TLDR: the AOIFP’s 15-point plan highlights the growing dissatisfaction within parts of the advice profession, particularly among older advisers and independently owned practices struggling with rising compliance costs and declining adviser numbers. Their concerns are legitimate, but their broader policy direction focuses on deregulation and relief for advisers rather than articulating a fully developed framework to rebuild public trust and long-term confidence in the profession.
A flawed framework
I may be “as light as a feather and as thick as a board”, but I also pay attention to things other people ignore; like the AOIFP’s plans for the future of advice.
I understand our aspirations for our emerging advice profession. I appreciate the challenges we face as we’re buffeted by commercial realities and struggling to recover from (self-inflicted wounds). I get that we’ve had twenty-plus years of frequent reform that has left advisers and consumers behind. I believe that our industry is capable of building a future that better reconciles accessibility, sustainability and consumer protection.
Unfortunately, the AIOFP’s 15-point plan probably isn’t it.
I say “probably” because the 15-point plan referenced in the IFA article hasn’t been publicly released or published on the AIOFP’s website. I appreciate it may be premature to criticise formal policy on the basis of media coverage, but the Association chose to publicise a policy that it has not made public; qualifications can be made if it ever is. The FSC, to their credit, don’t promote standards, policies or papers that they haven’t made available to the public. Also, to their credit, they generally respond constructively to feedback.
Reading the article leads me to think that the AIOFP’s 15-point plan reads less like a coherent blueprint for rebuilding the advice profession and more like a grievance document wrapped in policy language. While some elements correctly identify genuine structural problems, especially excessive compliance costs, regulatory ambiguity, adviser attrition, and the collapse in affordable advice access, the broader framework is undermined by ideological positioning, selective accountability, and a lack of practical implementation detail.
Advocacy and advice
The strongest part of the AIOFP’s advocacy is its recognition that Australia’s advice framework has become economically unsustainable for both advisers and consumers. That’s inarguable. Renewed focus on conflicts, remuneration and duties, as well as new compliance obligations introduced post-Royal Commission, have materially increased the cost and complexity of advice delivery. These factors, in turn, contribute to adviser exits and rising minimum client thresholds. Even regulators and policymakers now acknowledge that decreased accessibility to, and the increasing cost of, advice represent a major public policy failure for a population that would benefit from professional financial planning advice.
However, the AIOFP demonstrates the same selective memory and revisionism that marred other Associations’ proposals. The AIOFP repeatedly frames the profession’s problems as primarily caused by external enemies: regulators, institutional groups, the FSC, banks, and government overreach. That framing is politically convenient, but disingenuous. The Royal Commission wasn’t an artificial assault on advisers. It was a legislative and judicial response to genuine systemic misconduct across vertically integrated advice models, conflicted remuneration structures, fee-for-no-service scandals, and governance failures. Any serious reform proposal must acknowledge that advisers and advice businesses helped create the trust deficit now being blamed entirely on policymakers.
The plan also suffers from a recurring contradiction. On one hand, the AIOFP advocates for stronger professional recognition and adviser autonomy. On the other hand, it pushes for the removal or dilution of many consumer protection mechanisms introduced precisely because prior self-regulation failed. Calls to abolish annual fee consent forms, reduce documentation requirements, and loosen compliance settings may have merit in limited contexts, but the paper rarely explains what safeguards would replace them.
That absence matters because the core challenge is not simply reducing regulation. It is determining which regulation protects consumers versus which regulation merely protects bureaucracy. The AIOFP tends to treat almost all regulation as inherently anti-consumer. That’s far too simplistic.
Conflicts
There’s also an ideological inconsistency in the organisation’s position on vertical integration. Historically, the AIOFP has strongly opposed bank involvement in advice while accepting super fund involvement as “workable”.
But conflicts don’t disappear simply because the institution is member-owned rather than shareholder-owned. Industry funds increasingly operate sophisticated vertically integrated ecosystems with internal advice channels, proprietary products, and distribution incentives. Likewise, exempting advisers “offering in-house products as well as those who white-label platform solutions” seems a convenient way to circumvent potentially material conflicts. If institutional conflicts are the concern, the principle should apply consistently.
The article also references the AIOFP’s position that advisers should not place client funds with institutions unless advisers retain full client access and the arrangement is governed by an independent trustee. Conceptually, that sounds attractive. Few advisers would disagree with resisting institutional overreach or protecting client relationships from platform capture. But the proposal feels more ideological than practical. Modern advice delivery increasingly depends on integrated platform ecosystems, data connectivity, administration efficiencies, managed account functionality, and digital infrastructure that smaller independent practices cannot realistically replicate on their own.
The framing is also unnecessarily adversarial. Describing advisers as “subservient and bullied by Institutions” oversimplifies what are often commercially negotiated relationships between licensees, platforms, product providers, and advice businesses. Institutions certainly exercise commercial influence, sometimes excessively, but advisers also derive substantial operational, technological, and commercial benefits from those same arrangements. The reality is more nuanced than the article suggests.
