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Australian Securities and Investments Commission

Australia AFSL responsible manager proofs pack

A practical evidence pack map for ASIC AFSL responsible manager proofs, organisational competence, People Proofs, RG 105, portal submissions, authorisation scope, and variation planning.

Route focus

An AFSL application must prove organisational competence through responsible managers and supporting evidence that matches the financial services, financial products, client type, and scale of the business.

Who this helps

  • - AFSL applicants preparing responsible manager and organisational competence evidence
  • - Existing licensees adding responsible managers or varying authorisations
  • - Wholesale fund managers, advisers, dealers, custodians, and platform operators
  • - Responsible manager candidates turning experience into ASIC-ready proofs

Licence scope

  • - Map financial services, financial products, retail/wholesale scope, responsible manager coverage, representatives, and licence conditions.
  • - Check whether the business needs a new AFSL, AFSL variation, authorised representative arrangement, or responsible manager change notification.
  • - Separate AFSL organisational competence from financial adviser relevant-provider requirements.
  • - Use RG 105 to decide how each responsible manager demonstrates knowledge and skills for the exact services/products requested.

Pre-draft questions

  • - Which authorisations are requested, and which responsible manager covers each one?
  • - Is each responsible manager directly responsible for significant day-to-day decisions about the financial services business?
  • - Does each responsible manager have relevant experience, training, qualifications, overseas qualification comparability, or a strong Option 5-style submission?
  • - Will ASIC see dependence on one or two people as requiring a key person condition?
  • - What People Proofs or supporting documents should be ready before the portal transaction is submitted?

Evidence pack

Responsible manager proofs

  • - Responsible manager matrix by financial service, product, client type, role, decision rights, time commitment, qualifications, training, and practical experience.
  • - People Proofs, CVs, regulatory history, qualification documents, overseas qualification comparability material, references where requested, and role descriptions.
  • - Submission explaining why the responsible managers collectively cover the nature, scale, complexity, products, and client types of the business.

AFSL application evidence

  • - Authorisation matrix, business description, financial resources, compliance arrangements, risk management, dispute resolution, insurance, outsourcing, technology, complaints, and records.
  • - Retail personal advice evidence where relevant: relevant provider, financial adviser exam, professional standards, CPD, Code of Ethics, and FAR update plan.
  • - Variation evidence for adding services/products, changing key person conditions, changing responsible managers, or changing control.

Portal and register readiness

  • - ASIC Regulatory Portal access, draft transaction owner, upload plan, analyst-response log, and completeness check.
  • - Professional Registers Search and Financial Advisers Register verification plan after grant, variation, or representative/adviser change.
  • - Ongoing notification calendar for responsible manager changes, authorised representatives, website addresses, control changes, annual financial statements, and reportable situations.

People and governance

  • - Responsible managers must be organisationally close to the provision of financial services, not remote figureheads.
  • - Collective coverage matters: the responsible manager group should cover all services, products, client types, and complexity.
  • - If the business is heavily dependent on one or two people, a key person condition may become a planning issue.
  • - Fit and proper, training, representative supervision, complaints, breach reporting, and financial resources ownership should be mapped around the responsible manager model.

Forms and submission

  • - From 16 June 2025, new AFSL applications and many variations/notifications are made through the ASIC Regulatory Portal.
  • - ASIC no longer uses the old core/non-core proof language in the same way; the FAQ says the proof documents now needed are People Proofs and portal uploads.
  • - Before submission, read the AFS Licensing Kit and current FAQ, then upload requested documents through the portal transaction.

Timeline risks

  • - Incomplete, incorrect, or unsupported information can lead to return, refusal, or substantial delays.
  • - Responsible manager evidence that is too generic, not product-specific, or not tied to decision rights is a common weakness.
  • - Variation timing can be affected if responsible manager changes must be notified before the variation application.

Questions to ask advisers

  • - Do the responsible managers collectively cover every requested authorisation?
  • - Which RG 105 option or submission route best supports each person's competence?
  • - Is the applicant likely to receive a key person condition because competence depends on too few people?
  • - Which portal transaction must happen first: responsible manager change, AFSL variation, or new AFSL application?

Common mistakes

  • - Naming respected industry people who are not actually responsible for day-to-day decisions.
  • - Using the same responsible manager narrative for every financial product and client type.
  • - Confusing financial adviser exam/relevant provider status with responsible manager organisational competence.
  • - Relying on old eLicensing or proof-upload assumptions after the portal transition.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.