A practical step-by-step guide for AFS licensees
| Key point ASIC Connect records the appointment. It doesn’t create the authority. The AFS licensee should first give the person a written authorisation under s 916A of the Corporations Act 2001, then notify ASIC of the appointment. |
TLDR
- Confirm that the person actually needs to be appointed as an authorised representative.
- Give the person a written authorisation specifying the financial services they may provide.
- Make sure the relevant AFSL or appointing authorised representative is linked to ASIC Connect.
- Open Lodgements & Notifications, select the AFSL or authoriser and choose Appoint Representatives.
- Select Authorised Representative and identify the person as a natural person.
- Enter the individual’s identity, business and contact details.
- Specify the exact financial services and products they are authorised to provide.
- Deal with sub-authorisation and any cross-endorsement.
- Review, declare, pay and submit the transaction.
- Generally notify ASIC within 30 business days of the authorisation being issued.
- If the person is also a relevant provider, deal separately with Financial Advisers Register appointment and registration.
Do you need to appoint the person as an authorised representative?
Not everyone who provides financial services for an AFSL needs to be appointed as an authorised representative. ASIC states that an employee or director of the licensee is already a representative of the licensee and does not need a separate authorised representative appointment.
That does not remove the Financial Advisers Register requirements. If an individual provides personal advice to retail clients on relevant financial products, ASIC says they must be appointed to the Financial Advisers Register and registered with ASIC before providing that advice.
| Practical distinction An ordinary authorised representative appointment and a financial adviser appointment are not the same thing. A person can be both, but one status does not automatically complete the requirements for the other. |
What is an authorised representative?
An AFS licensee may appoint a person to provide specified financial services on its behalf. Section 916A of the Corporations Act 2001 provides the basic mechanism: the licensee gives the person a written notice authorising specified financial services. Those services may be some or all of the financial services covered by the licence.
ASIC recognises individuals, bodies corporate, partnerships and certain groups of trustees as possible authorised representatives. This article deals with appointing an individual.
There are therefore two separate steps. First, the legal appointment: the AFSL gives the individual written authority. Second, the regulatory notification: the appointment is recorded with ASIC.
How do you appoint an individual AR in ASIC Connect?
Step 1: Make sure the AFSL or authoriser is linked to ASIC Connect
If the AFSL itself is making the appointment, the licence must be linked to the ASIC Connect account used for the transaction. ASIC’s current portal guidance says an ASIC Connect account, ASIC key and linked AFS licence are required for licensee transactions.
If an existing authorised representative is making the appointment on the licensee’s behalf, that authoriser must have the relevant ASIC Connect access. Do not confuse linking the authoriser with appointing the new representative.
Screenshot note. ASIC’s current portal continues to link to the March 2018 “How to appoint authorised representatives” user guide. ASIC warns that the screens and data shown are examples and that actual screens may differ slightly in text and layout. The figure references in this article correspond to that ASIC guide.
Step 2: Select “Lodgements & Notifications”
After logging into ASIC Connect, select Lodgements & Notifications from the menu at the top of the screen.
| ASIC SCREENSHOT – USER GUIDE PAGE 6 Open ASIC screenshot guide |
Step 3: Select the AFSL and “Appoint Representatives”
Select the radio button beside the relevant AFS Licensee or appointing AFS Representative. In the Transactions column, select Appoint Representatives and then select Go.
| ASIC SCREENSHOT – USER GUIDE PAGE 7. Open ASIC screenshot guide |
Step 4: Tell ASIC who made the appointment
ASIC asks whether the licensee is notifying it about a representative who was appointed by an authorised representative on the licensee’s behalf. Select No where the AFSL made the appointment itself. Select Yes where an existing authorised representative made the appointment with the licensee’s consent, and provide that representative’s number.
| ASIC SCREENSHOT – USER GUIDE PAGE 8. Open ASIC screenshot guide |
How should you enter an individual representative?
Step 5: Enter the appointment details
Enter the effective date of appointment. ASIC’s guide states that the appointment date must be on or after the date the AFS licence was granted or, where an authorised representative is making the appointment, on or after that authoriser was appointed by the licensee.
Select Authorised Representative. If you are appointing the person only as an authorised representative, do not assume you should also select Financial Adviser. ASIC’s guide notes that a person can be both, but ASIC’s current portal guidance treats financial adviser appointment and registration as additional processes.
