Guides · Financial Services Guide · Chapter 3 of 7
ASIC obligations once you are licensed
Last reviewed 29 August 2026
The general obligations in section 912A, the licence conditions, and the reporting and lodgement cycle that follows you every year.
In short
Section 912A of the Corporations Act requires a licensee to provide its services efficiently, honestly and fairly, manage conflicts, maintain competence and adequate resources, supervise representatives, have dispute resolution, and comply with financial conditions. These are continuous obligations tested against evidence — if it is not documented, ASIC treats it as not done.
The licence is the beginning, not the finish line. What follows is a set of standing obligations that ASIC assesses by looking at records: registers, file notes, board papers, training logs and monitoring reports.
The general obligations
- Efficiently, honestly and fairly. A composite standard, read as a whole, and the provision most often pleaded in enforcement proceedings. It reaches conduct that is not dishonest but is careless, unfair in outcome or systemically poor.
- Conflicts of interest. Adequate arrangements to manage conflicts, whether actual or potential, between the licensee's interests and its clients'. Disclosure alone is rarely adequate management.
- Compliance with financial services laws. Including taking reasonable steps to ensure representatives comply.
- Competence and training. Maintaining organisational competence and ensuring representatives are adequately trained and competent, with ongoing professional development recorded.
- Resources. Adequate financial, technological and human resources, including technology resilience and cyber capability.
- Risk management. Adequate risk management systems, proportionate to the business.
- Dispute resolution. Internal dispute resolution meeting ASIC's standards, plus AFCA membership, where retail clients are involved.
- Compensation arrangements. Usually professional indemnity insurance adequate for the retail business.
Licence conditions
Your licence document carries standard and, sometimes, tailored conditions — the authorisations themselves, client money handling, financial requirements, audit lodgement and record retention. Read them annually. Businesses drift beyond their authorisations gradually, usually by adding a product class that nobody re-tested against the licence.
The annual cycle
- Lodge audited financial statements and an auditor's report within the period set by your conditions.
- Confirm and update details on the ASIC registers — responsible managers, authorised representatives, addresses — within the prescribed timeframes.
- Pay industry funding levies.
- Refresh compliance and risk documents so they describe the business as it now operates, not as it was at application.
Client money and product distribution
Where you hold client money, the client money provisions and their reconciliation and account-designation requirements apply strictly; breaches here are treated seriously because they go to solvency and to trust. Where you issue or distribute products to retail clients, the design and distribution obligations require a target market determination, distribution consistent with it, and collection and review of distribution information.
Evidence, not intention
Every one of these obligations is assessed on documents. Board and compliance committee minutes, conflicts registers, training records, monitoring and supervision reports, complaints registers, incident logs and remediation files are the artefacts of compliance. A licensee that can produce them contemporaneously is in a fundamentally different position from one reconstructing them after a notice arrives.
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All chapters
- 01Do you need an AFSL?
- 02Authorisation pathways: your own licence or someone else's
- 03ASIC obligations once you are licensed
- 04Disclosure: FSGs, SOAs, PDSs and target market determinations
- 05Marketing and promotion of financial products
- 06Building a compliance framework that holds up
- 07Breach reporting, remediation and enforcement