Focused comparison

Australia asset management vs United Kingdom asset management

A focused comparison for asset management businesses choosing between Australia and United Kingdom.

QuestionAustraliaUnited Kingdom
Likely routeAFSL authorisations for managed investment, dealing, advice, or managed discretionary accountsFCA managing investments or portfolio management permission
Key peopleResponsible managers with appropriate competence and organisational capacity Authorised representatives where services are provided under another licenseeSenior Manager Function approval where a controlled function applies Certification for relevant staff under SM&CR where applicable
Corporate evidencePeople and competence; Governance and accountability; Capital and financial resources; Compliance framework; Custody and client assets; Financial forecasts; Official-source route memo; Public register verification plan; Questions log for qualified advisersPeople and competence; Governance and accountability; Capital and financial resources; Compliance framework; Custody and client assets; Financial forecasts; Official-source route memo; Public register verification plan; Questions log for qualified advisers
Capital/resourcesFinancial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations.Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model.
TimelineOften 4 to 8+ months depending on authorisations and proof quality.FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months.
Common bottlenecksRequested authorisations are broader than the actual operating plan can support Responsible manager evidence is thin or not matched to all authorisationsPermissions requested do not match the actual operating model Financial forecasts are inconsistent with the applicant legal entity or prudential category