A Responsible Manager is someone ASIC relies on to assess whether you meet the organisational competence requirement under RG105.
You need responsible managers whose combined knowledge and skills cover all of the financial services and products on your licence. ASIC does not set a fixed number for every applicant. What you need depends on the nature, scale and complexity of your business and whether your responsible managers genuinely cover the authorisations you are seeking.
In practice, ASIC expects a Responsible Manager to have relevant qualifications or training, as well as relevant industry experience aligned to the services and products your licence will cover. RG105 sets out several pathways ASIC may consider when assessing knowledge and skills. The most commonly used pathways require at least three years of relevant experience over the past five years. That applies where the Responsible Manager relies on a relevant industry or APRA standard, a relevant university degree plus a short industry course, or a relevant industry-specific or product-specific qualification at diploma level or higher.
On the education side, ASIC generally prefers a degree in a relevant discipline, such as economics, commerce, business, or accounting, where you are relying on the university degree pathway. It also accepts a relevant industry-specific or product-specific qualification equivalent to a diploma or higher under another pathway. The key point is not just the level of study. It is whether the qualification or training is relevant to the actual financial services and products the Responsible Manager will oversee.
These RG105 pathways are minimum guidance only. Meeting a qualification or experience pathway does not, by itself, guarantee that ASIC will accept a proposed Responsible Manager. ASIC still looks at whether the person’s experience is genuinely relevant to the financial services and products covered by the authorisations you are seeking.
A Responsible Manager is not just a name on an application. ASIC expects that person to contribute to the licensee’s competence in a real and ongoing way. You need to be able to show how their qualifications, training and experience align with your proposed activities, and how they remain involved in the business after approval.