What is an AFSL in 2025?
An Australian Financial Services Licence (AFSL) remains a legal requirement for any business or individual providing financial services in Australia.
With ASIC's updated Regulatory Portal in 2025, the application process has been streamlined but remains rigorous.
ASIC’s Information Sheet 294 (INFO 294) confirms a major shift in the way businesses apply for an Australian Financial Services (AFS) licence. As of 16 June 2025, the traditional eLicensing system was replaced by the ASIC Regulatory Portal, introducing a modern, streamlined, and more transparent process for financial service providers.
Key Changes to AFS Licence Applications
- Mandatory digital filling - From 16 June 2025 all AFSL applications, variations, suspensions, cancellations, and change of details must now be completed online - transactions - processed in the ASIC Regulatory Portal, replacing the legacy eLicensing forms (FS01, FS03) are no longer accepted.
- Applications are now referred to as transactions instead of forms (e.g. FS01, FS03, FS20).
- Only People Proofs are required – no more “core” or “non-core” proofs.
- The old method of sending documents via email or a separate system (MOVEit) is no longer used. No need for MOVEit uploads or worrying about 10 MB file limits.
- Fit and proper person information is now captured directly in the application.
Benefits of the New Portal
The ASIC Regulatory Portal improves the application experience with:
- A guided, user-friendly interface with tailored questions.
- Pre-filled information where ASIC already holds data.
- Flexible authorisation selections (e.g. limiting advice to retail or wholesale clients, or restricting derivatives/FX contracts to hedging purposes only).
- Removal of outdated requirements such as business references and bankruptcy certificates.
What Financial Service Providers Must Do
If you need to apply for or vary an AFS licence now:
- Register an ASIC Regulatory Portal account if you haven’t already.
- Clearly define your financial services and select the right authorisations.
- Upload supporting documents, including People Proofs.
- Ensure your systems and processes are ready to meet AFS licence obligations under the Corporations Act 2001.
Why This Matters
The move from eLicensing to the ASIC Regulatory Portal reduces red tape, simplifies compliance, and ensures that AFS licence applications are assessed more efficiently and transparently.
Key Services Requiring an AFSL:
✅ Financial product advice (retail or wholesale)
✅ Dealing in securities, derivatives, or forex
✅ Operating a managed investment scheme (MIS)
✅ Providing custodial/depository services
✅ Trustee services (including SMSF advice)
New for 2025:
· Enhanced digital submission requirements
· Stricter Responsible Manager assessments
· Updated compliance expectations for crypto-related services
Step 1: Check If You Need an AFSL
Use our quick-reference table:
💡 Free Assessment: Contact our team for a personalised evaluation.
Step 2: Preparing Your 2025 AFSL Application
- Applications are no longer called forms (FS01, FS03, FS20, etc.).
- They are now called transactions in the portal.
- Examples of transactions you can complete:
- Apply for a new AFS licence
- Apply for a variation to your licence
- Suspend or cancel an AFS licence
- Notify change of details, change of responsible manager, or change of control
📌 Timing for Essential Supporting Documents
Previously: You had to provide Core Proofs and Non-Core Proofs.
Now: You only need to provide People Proofs. These are documents about your ‘fit and proper people’ and responsible managers (e.g. qualifications, background checks).
- No separate MOVEit uploads – all documents are uploaded directly in the ASIC Regulatory Portal.
- No 10 MB file limit anymore.
Business & Compliance Documentation
- Updated business description (must align with ASIC's new template)
- Compliance framework reflecting 2025 regulatory changes
- Risk management plan with cybersecurity protocols
People Proofs - Responsible Managers (RMs) - 2025 Requirements
Organisational Competence Matrix (ASIC’s new format)
- When required: At the application stage.
- ASIC now requires this in their new structured format to demonstrate that your nominated responsible managers collectively meet the organisational competence obligation under s912A of the Corporations Act.
- This replaces the old Core Proof B1 (Organisational Competence Statement).
ASIC now requires:
🔹 Minimum 2 RMs for most applications
🔹 Digital verification of qualifications
🔹 Annual RM competency assessments
Key RM Criteria:
✔ 5+ years' recent industry experience
✔ Formal qualifications (RG 146 + degree)
✔ Clean regulatory history (police & bankruptcy checks)
Financial Resources
Under the old system, you had to lodge the B5 Financial Statements and Financial Resources proof as part of your AFS licence application.
👉 Now (from 16 June 2025 onwards):
- You do not need to submit financial statements and financial resources documents at the time of application.
- Instead, ASIC will only ask for these later at the “requirements stage” — that’s the stage when ASIC is considering whether to grant your licence and may need additional documents before final approval.