For an individual AR, the usual responses are:
- Has ASIC issued this representative with a representative number? – No, unless the person already has one.
- Does the representative have an ABN? – Answer according to the person’s circumstances.
- Is the representative a natural person? – Yes.
| ASIC SCREENSHOT – USER GUIDE PAGE 9. Open ASIC screenshot guide |
Step 6: Identify the individual correctly
ASIC then asks for the individual’s name and birth details and searches for a possible existing match. If the person already appears on the representative register, select the matching record. If no existing record matches, select the option indicating that none of the results applies.
This step matters because an individual who has previously been an authorised representative may already have a representative number. Creating a second identity can produce avoidable register problems.
| ASIC SCREENSHOT – USER GUIDE PAGE 10. Open ASIC screenshot guide |
What business details should be entered?
ASIC then collects the authorised representative’s principal place of business or practice and email address. A registered business name can also be recorded where the individual trades under one.
Use the person’s actual business or practice details. If they operate through a separate company, do not accidentally turn the company’s details into the individual’s legal identity. The authorised representative being appointed in this transaction is the individual.
| ASIC SCREENSHOT – USER GUIDE PAGE 11 Open ASIC screenshot guide |
What authorisations should you select?
This is the most important substantive part of the transaction. ASIC asks whether the authorised representative can appoint further authorised representatives or financial advisers on behalf of the AFSL and whether the representative has the same authorisations as the licensee.
Do not select “same as licensee” merely because it is simpler. The ASIC record should reflect the written authority actually given to the person. If the AFSL has broader authorisations than the person needs, select only the financial services and products within the individual’s authorised scope and record any further restrictions.
Control principle. The written authorisation, ASIC register and actual operating permissions should align. A broader ASIC entry than the written authority creates ambiguity. A broader written authority than the AFSL itself holds is ineffective.
ASIC SCREENSHOT – USER GUIDE PAGE 12 Open ASIC screenshot guide
Can an individual AR appoint other representatives?
Sometimes, but it should be deliberate. Section 916B allows an authorised representative to give a written authorisation to another person in circumstances permitted by the Act and with the licensee’s consent.
For many individual AR arrangements, there is no operational reason to grant sub-authorisation power. If the person does not need it, leaving the power unavailable generally produces a cleaner control environment. If it is required, the AFSL should document who may be appointed, the permissible scope, onboarding requirements and how the licensee will maintain visibility over those appointments.
What if the person is already an AR of another AFSL?
ASIC Connect includes a cross-endorsement step. It asks whether the individual is also an authorised representative of one or more other AFS licensees. If so, record the other AFSL details and the relevant consent.
This is not just an administrative disclosure. Section 916C restricts an authorised representative from acting for more than one licensee unless the statutory conditions are satisfied. Confirm the legal position before completing the transaction.
| ASIC SCREENSHOT – USER GUIDE PAGE 13 Open ASIC screenshot guide |
What should you check before submitting?
Use the Review screen to compare the ASIC entry with the signed written authorisation. Check the individual’s name, representative number if applicable, appointment date, ABN status, address, authorisations, sub-authorisation position and any cross-endorsement.
ASIC’s guide says up to 25 authorised representative appointments can be notified in one transaction. For a single appointment, resist the temptation to treat the review screen as a formality. This is the last opportunity to catch a mismatch before the register updates.
| ASIC SCREENSHOT – USER GUIDE PAGE 14 Open ASIC screenshot guide |
The lodger then reads ASIC’s declarations, confirms the authority under which the notice is being submitted, proceeds through payment and confirms the transaction.
| ASIC SCREENSHOT – USER GUIDE PAGE 15 Open ASIC screenshot guide |
How long do you have to notify ASIC?
ASIC states that an AFS licensee or authoriser appointing an authorised representative must notify ASIC within 30 business days of the date the authorisation is issued. ASIC identifies s 916F(1) of the Corporations Act 2001, as modified by reg 7.6.04AA of the Corporations Regulations 2001, as the relevant requirement.
That is the statutory deadline, not the recommended operating timetable. A better control is to make the ASIC notification part of the appointment workflow and lodge it immediately after the written authority takes effect.
