AFSL Applications
AFSL Applications.
End-to-end management of new AFSL applications. Authorisation scoping, Responsible Manager nomination, compliance frameworks, and direct ASIC liaison — from initial brief to licence grant.
Apply or acquire
Apply for a new AFSL, or acquire an existing one?
Apply for a new licence
The right choice when you need a specific combination of authorisations that no available licensee matches, when you want a clean compliance slate, or when no suitable acquisition target is on the market. A new application gives you a licence shaped exactly to your business model, with no inherited conditions, history, or obligations.
Typical timeline: 8–12 months
Acquire an existing licensee
Acquisition is often faster, one to three months versus eight to twelve, but only works if a licensee with the right authorisations is available, and only if the inherited compliance position is acceptable to you. For international firms wanting Australian market entry quickly, acquisition usually wins. For firms with novel business models or specific authorisation requirements, applying is usually the better path.
Typical timeline: 1–3 months
Not sure which path fits? We can help you compare options →
What we do
Application services.
We manage AFSL applications end-to-end, taking responsibility for everything between your initial brief and the day ASIC grants the licence.
- Authorisation scoping.
- Translating your business model into the specific financial products, client categories, and service types you need ASIC to authorise. Authorisations that are too narrow restrict the business; too broad attract additional scrutiny and lengthen the assessment.
- Responsible Manager strategy and nomination.
- Identifying which RM profiles your authorisations require under RG 105, mapping them against your team's existing experience, and sourcing additional RMs from our network where required. Most applications need two RMs, but specific authorisations can demand more.
- Compliance framework drafting.
- Building the policies, procedures, and risk management frameworks ASIC expects to see with a credible application. This includes your compliance plan, risk framework, dispute resolution arrangements, professional indemnity arrangements, and the supporting evidence ASIC requires.
- ASIC application preparation and submission.
- Compiling the application itself — the supporting proofs, RM CVs, business descriptions, financial projections — and submitting through the ASIC portal. Every section is prepared to anticipate the questions ASIC will ask.
- Liaison with ASIC through assessment.
- ASIC almost always responds with requests for information (RFIs) during assessment. We manage those responses — typically one to three rounds — working with you on the substantive answers and handling the drafting and submission.
- Post-grant compliance handover.
- Once the licence is granted, transitioning your business to ongoing compliance: monthly, quarterly, and annual obligations, breach reporting procedures, RM reviews, and the operating cadence of a compliant AFSL.
The process
The AFSL application process, step by step.
A new AFSL application typically follows six stages from initial scope to licence grant. Most applications take eight to twelve months end-to-end.
- 01
Scope the authorisations
Define exactly what financial products you'll deal in, who you'll deal with (retail, wholesale, or both), and what services you'll provide. The output is a clear list of the authorisations to be sought.
- 02
Nominate Responsible Managers
Confirm which RMs will be nominated, validate their experience against RG 105 requirements for the specific authorisations sought, and gather supporting evidence. If you don't have sufficient in-house RMs, this is when external RMs are sourced.
- 03
Build the compliance framework
Draft the compliance plan, risk management framework, conflict management policy, dispute resolution arrangements, breach reporting procedures, and operational policies relevant to the authorisations.
- 04
Prepare and submit the application
Compile the application form, all required proofs, and submit through the ASIC portal. Every section is prepared to anticipate the questions ASIC will ask.
- 05
Respond to ASIC's requests for information
ASIC will assess the application and typically issue one to three rounds of RFIs over several months. Each round requires substantive responses involving clarification of business activities, additional documentation, or revisions to compliance policies.
- 06
Licence grant and post-grant setup
ASIC grants the licence, typically subject to standard or specific conditions. Ongoing compliance obligations commence immediately. We transition you to the operating cadence of a compliant AFSL.
Cost and timeline
What an AFSL application costs.
There is no fixed price for an AFSL application. Professional fees are scoped against the work required, and the work required depends on the complexity of what you're seeking and the support you already have in place.
The main cost drivers:
- Authorisation complexity.
- A single-product retail dealing authorisation costs less to prepare than a multi-product application covering retail and wholesale clients, dealing, advising, and market making. More authorisations means more RM proofs, more compliance policies, more ASIC scrutiny.
- Business model novelty.
- ASIC examines novel business models more closely. Crypto and digital asset applications, for example, attract longer assessment times and more rounds of RFIs than equivalent applications in established categories.