Regulation and Representation
The article’s discussion of the Life Insurance Framework (LIF) reforms is similarly one-sided. There’s legitimate debate about whether the reduction in commissions eroded advisers’ willingness to provide risk advice and contributed to declining accessibility in the life insurance market. Many advisers would argue that it’s unquestionably true. However, the article largely ignores why the reforms occurred in the first place: concerns about conflicted remuneration structures, policy churn, and incentives that encouraged product replacement over long-term client outcomes. Any serious reassessment of LIF should acknowledge both the reduction in adviser participation and the original policy rationale behind the reforms.
The article also touches on the AIOFP’s proposal to reduce professional representation down to just three bodies: the AIOFP, the SIAA and the SMSF Association. While there is a reasonable argument that fragmentation weakens advocacy efforts and creates inconsistent messaging to government and regulators, the proposal raises an obvious question: who gets excluded and why? Limiting representation to organisations that primarily reflect independently owned advice firms, stockbrokers and SMSF specialists risks narrowing the diversity of perspectives within a profession that now spans institutional advice, scaled licensees, digital advice providers, specialist risk advisers, younger entrants, and multidisciplinary firms.
More importantly, the proposal seems to assume that disagreement within the profession is itself the problem, rather than a reflection of the profession’s structural diversity. Consolidating representation may strengthen lobbying efficiency, but it does not necessarily produce better policy outcomes. In some respects, it risks creating a more ideologically homogeneous advocacy environment dominated by groups already aligned on deregulation and institutional scepticism.
The CSLR
The article’s discussion of managed investment schemes (MISs) and the Compensation Scheme of Last Resort (CSLR) is one of the more compelling parts of the AIOFP’s position. There is genuine merit in questioning whether advisers are bearing a disproportionate share of CSLR funding obligations, given that product failures and MIS collapses can generate substantial consumer losses independent of adviser misconduct. The criticism that product manufacturers and scheme operators are insufficiently exposed to the financial consequences of failed products is not unreasonable.
At the same time, the proposal highlights a broader tension that runs throughout the article. The AIOFP frequently argues for stronger accountability when institutions, regulators, or product issuers are involved, while simultaneously advocating reduced obligations and oversight when advisers themselves are concerned. That asymmetry weakens the consistency of the broader reform narrative.
The recommendation that MIS operators be forced to clearly identify advertising and promotional materials is comparatively uncontroversial and arguably one of the more constructive consumer protection proposals mentioned in the article. Greater transparency around marketing, sponsorship, and product promotion would likely improve consumer understanding and accountability across parts of the investment sector that have historically operated with limited scrutiny.
Final thoughts
In my experience, the AIOFP also tends to romanticise adviser independence without fully confronting the commercial realities of the modern advice market. Scale, technology investment, cybersecurity obligations, PI insurance costs, and succession challenges are driving global consolidation, not just in Australia. Independent boutique advice businesses remain important, but they are unlikely to become the dominant long-term structure of the profession. The broader market trend is toward hybrid models combining advice, technology, platform infrastructure, and scaled operations.
Perhaps the most significant omission in the article is any meaningful discussion about how the profession intends to rebuild consumer trust. The reported proposals focus heavily on adviser viability, deregulation, and reducing compliance obligations, but provide little detail about how consumer confidence would be strengthened alongside those changes. That imbalance matters because accessibility alone does not resolve the advice gap if consumers remain sceptical about the quality, objectivity, or reliability of financial advice.
The AIOFP consistently and predictably represents advisers’ frustration with regulation, institutions, and government intervention. While most of us empathise with that frustration, we can’t pretend to know why many of those regulatory settings were introduced in the first place. Without acknowledging the misconduct and governance failures that contributed to prior reforms, the AOIFP’s plan appears more focused on rolling back obligations than improving professional standards and client outcomes.
If you enjoyed this, please read:
Advisers and Licensees Unite
Clarifying the Path Forward on Advice Licensing
The Future of Advice in a Changing Regulatory Environment
Frequently Asked Questions
The author acknowledges that the advice profession faces genuine structural problems, including rising compliance costs, adviser attrition and declining affordability of advice. However, he argues that the AIOFP’s proposed solutions focus too heavily on deregulation and adviser frustration without adequately addressing consumer trust, accountability, or the historical reasons many reforms were introduced.
Yes, but selectively. The article distinguishes between regulations that protect consumers and regulations that primarily create administrative burden. It argues that reducing bureaucracy may be necessary, but warns that simply removing obligations without replacing consumer safeguards risks repeating mistakes that contributed to the Royal Commission and broader trust failures within the profession.
The article argues that the AIOFP applies inconsistent logic when criticising institutional influence. It notes that conflicts of interest can exist in both shareholder-owned and member-owned structures, including superannuation funds. It also argues that modern advice businesses increasingly rely on integrated platforms, technology and operational scale, making blanket opposition to institutional relationships commercially unrealistic.
The author questions whether limiting representation to the AIOFP, SIAA and SMSF Association would narrow the diversity of perspectives within the profession. He argues that disagreement between associations may reflect the structural complexity of the advice industry rather than simply fragmentation, and warns that concentrating representation could create a more ideologically uniform advocacy environment.
The article concludes that the AIOFP correctly identifies many legitimate frustrations within the advice profession, particularly among independently owned firms facing rising costs and declining adviser numbers. However, it argues that the broader policy direction appears weighted toward deregulation and adviser relief rather than presenting a balanced framework capable of improving accessibility, strengthening professional standards, and rebuilding long-term public confidence in financial advice.
