Guides · Financial Services Guide · Chapter 4 of 7
Disclosure: FSGs, SOAs, PDSs and target market determinations
Last reviewed 29 August 2026
Which disclosure document applies to which activity, when it must be given, and where disclosure obligations are most often missed.
In short
Retail clients must receive a Financial Services Guide before a service is provided, a Statement of Advice where personal advice is given, and a Product Disclosure Statement before acquiring a product. Product issuers and distributors must also prepare and follow a target market determination. Wholesale clients sit outside most of this — which is why client classification must be documented properly.
Disclosure obligations are timing obligations as much as content obligations. A perfect document given at the wrong point in the process is still a breach.
The four core documents
- Financial Services Guide. Given as soon as practicable once it becomes apparent a financial service will be provided to a retail client, and before it is provided. Covers who you are, what services you are authorised to provide, how you and your representatives are remunerated, associations and referral arrangements, and how to complain.
- Statement of Advice. Required when personal advice is given to a retail client. Sets out the advice, the basis for it, and information about remuneration and interests that could reasonably be capable of influencing the advice. A Record of Advice can be available in defined circumstances, including certain further advice situations.
- Product Disclosure Statement. Given by the issuer or seller before a retail client acquires a product. Must be clear, concise and effective, and must contain the information a reasonable person would require to make a decision.
- Target market determination. Required under the design and distribution obligations for most retail products. Describes the class of consumers the product is appropriate for, distribution conditions, review triggers and reporting requirements.
Retail or wholesale
Client classification determines almost everything about your disclosure burden. The tests include the price or value of the product, the purpose of acquisition, the sophisticated investor and accountant's certificate routes, and the professional investor category. Two rules matter operationally: assess and document classification before the service is provided, and keep the certificate on file with its date. Certificates go stale, and a retrospective classification is not a defence.
Where disclosure most often fails
- An FSG published on a website but never actually delivered before the service is provided.
- Personal advice given in a call or email, characterised internally as general advice, with no SOA.
- A PDS updated for a product change with no supplementary document and no notification to existing holders.
- A target market determination prepared at launch and never reviewed, despite distribution data showing sales outside the target market.
- Remuneration and referral fee disclosure described in general terms when the client needs the actual arrangement.
Design and distribution in practice
The distributor obligations are the ones that surprise businesses. If you distribute someone else's product, you must take reasonable steps consistent with the target market determination, keep records of distribution, report complaints and significant dealings outside the target market to the issuer, and respond to the issuer's information requests. That is an operational build, not a document.
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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