The AFSL Application Process: What You Need to Know Before You Begin

AFSL Express
May 8
3 min read

Applying for an Australian Financial Services Licence (AFSL) is no small task. Whether you're launching a new venture or formalising an existing operation, the application process can be complex, time-consuming, and expensive — especially if you're not properly prepared. At AFSL Express, we can help professionals navigate the decision between applying for their own licence or operating under an existing one. This guide walks you through what to consider before jumping into an AFSL application.

1. Know Why You’re Applying

ASIC doesn't issue licences just because you want one for branding or flexibility. You need to demonstrate a legitimate need for the licence based on the actual services you intend to provide. If your proposed model falls outside the usual retail advice or funds management structure, you may require legal advice to confirm whether a full AFSL is appropriate.

2. Decide What You Want to Be Authorised For

AFSLs are issued based on specific authorisations. You’ll need to define:

What products you’ll deal in (e.g. securities, managed investment schemes, derivatives).
What services you’ll provide (e.g. financial advice, dealing, custodial services).
Who your clients will be (retail, wholesale, or both).

ASIC expects a clear link between the authorisations you’re applying for and the competence of your nominated personnel.

3. Structure and Responsible Managers

Before submitting an application, you must be clear about:

Who will hold the licence (e.g. a company or trustee).
Who will be nominated as Responsible Managers (RMs).

Responsible Managers are key people whose experience supports your licence application. They don’t have to be directors, but they do need to be actively involved in overseeing the financial services. ASIC will assess their qualifications and experience under RG 105 to determine whether your business is “organisationally competent.”

4. Prepare Your Core Documentation

An AFSL application requires more than just ticking boxes. You'll need to prepare a full set of "core proof" documents, including:

A detailed business description and transaction example.
A table of organisational expertise showing how your RMs meet the required criteria.
Copies of qualifications, references, and signed declarations for each RM.
Fit and proper documentation for RMs and key personnel (e.g. bankruptcy and police checks).
Financial statements and cash flow projections.

ASIC may request further material (non-core proofs) once your application is under review.

5. Expect Time and Cost Pressures

Most straightforward AFSL applications take 4 to 6 months from submission to approval. More complex applications — especially those involving retail clients or niche business models — can take significantly longer.

You’ll also need to budget for:

Application and legal fees.
Professional indemnity insurance (RG 126-compliant).
External dispute resolution (e.g. AFCA membership).
Ongoing compliance and recordkeeping obligations.

6. Alternatives to Applying

After reviewing the costs, time commitment, and regulatory burden of holding your own AFSL, many professionals — especially sole operators or small teams — opt to become a Corporate Authorised Representative (CAR) under an existing AFSL.

This structure gives you the legal ability to operate, provide advice, and deal in financial products without needing to build and maintain a full compliance infrastructure yourself. If you’re considering this option, AFSL Express provides low-overhead, fixed-fee CAR arrangements that let you stay focused on your business, not the red tape.

Final Thought

The AFSL application process is a significant step. It’s not just about paperwork — it’s about proving you have the people, systems, and resources in place to responsibly deliver financial services under the law. Whether you choose to apply or operate under a trusted licensee, make sure the path fits your long-term goals — and your operational reality.

Want to avoid the stress and start operating sooner? Talk to us about joining as a Corporate Authorised Representative.

Telephone: 0417 021 101