What if the person is also a financial adviser?
Don’t stop at the AR appointment. ASIC’s current portal guidance states that after appointing a financial adviser or time-share adviser, the adviser must also be registered with ASIC. The authorised representative transaction and the relevant provider registration requirements are therefore separate compliance steps.
This distinction is particularly important where an individual provides personal advice to retail clients on relevant financial products. Before they start giving that advice, confirm that both their representative authority and their Financial Advisers Register appointment and registration are correct.
What should the licensee retain as evidence?
The ASIC notification should sit inside a broader representative onboarding file. A defensible record would ordinarily include:
- due diligence and identity verification for the proposed representative;
- the written authorisation and its effective date;
- the exact financial services and products authorised;
- any limitations or conditions;
- approval of any sub-authorisation power;
- cross-endorsement consent where applicable;
- ASIC Connect lodgement confirmation and representative number;
- a register extract after appointment;
- Financial Advisers Register appointment and registration evidence where relevant;
- induction, training and competence evidence;
- monitoring and supervision arrangements; and
- an entry in the licensee’s internal representative register and compliance systems.
The ASIC register proves what was notified. It does not prove that the licensee has designed and implemented an adequate supervision framework. Those are separate questions.
What are the common mistakes?
The most significant mistakes generally occur before or around the ASIC Connect lodgement, rather than in the lodgement itself.
Treating ASIC registration as the appointment.
The ASIC Connect transaction records the appointment. It does not create the substantive authority. The authorised representative should already have been given written authority under s 916A of the Corporations Act 2001 before the ASIC notification is lodged.
Failing to put an Authorised Representative Agreement in place before appointment.
A written authorisation is the statutory foundation of the appointment, but a properly drafted Authorised Representative Agreement should ordinarily be executed before the representative starts providing financial services.
The agreement should define the representative’s authority and deal with matters such as compliance with the licensee’s policies, supervision, access to records, complaints, breaches, confidentiality, insurance, costs, indemnities, suspension and termination.
The agreement should not be treated as paperwork to be completed after the ASIC appointment. It is part of the control framework that establishes the conditions on which the person is permitted to operate under the AFSL.
Appointing the person before completing appropriate background checks.
An AFSL should have a reasonable basis for deciding that a proposed representative is suitable before allowing that person to provide financial services under its licence.
Pre-appointment due diligence should ordinarily include, where appropriate:
- identity verification;
- National Police Check;
- bankruptcy, insolvency and credit history checks;
- employment and professional reference checks;
- ASIC register and banning/disqualification searches;
- investigation of previous AFSL and authorised representative relationships;
- review of complaints, disciplinary or regulatory history;
- qualification and training verification;
- relevant provider status and Financial Advisers Register history, where applicable; and
- consideration of conflicts, outside business interests and other matters relevant to the person’s suitability.
Not every check is expressly mandated by the Corporations Act. The point is broader. The licensee remains responsible for who it authorises and should be able to demonstrate a documented, risk-based process for assessing whether that person is competent, trustworthy and appropriate to operate under the licence.
Police, credit and reference checks are therefore not simply recruitment formalities. They form part of the evidence supporting the licensee’s appointment decision.
Treating a clear police or credit check as sufficient due diligence.
Background screening is only one part of the assessment. A person can have no criminal or adverse credit history and still be unsuitable because of competence deficiencies, poor compliance history, unresolved complaints, conflicts, previous regulatory concerns or conduct identified through references.
The purpose of due diligence is to assess the person as a whole, not merely to collect certificates.
Failing to investigate previous licensee relationships.
Where the proposed AR has previously operated under another AFSL, the licensee should understand why that relationship ended and whether there were any unresolved compliance, advice, complaint or conduct issues.
A reference limited to confirming employment dates is unlikely to provide much comfort. Where possible, the licensee should seek meaningful references from previous licensees, employers or principals and investigate material inconsistencies.
Giving the AR every AFSL authorisation by default.
The representative should receive only the authority genuinely required for their role and that the licensee intends them to exercise.
The Authorised Representative Agreement, written authorisation, ASIC record and the licensee’s internal systems should describe the same scope of financial services and products.
Broader authority increases the licensee’s exposure without necessarily providing any commercial benefit.
Confusing an authorised representative with an employee representative.
