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Australian Securities and Investments Commission

Australia responsible manager organisational competence route map

How responsible manager evidence supports AFSL organisational competence under RG 105, and why it is separate from the ASIC financial adviser exam and RG 146 staff training.

Exam focus

RG 105 organisational competence and responsible manager proof mapping for AFSL applicants and licensees.

Who this helps

  • - AFSL founders
  • - Responsible manager candidates
  • - Compliance consultants
  • - Existing licensees changing responsible managers

Route map

  1. 1. Define each AFSL authorisation and the financial services/products the business will provide before choosing responsible managers.
  2. 2. Map responsible managers to significant day-to-day business decisions, fit and proper status, and the qualifications/experience options in RG 105.
  3. 3. For a new or changed responsible manager, prepare ASIC portal evidence before appointment or change notifications.
  4. 4. Keep adviser professional standards and representative appointment evidence separate from responsible manager organisational competence.

Licensing context

  • - RG 105 is about an AFS licensee's organisational competence obligation, not a consumer-facing adviser exam route.
  • - ASIC's responsible manager page says licensees notify changes and ASIC uses the information to assess whether changes affect organisational competence.
  • - A person can be a responsible manager, relevant provider, authorised representative, director, or employee in different combinations, but each status needs its own evidence analysis.

Study focus

  • - Build a competence matrix by authorisation, financial product, business line, responsible manager, experience, qualifications, and time commitment.
  • - Prepare a proof file with Statement of Personal Information, criminal history checks, competence history, qualification certificates, and overseas checks where relevant.
  • - Connect responsible manager evidence to policies, delegation, supervision, incident escalation, outsourcing, and compliance calendar ownership.

What to verify before relying on the route

  • - Whether each responsible manager is directly responsible for significant day-to-day business decisions about the relevant financial services.
  • - Whether the responsible manager's practical experience matches the actual products and services in the AFSL authorisations.
  • - Whether new appointments, ceasing, or changed days spent on responsible manager duties trigger ASIC notification timing.

Application tie-in

  • - AFSL applications should show a complete responsible manager matrix and not rely on adviser-exam passes as organisational competence evidence.
  • - Variation or change packs should explain the impact on organisational competence and maintain coverage across all financial services.
  • - Related tools should prompt for authorisation scope, responsible manager coverage, evidence gaps, and ASIC portal submission channels.

Common mistakes

  • - Treating the ASIC financial adviser exam as responsible manager evidence.
  • - Naming a responsible manager who lacks day-to-day decision authority.
  • - Providing generic CVs without mapping experience to each AFSL authorisation.
  • - Missing notification timing when appointing, ceasing, or changing responsible manager details.

Paper and module study maps

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.