Responsible Manager Sourcing
Responsible Manager Sourcing.
ASIC requires every AFSL holder to nominate Responsible Managers with demonstrable knowledge and skill across each authorisation. AFSL Exchange sources qualified RMs for new applications, post-sale continuity, and keyperson condition coverage.
The role
The role of a Responsible Manager.
A Responsible Manager (RM) is an individual nominated to an AFSL holder to demonstrate that the licensee has the organisational competence required under section 912A of the Corporations Act. ASIC sets out the framework for assessing organisational competence in Regulatory Guide 105 (RG 105).
In practice, RMs are the people ASIC looks to when determining whether a licensee has the knowledge and skills to provide the financial services it is authorised to provide. They do not need to perform the day-to-day work, but their experience must cover the authorisations held, and they must have sufficient authority and access within the licensee to genuinely oversee the relevant services.
Most AFSL holders nominate two RMs. The combined experience of nominated RMs must cover every authorisation on the licence — not just the most prominent ones. ASIC expects RMs to be involved in the business, not merely listed on paper.
Most licences carry a keyperson condition tied to named RMs. If a keyperson RM leaves, the licensee must notify ASIC and, in many cases, source a replacement before the licence can continue operating without restriction.
When you need an RM
Common scenarios.
We source Responsible Managers in four recurring situations.
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New AFSL applications
An applicant has identified the authorisations it wants to seek but does not have sufficient qualified RMs in-house. We match the application's authorisation profile to RMs in our network whose experience covers the relevant services.
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Post-acquisition continuity
A buyer has acquired an AFSL-licensed entity and the previous RMs are not continuing, or are continuing only through a transition period. The buyer needs RMs who can step in and satisfy keyperson conditions before, or shortly after, settlement.
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RM departures from existing licensees
An existing licensee has lost a Responsible Manager through resignation, retirement, or change of role, and needs a replacement to maintain its authorisations and satisfy any keyperson conditions on the licence.
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Expansion into new authorisation categories
A licensee adding new authorisations to its existing licence needs RMs whose experience covers the new categories. The existing RMs' experience may not be sufficient under RG 105 for the new scope.
Our network
Our network of Responsible Managers.
AFSL Exchange maintains an active network of qualified Responsible Managers available for appointment to AFSL holders.
- Coverage across authorisation categories.
- FX and derivatives, retail and wholesale dealing, market making, managed investment schemes, financial planning, insurance broking, and digital asset operations. Different categories require different RM profiles, and we match candidates to your specific authorisations.
- Australian-resident.
- All RMs in our network are Australian-resident, satisfying ASIC's residency expectations and the practical reality of meaningful oversight.
- Vetted experience and qualifications.
- Each RM has demonstrable experience aligned to one or more of the RG 105 assessment options. Experience and qualifications are validated before any candidate is introduced.
- Flexible engagement.
- RMs are available for full appointments as nominated RMs on the licence, or for defined transition periods covering a gap until an in-house RM is appointed.
How it works
From brief to appointment.
Our RM sourcing process follows four steps.
- 01
Brief
Tell us the authorisations the licence holds (or will hold), the licensee's context, and the timeline. We need enough detail to identify candidates whose experience genuinely fits.
- 02
Shortlist
We propose a shortlist of RM candidates from our network whose experience covers the relevant authorisations under RG 105. We provide CVs and a summary of how each candidate's experience maps to the authorisations sought.
- 03
Introductions
You meet with the candidates you'd like to consider. Discussions cover the role, the licensee's business, the level of involvement expected, and commercial terms.
- 04
Appointment
Once a candidate is selected, the appointment is formalised: contract between the licensee and the RM, ASIC notification, and inclusion in the licensee's organisational competence proofs or update to ASIC's records.
RG 105
ASIC's Responsible Manager requirements.
ASIC's framework for assessing whether an RM has sufficient knowledge and skills is set out in Regulatory Guide 105. The guide describes five options for demonstrating organisational competence; an RM must satisfy at least one.
- Option 1
Industry experience plus an industry-relevant qualification.
Three years of relevant experience in the last five years, combined with a qualification specifically tailored to the relevant financial services or products.
- Option 2
Industry experience plus a general higher education qualification.
Five years of relevant experience in the last eight years, combined with a relevant tertiary qualification — typically a bachelor degree in business, commerce, economics, or law.
- Option 3
Industry experience plus an industry-recognised qualification.
Three years of relevant experience in the last five years, combined with a qualification approved by the relevant industry body — for example, a SIA Graduate Diploma, FINSIA qualification, or RG 146-compliant training.
- Option 4
Industry experience plus relevant short-form training.
Five years of relevant experience in the last eight years, combined with relevant short-form training covering each of the financial services and products.
- Option 5
Eight years of relevant experience.
Eight years of relevant experience in the last eleven years, without a corresponding qualification, where the experience is sufficient on its own to demonstrate competence for the specific authorisations sought.
Beyond these options, RMs must also satisfy "fit and proper" requirements: no relevant criminal history, no banning orders, no insolvency events, and no other matters that would disqualify them from a position of responsibility in financial services.
RMs are not authorised representatives. An authorised representative is a person authorised by an AFSL holder to provide financial services on behalf of the licensee. An RM is responsible for the licensee's organisational competence to provide those services. The same person can hold both roles, but the roles are legally distinct.
RMs are not directors. A director is responsible for the company's overall management and statutory obligations. An RM is responsible for the financial services competence of the licensee. The roles can be held by the same person, but each carries different obligations under different parts of the Corporations Act.
Responsible Managers — common questions
What is a Responsible Manager?
A Responsible Manager is an individual nominated to an AFSL holder under section 912A of the Corporations Act to demonstrate that the licensee has the knowledge and skills required to provide the financial services it is authorised to provide. ASIC's framework for assessing RM competence is set out in Regulatory Guide 105.
How many Responsible Managers does an AFSL need?
ASIC requires at least one RM, but most licences nominate two. The combined experience of the nominated RMs must cover every authorisation on the licence. More complex authorisation profiles often require more than two RMs to provide adequate coverage.
Can a Responsible Manager work for multiple AFSLs?
Yes, in principle. ASIC does not prohibit an RM from serving multiple licensees. In practice, the RM must have sufficient time, authority, and access within each licensee to genuinely oversee the relevant services. ASIC will look at the substance of the involvement, not just the title.
What happens if a Responsible Manager leaves?
The licensee must notify ASIC of the change. If the departing RM is named in a keyperson condition on the licence, the licensee typically has a defined period to nominate a replacement; failure to do so can result in restrictions on the licence or, in some cases, suspension of authorisations. We source replacement RMs for licensees in this situation.
Do Responsible Managers need to be Australian residents?
ASIC expects RMs to be Australian-resident, and in practice this is the strong norm. Non-resident RMs are theoretically possible but attract additional scrutiny and are rarely accepted for licences servicing Australian clients. All RMs in our network are Australian-resident.
What qualifications does a Responsible Manager need?
It depends on the option under RG 105 they're relying on. Some options require a specific industry qualification, others require a general tertiary qualification, others require only experience. The qualifications must be appropriate for the specific financial services and products the licensee is authorised to provide. Generalist qualifications are not sufficient for specialist authorisations.
Get in touch
Need a Responsible Manager?
Tell us the authorisations the licence holds, the licensee's context, and when you need the RM in place. We'll come back with a shortlist of candidates from our network.