Responsible Manager Competence and Development Policy Template (AFSL)

Aligned with ASIC RG 105 & s912A

$189.00 +GST

Free Download for COMPASS Members

Use this policy to:
  • Document how you vet Responsible Managers for good fame and character;
  • Show how your Responsible Managers meet the five RG 105 pathways;
  • Run a CPD program and training register for Responsible Managers;
  • Support your organisational competence obligations under section 912A(1)(e) of the Corporations Act.

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Table outlining Responsible Manager Competence and Development Policy obligations, timing, and responsible persons.

About this Document

Use this policy if you:
  • Hold an AFSL and need a written policy showing how you keep your Responsible Managers competent and of good fame and character
  • Are nominating new Responsible Managers and want a documented vetting process covering police and ASIC register checks
  • Need to evidence how your Responsible Managers meet the knowledge and experience standards in ASIC Regulatory Guide 105
  • Want a structured continuing professional development program and training register for your Responsible Managers
  • Need a Board-approved policy that supports your obligation to maintain organisational competence under section 912A(1)(e) of the Corporations Act 2001 (Cth)
It is suited to:
  • Australian financial services businesses that nominate, or expect to nominate, Responsible Managers on their AFSL
  • Fund managers, responsible entities and registered scheme operators
  • Wholesale and retail advice licensees
  • Licensees preparing a new Responsible Manager nomination or refreshing their organisational competence evidence for ASIC
What this policy covers:
  • Document control, version history, key obligations, related documents and who the policy applies to
  • The licensing obligations that sit behind the policy, including section 912A(1)(e) of the Corporations Act 2001 (Cth), the Corporations Regulations 2001 (Cth) and RG 105, with a regulatory framework diagram
  • Good fame and character vetting at recruitment, including police checks and ASIC register checks
  • Maintaining adequate skills and competence, including degree and qualification checks, experience assessment and probation monitoring for newly nominated Responsible Managers
  • The five RG 105 knowledge and experience pathways, set out in full and shown at a glance in a diagram
  • Training needs analysis for new and existing Responsible Managers, and how training records are kept
  • Internal and external CPD, including the minimum eight hours per year, and how the training register is maintained
  • Review, update and Board approval arrangements, with a placeholder checklist at Appendix A
You receive an editable Word document with placeholders for your company name, ACN, AFSL number, Responsible Manager names, authorised services and internal job titles, plus drafting notes, worked examples and a six-step completion checklist. It is a practical, lawyer-drafted starting point that you can tailor to your licence conditions and risk profile, and complex or unusual competence questions may still warrant tailored legal advice.

How To Use This Template

This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.

Before you use it, you should:

  • Complete all placeholders, bracketed items and optional fields;
  • Remove any drafting notes or clauses that aren’t relevant to your situation; and
  • Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.

Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.

If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.

This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.

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