- Whether external Responsible Managers need to be sourced.
- Applicants with sufficient in-house RM expertise save the cost of sourcing external RMs. Applicants without need RMs sourced, vetted, and contracted, which adds cost and time.
- Whether compliance frameworks are built from scratch.
- A first-time applicant building a compliance framework from zero is a different scope to a firm with existing policies that need refinement. We work with both, and the fee reflects the work required.
Timeline.
Eight to twelve months is typical from initial brief to licence grant. Faster is possible for simple, single-authorisation applications with clean RMs and prepared compliance frameworks. Longer is common for novel business models or complex multi-authorisation applications.
For a scoped fee estimate, contact us with a brief on the authorisations you need.
Authorisation profiles
Authorisations we commonly apply for.
While every application is scoped to the specific business, several profiles recur often enough to be worth describing.
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FX and CFD brokers
Authorisations to deal in derivatives and foreign exchange contracts, typically for retail and wholesale clients, often including making a market. Requires RMs with relevant derivatives experience, robust risk management around margin and leverage, and detailed product disclosure arrangements.
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Crypto and digital asset operators
Authorisations vary based on activities: dealing in derivatives over crypto assets, dealing in non-cash payment products, or managing investment schemes holding digital assets. ASIC's regulatory approach in this category is evolving, and applications attract close scrutiny.
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Managed Investment Scheme operators
Authorisations to operate registered or unregistered MISs, often including issuing interests, dealing in interests, and providing advice. Responsible entity capacity requires additional financial and operational thresholds.
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Financial advisers
Authorisations to provide personal advice on financial products to retail clients, with the corresponding adviser registration and education obligations under the Corporations Act and FASEA standards.
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Insurance brokers
Authorisations to deal in and provide advice on general or life insurance products, with retail and wholesale client coverage as required.
AFSL applications — common questions
How much does an AFSL application cost?
Costs vary based on the authorisations sought, the complexity of the business model, the number and source of Responsible Managers, and whether compliance frameworks are built from scratch. There is no fixed price. For a scoped estimate, contact us with a brief on the authorisations you need.
How long does an AFSL application take?
Most applications take eight to twelve months from submission to licence grant. Timeline depends on the complexity of the authorisations sought, the responsiveness of the applicant to ASIC's requests for information, and current ASIC processing times. Acquiring an existing licensee, where suitable, can take one to three months instead.
What is a Responsible Manager and do I need one?
A Responsible Manager (RM) is an individual nominated to an AFSL holder who demonstrates the knowledge and skills required to oversee the financial services authorised under the licence, as set out in ASIC's RG 105. Every AFSL holder must nominate at least one RM, and most applications require two. RMs do not need to be employees, but their authority and access must be sufficient for them to meaningfully oversee the relevant services.
Can I apply for an AFSL as a foreign company?
Yes. Foreign companies can apply for an Australian AFSL, but the application must satisfy specific requirements: the company must be registered as a foreign company in Australia, must have an Australian agent, and must meet the same Responsible Manager and financial resource requirements as a domestic applicant. Some foreign companies find acquiring an existing Australian-licensed entity faster than applying directly.
What happens if ASIC refuses my application?
ASIC rarely outright refuses applications. More commonly, ASIC issues RFIs that ultimately lead the applicant to withdraw and resubmit, or to narrow the authorisations sought. If ASIC does formally refuse, the applicant has rights of review through the Administrative Review Tribunal. Most outcomes are negotiated through the RFI process rather than reaching a refusal decision.
Do I need to be ASIC-registered before applying?
The applicant entity must be an Australian-registered company (or a registered foreign company) at the time of application. Sole traders and partnerships cannot hold an AFSL. We can advise on entity structuring as part of scoping the application.
What's the difference between an AFSL and an ACL?
An AFSL (Australian Financial Services Licence) authorises the provision of financial services, including advice on and dealing in financial products such as securities, derivatives, superannuation, and life insurance. An ACL (Australian Credit Licence) authorises the provision of credit services, including advice on and dealing in credit contracts such as mortgages, personal loans, and consumer leases. A business that provides both financial and credit services needs both licences.
Get in touch
Ready to start your application?
Tell us what authorisations you need and what timeline you're working to. We'll come back with a scoped approach and a fee estimate.