Not every person providing financial services for a licensee needs to be appointed as an authorised representative.
An employee or director of the licensee may be able to provide financial services as a representative of the licensee without being separately appointed as an AR. The correct structure should therefore be determined before lodging anything with ASIC rather than appointing everyone as an authorised representative by default.
Confusing an authorised representative with a financial adviser.
“Authorised representative” and “financial adviser” describe different regulatory concepts.
A person can be an authorised representative without being a relevant provider. Conversely, where the person will provide relevant personal advice to retail clients, separate Financial Advisers Register appointment and registration requirements may apply.
Completing the AR appointment does not, by itself, satisfy those requirements.
Failing to check whether ASIC has already issued the person a representative number.
Where a person has previously been an authorised representative, their existing representative number should ordinarily be used. Creating unnecessary duplicate records can make regulatory histories harder to follow and create discrepancies between the licensee’s records and ASIC’s registers.
Ignoring existing AFSL relationships.
If the person is already an authorised representative of another AFSL, the licensee should investigate that relationship before appointment and consider the restrictions and consent requirements in s 916C of the Corporations Act 2001.
This is a substantive licensing issue, not simply another question on the ASIC Connect form.
Assuming the AR can appoint other representatives.
An individual AR does not automatically acquire authority to appoint or sub-authorise other people merely because they have been appointed as an authorised representative.
Where any sub-authorisation arrangement is contemplated, the licensee should determine whether it is legally permissible, expressly consent to the arrangement where required and define the limits of that authority.
For most individual AR structures, there should be a clear reason before giving the representative this additional power.
Failing to assess competence before appointment.
Being legally eligible for appointment does not establish that the person is competent to provide the services for which they are being authorised.
The licensee should verify relevant experience, qualifications, training and product competence and determine whether any additional supervision or restricted authority is required during onboarding.
Where the person is a relevant provider, the licensee should separately verify that the education, training, exam, professional year and other applicable requirements have been satisfied.
Allowing the representative to commence before onboarding is complete.
ASIC registration should not be treated as permission to start immediately.
Before the representative provides financial services, the licensee should have completed its onboarding requirements, including relevant training, policy acknowledgements, system access, disclosure arrangements, escalation procedures and supervision settings.
The licensee should be able to identify the point at which the representative was formally approved to commence and the evidence supporting that decision.
Leaving supervision until after appointment.
The monitoring framework should be determined as part of the appointment process.
Before commencement, the licensee should decide matters such as:
- initial or heightened supervision;
- file-review frequency;
- adviser risk rating;
- review of advice or transactions during the onboarding period;
- complaints and incident monitoring;
- compliance attestations;
- training requirements; and
- escalation thresholds.
A new representative may warrant closer supervision until the licensee has sufficient evidence of their competence and compliance behaviour.
Failing to reconcile the records.
The Authorised Representative Agreement, written authority, ASIC Authorised Representatives Register, Financial Advisers Register where relevant, internal representative register and compliance systems should all align.
Differences between those records can mean the licensee cannot reliably answer a basic supervisory question: who is authorised to do what under our licence?
The practical compliance lesson
Adding an authorised representative to ASIC Connect is an administrative task at the end of a governance decision. The substantive questions come first: Why does this person need representative status? What financial services may they provide? What must they not do? Who supervises them? What evidence will the AFSL retain?
If those questions have been resolved, the ASIC Connect transaction is straightforward. If they have not, completing the transaction simply records an unclear appointment more efficiently.
This article was checked against ASIC’s current AFS licensee portal, ASIC’s current guidance on appointing and ceasing authorised representatives, the Authorised Representative Register guidance and ASIC’s user guide for the ASIC Connect appointment transaction. The user guide itself is dated March 2018, but ASIC’s 2026 portal continues to link to it.
Further reading
- ASIC – Appoint or update an authorised representative or financial adviser
- ASIC – Appointing and ceasing authorised representatives
- ASIC – Authorised Representative Register
- ASIC – How to appoint authorised representatives (PDF user guide)
- Federal Register of Legislation – Corporations Act 2001
| Screenshot note ASIC’s current portal continues to link to the March 2018 “How to appoint authorised representatives” user guide. ASIC warns that the screens and data shown are examples and that actual screens may differ slightly in text and layout. The figure references in this article correspond to that ASIC guide. |
Frequently asked questions
Yes, in practice they should.
