Focused comparison

Australia investment advice vs United Kingdom investment advice

A focused comparison for investment advice businesses choosing between Australia and United Kingdom.

QuestionAustraliaUnited Kingdom
Likely routeAFSL financial product advice authorisation and adviser registration where retail personal advice is providedFCA advising on investments 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; Compliance framework; AML/CFT and financial crime; Complaints and conduct; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisersPeople and competence; Compliance framework; AML/CFT and financial crime; Complaints and conduct; Regulatory reporting; 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