better-governed communications.
Authority and Practice
The practical reality is that AI has significantly increased the commercial value of educational content. Organisations recognised as authoritative are increasingly recommended when prospective clients ask questions about retirement, superannuation, investing, or financial advice.
For retirement-focused licensees, the practical implication is significant. People researching retirement income, aged care, superannuation, estate planning, SMSFs or financial advice may increasingly ask AI for explanations or provider suggestions before contacting anyone. Even where the retiree is not the AI user, their adult children or professional advisers may be.
That makes authority a commercial asset, rather than simply a marketing objective.
That conclusion is strongest in retirement advice where decisions are high-consideration, trust-dependent and education-led, which makes AI-mediated authority especially valuable. Retirees and pre-retirees do not usually start with “Which licensee should I use?” They start with questions like:
- “How much do I need to retire?”
- “Should I start an account-based pension?”
- “How does downsizer contribution work?”
- “Should I pay off debt before retiring?”
- “How do I choose a financial adviser?”
Those are precisely the kinds of questions AI systems are built to answer, and precisely the kinds of questions that allow authoritative firms to become visible before a prospective client is ready to make contact.
The same principle applies across financial services.
Consumers increasingly research complex topics before contacting a business. They may ask AI about SMSFs, managed accounts, investment governance, insurance strategy, responsible lending, commercial lending, compliance obligations or AFSL requirements.
Organisations that consistently publish credible, well-governed educational material are more likely to become part of those conversations than organisations that remain largely invisible.
That presents both a strategic opportunity and a governance challenge.
Historically, conservatism and fear have restrained digital marketing. Some licensees managed regulatory risk by restricting what advisers can publish to avoid inadvertently providing personal advice, breaching advertising requirements or creating misleading impressions.
Those concerns are understandable, but conservatism and excessive caution now carry commercial risk, particularly since silence is more costly in retirement advice.
If your licensees and advisers become invisible because they can’t demonstrate expertise publicly, AI will recommend those organisations that do, providing an advantage to those prepared to invest in authoritative educational content. But the businesses that embrace the leverage that AI provides also need to ensure that public content doesn’t become a substitute for financial advice.
Increasingly, for a profession focusing on credibility and client acquisition, silence is a competitive decision. However, the commercial case for visibility only matters if licensees can separate public expertise from regulated advice. That distinction is where much of the industry still gets stuck.
A better question for compliance teams
Many advisers produce content and then ask their compliance team “Can I publish this?”. A more useful question is: “What controls are required to publish this safely?”
You may say it’s the same thing but, in reality, that change in thinking is significant because the “How” approach recognises that visibility has commercial value while accepting that communications also require appropriate governance.
So, compliance’s attention shifts to enabling compliant communication rather than preventing it. It’s a pivot with significant upside.
What should licensees do?
To realise the opportunities the research identifies, licensees need to build a communication governance framework that supports promotion rather than enforcing a control framework that discourages thought leadership.
In practice, communication governance should operate like every other component of a compliance framework. Rather than relying on ad hoc reviews or individual judgement, licensees should establish documented controls that produce evidence of oversight and consistent decision-making.
An effective communication governance framework should:
- Classify content before it is created: distinguish educational content, general advice, personal advice, promotional material, product commentary and client examples.
- Set approval pathways by risk: apply lighter review to low-risk educational content and heightened review to product discussion, strategy discussion, case studies, performance claims or calls to action.
- Require source discipline: use authoritative sources, balanced explanations and current regulatory references.
- Control adviser execution: provide approved formats, templates, disclaimers and review triggers.
- Monitor published material: include public communications in the supervision program rather than treating publication as the end of the process.
- Refresh or withdraw content: periodically review older material when law, regulatory guidance, product settings or firm policy changes.
Questions boards and responsible managers should ask
Boards and Responsible Managers should be able to answer:
- Who approves high-risk public communications?
- How do we distinguish education from financial product advice?
- Can we demonstrate why the content was approved?
- How do we monitor adviser websites and social media?
- How do we identify outdated content?
- What evidence demonstrates that our communication controls are operating effectively?
The strategic lesson
AI has increased the commercial value of recognised expertise, but it has not reduced the regulatory obligations that apply to financial services communications.
The organisations that succeed will not be those that publish the most content, nor those that prohibit their people from communicating altogether. They will be those that build communication governance into their compliance infrastructure so that expertise can be demonstrated consistently, responsibly and with appropriate oversight.
The question is no longer whether authority creates risk. The question is whether your governance framework allows your organisation to demonstrate authority safely.
Build authority without weakening your compliance controls
Assured Support helps AFSL and ACL businesses design communication governance frameworks that support public expertise while managing advice, advertising and supervision risk.
[complyᵉ] provides the infrastructure to document approvals, assign accountability, retain evidence, monitor published content and track remediation.
Talk with an expert about building a defensible communication governance framework.
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Further reading
Frequently Asked Questions
AI increasingly recommends organisations it considers authoritative when users ask questions about retirement, superannuation, investing or choosing a financial adviser.
Recent research suggests that AI recommendations influence later search behaviour even where no referral click is recorded, meaning visibility can affect demand before traditional analytics detect it.
For licensees, authority is becoming a commercial asset that should be governed as carefully as any other communication activity.
No. Explaining legislation, describing advice processes or discussing financial concepts does not automatically constitute financial product advice.
The distinction depends on the overall context, including whether the communication could reasonably influence someone to make a financial decision, the audience being addressed, references to products or strategies, and any calls to action.
That’s why effective governance classifies communications according to risk rather than treating all public content the same.
Governed authority is a structured approach that enables advisers to demonstrate expertise without compromising regulatory obligations.
Instead of relying on ad hoc compliance approval, organisations establish content categories, approval pathways, evidence standards, source requirements and ongoing monitoring.
The objective is not to restrict communication but to ensure that educational content remains educational while advice continues to be delivered through the firm’s regulated advice process.
Historically, many licensees reduced regulatory risk by limiting what advisers could publish. While understandable, that approach now carries commercial consequences.
AI systems increasingly recommend organisations that consistently publish authoritative educational content, meaning businesses that remain invisible may lose opportunities before prospective clients even begin comparing advisers.
The objective is not unrestricted publishing, but communication that is appropriately governed, reviewed and supervised.
Rather than asking whether an article can be published, compliance teams should ask what controls are needed for it to be published safely. That means classifying content by risk, defining proportionate approval pathways, requiring reliable sources, documenting review decisions and monitoring published material over time.
This shifts compliance from acting primarily as a gatekeeper to becoming an enabler of well-governed communication.
The most effective response is not to publish more content indiscriminately, but to publish better-governed content consistently. Licensees should establish clear content classifications, proportionate review processes, defined source standards and ongoing monitoring so advisers can demonstrate expertise without inadvertently providing regulated advice.
As AI increasingly rewards recognised authority, communication governance becomes part of the firm’s broader compliance framework rather than simply a marketing activity.