Section 916A of the Corporations Act 2001 requires the representative to be given written authority specifying the financial services they may provide on behalf of the licensee. A formal Authorised Representative Agreement is the usual way to document that authority and the conditions attached to it.
The agreement should ordinarily address:
– the scope of the representative’s authority;
– compliance with the licensee’s policies and directions;
– monitoring and supervision;
– access to records and systems;
– complaints and breach escalation;
– training and competence;
– confidentiality and data handling;
– insurance and costs;
– indemnities;
– suspension and termination; and
– obligations on cessation.
The agreement should be executed before the representative commences providing financial services.
The important distinction is that the written authorisation creates the authority; the ASIC Connect transaction records it.
The licensee should complete sufficient due diligence to have a reasonable basis for concluding that the proposed representative is suitable to operate under the licence.
Depending on the role and risk profile, this should ordinarily include:
– identity verification;
– National Police Check;
– credit and bankruptcy checks;
– employment and professional reference checks;
– ASIC banning and disqualification searches;
– review of previous authorised representative or AFSL relationships;
– investigation of complaints, disciplinary or regulatory history;
– qualification and training verification;
– Financial Advisers Register history where relevant; and
– consideration of conflicts, outside business interests and other conduct risks.
Police, credit and reference checks are not simply administrative formalities. They help the licensee demonstrate that the appointment decision was informed and risk-based.
The licensee should also resolve any adverse or inconsistent information before appointment rather than treating a completed background check as sufficient in itself.
Not as a standalone statutory requirement in every case.
The Corporations Act does not prescribe a universal rule that every authorised representative must obtain a National Police Check before appointment.
However, the licensee remains responsible for who it authorises and for maintaining adequate compliance arrangements. A police check is therefore a common and sensible component of pre-appointment due diligence, particularly where the representative will deal directly with clients, exercise discretion or handle sensitive financial information.
The stronger compliance question is not “does the Act expressly require this particular check?” but “what evidence does the licensee have that it reasonably assessed the person before allowing them to operate under its licence?”
No.
An authorised representative and a financial adviser or relevant provider are different regulatory concepts.
An authorised representative is authorised to provide specified financial services on behalf of an AFSL holder.
A relevant provider is an individual who provides relevant personal advice to retail clients and is subject to the separate Financial Advisers Register and registration regime.
A person may therefore be an authorised representative without being a relevant provider.
Where the person will provide relevant personal advice, the licensee must separately deal with their Financial Advisers Register appointment and registration requirements.
Not necessarily.
An employee or director of the AFSL may be able to provide financial services as a representative of the licensee without being separately appointed as an authorised representative under s 916A.
That means you should determine the correct legal structure before lodging any ASIC Connect transaction.
Appointing every person as an AR by default can create unnecessary complexity and may produce records that do not accurately reflect the underlying relationship.
Only where the legal structure permits it and the licensee has given the necessary consent.
An individual AR does not automatically acquire a general right to appoint or sub-authorise other people simply because they have been appointed.
Where sub-authorisation is contemplated, the licensee should define:
– who may be appointed;
– what authority may be delegated;
– whether prior licensee approval is required;
– how those individuals will be screened; and
– how the licensee will monitor them.
For most individual AR arrangements, there should be a clear reason before granting this additional power.
Only the authority the representative genuinely needs.
The representative should not automatically receive every financial service and product authorisation held by the AFSL.
The licensee should determine the scope by reference to:
– the person’s role;
– competence and experience;
– the services they will actually provide;
– the products they will deal with;
– any higher-risk activities; and
– any restrictions or additional approvals that should apply.
The written authority, Authorised Representative Agreement, ASIC record and internal systems should all align.
Appointment should trigger a defined onboarding and supervision process.
The licensee should ensure the representative has completed required training, understands relevant policies and escalation obligations, has the correct system access and is subject to an appropriate monitoring framework.
For a new representative, that may include:
– enhanced file review;
– closer supervision;
– restricted authority during an initial period;
– additional compliance attestations;
– targeted training; and
– more frequent review until the licensee has sufficient evidence of competent and compliant behaviour.
Appointment is therefore the start of the supervisory relationship, not the end of the onboarding process.