- This reduces upfront paperwork and speeds up the initial application process.
- Increased NTA thresholds for certain services (2025)
- Real-time financial reporting via ASIC's portal (2025)
Professional Indemnity (PI) Insurance – minimum $2M coverage for retail clients
- When required: At the requirements stage, not upfront.
- If ASIC is prepared to grant you a licence, they will issue a requirements letter. - without this, ASIC will not finalise your licence.
Compliance Training Records (digital logs required)
- When required: Generally after your licence is granted, as part of ongoing compliance and monitoring.
- You don’t need to lodge training records in the initial application.
- However, ASIC can:
- Ask for training logs during the assessment stage if they need evidence your staff are properly trained.
- Review your compliance training program as part of surveillance or monitoring once you are licensed.
- Digital logs must be accessible and up to date to demonstrate compliance with s912A obligations (adequate training and competence of representatives).
Step 3: Submitting via ASIC's 2025 Portal
- Create and register your ASIC Regulatory Portal account.
- All applications (“transactions”) must now be lodged on the new portal – the old eLicensing system is no longer in use.
- Complete Form FS01 (now with AI-assisted validation)
- Upload documents in specified digital formats
- Pay fees (from $1,750; crypto services +20%)
⏳ Processing Time: 3-5 months (with complete submission)
Step 4: ASIC's 2025 Assessment Process
ASIC now:
🔍 Automatically flags incomplete applications
📧 Responds within 10 business days for queries
✅ Issues digital licences upon approval
Top 2025 Rejection Reasons:
❌ Insufficient RM engagement evidence
❌ Non-compliant digital document formatting
❌ Inadequate cybersecurity measures
Step 5: Post-Licence Compliance in 2025
New obligations include:
✔ Quarterly compliance attestations
✔ Digital audit trail maintenance
✔ Mandatory staff training on updated RG 105
Key Requirements for Retail Client Services
If you intend to service retail clients, additional conditions apply:
1. Professional Indemnity (PI) Insurance
- Must meet ASIC RG 126 standards
- Minimum coverage of $2 million per claim
- Must be active before your AFSL goes live
- Policy must cover all retail services provided
2. AFCA Membership
- Mandatory membership with the Australian Financial Complaints Authority
- Required for external dispute resolution
- Annual fees apply based on business size
3. Auditor Appointment
- Must appoint an approved auditor within one month of licence grant
- Required to notify ASIC of auditor details
- Annual audits mandatory for retail licensees
4. AUSTRAC Registration
- Required for businesses dealing with AML/CTF-regulated services:
- Foreign exchange (FX) providers
- Non-cash payment facilities
- Crypto asset exchanges
- Must implement AML/CTF program
Preparing Your AFSL Transactions – (Previously Called Proofs)
ASIC still requires a detailed suite of information to demonstrate your competence, financial resources, and compliance framework.
What has changed is the way this information is collected:
- Under the old system, these were called Core Proofs and Non-Core Proofs, lodged as separate documents.
- Under the new ASIC Regulatory Portal, the same information is now built into the online transaction form through structured fields and tailored questions.
- The only documents you now upload separately are People Proofs (evidence relating to responsible managers and ‘fit and proper people’).
👉 In other words, the “proofs” haven’t disappeared — they’ve just been absorbed into the AFSL application process within the portal, making the system more streamlined.
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Preparing Your AFSL Transactions – (Previously Called Proofs)
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Preparing Your AFSL Transactions – (Previously Called Non Core Proofs) - (sometimes called “supporting proofs”) were extra documents ASIC could require depending on your business model.
Compliance Framework – Your Ongoing Obligations
An AFSL comes with continuous compliance obligations that must be operational from day one:
Essential Compliance Components
✔ Written compliance policies covering:
- Conflicts of interest management
- AML/CTF program (where required)
- Complaints handling procedures
- Breach reporting processes
✔ Staff training and monitoring programs
- Annual compliance training
- Ongoing competency assessments
- Representative supervision framework
✔ Incident management systems
- Breach identification procedures
- ASIC reporting timelines (10 days for significant breaches)
- Remediation processes
✔ Record-keeping and auditing
- Minimum 7-year document retention
- Annual compliance audits
- Financial record requirements
Key Takeaways for 2025 Applications
- Retail services require additional safeguards (PI insurance, AFCA, audits)
- Proofs must be comprehensive and service-specific
- Compliance starts pre-licence - systems must be operational at grant
- Digital readiness is critical for ASIC's updated portal
- Start early – Allow 6+ months for the process
- Invest in digital readiness – ASIC now requires machine-readable documents
- Prioritise RM selection – ASIC is rejecting "paper-only" managers