Credit broking, mortgage broking and consumer finance intermediaries

No. ACL covers specified credit activities under the National Consumer Credit regime, while AFSL covers financial services activities under the Corporations Act. Consumer lending or specific loan assistance must be assessed separately from securities, funds, insurance, foreign exchange, margin lending and similar activities. Holding both licences does not remove the need to meet the competence, financial and compliance requirements for each.ASIC INFO101

RG207 does not prescribe a uniform minimum paid-up share capital or fixed NTA amount for ordinary ACL holders not regulated by APRA. Sufficient resources to pay debts as they fall due and cover business, supervision and exit costs should be demonstrated, taking into account information for at least the next 12 months. Share capital, NTA, cash flow, loan funds and PI cover must be assessed separately; individual conditions and other regulatory statuses apply separately.RG207

No uniform requirement for two managers at an ordinary ACL has been verified. RG206 assesses the number based on scope, scale and complexity; a small business may have one person genuinely responsible for day-to-day credit decisions, while a larger business may need several people to provide coverage. A Pty Ltd must have at least one director ordinarily resident in Australia under company law; this is not the same rule as the number of responsible managers for ACL.RG206

Usually, qualifications alone are not sufficient. RG206 minimum expectations combine at least two years of relevant and effective experience with a relevant Certificate IV or higher qualification; the responsible manager for third-party home loan assistance should hold at least a Certificate IV in Finance and Mortgage Broking. The person must genuinely manage the business and have the time and authority to do so; their name cannot simply be borrowed, and experience gained through unlawful unlicensed operations cannot be counted.RG206

No. A firm engaged solely in lending or leasing its own funds, and meeting the specific definition in reg 12 and the actual licensing conditions, may qualify for the PI exception, but must still have appropriate indemnity arrangements. Third-party brokers generally need PI or an alternative arrangement approved by ASIC; RG210 minimum expected insurance cover of AUD 2 million for each claim and in aggregate is not capital. Revenue, representatives and risk may require higher cover.RG210

ASIC's current page permits an application to be lodged before becoming an AFCA member, but membership in the credit licensee category is required before the licence is granted. Applicants should still arrange membership early and prepare an internal complaints process and ongoing membership maintenance. Lodging an AFCA application does not establish that all licensing conditions have been met.ASIC application steps

Statutory BNPL entered the national consumer credit regime from 10 June 2025; zero interest or merchant-funded fees are not general grounds for exemption from licensing. LCCC may, subject to conditions, opt for modified responsible lending, but financial inquiries, verification and assessments of unsuitability still apply. The 2025 transitional arrangements are not a general basis for new applicants to operate without a licence in 2026.ASIC BNPL licence

Neither. The AUD 2,000 in RG281 relates to specific assessment and credit reporting steps; the presumption for a small target amount may also be rebutted and does not replace an assessment of financial circumstances. The fee cap in LCCC is separately aggregated over a 12-month period for the same consumer and provider; it is not an equity capital requirement or a fixed limit for a single loan.RG281

ACL should not apply AFSL’s 30-business-day rule. Current reg 9(10) requires details of a change of control to be submitted in the approved form when the change becomes known, no later than 10 business days after it occurs. Control is not limited to a majority shareholding; it also includes control of the board and of substantive business policies. An acquisition also requires checks on fitness and propriety, managers, resources and authorisations. Notification does not constitute ASIC’s approval of the transaction or new business.Current Credit Regulations

It cannot be used automatically. ACL belongs to the licensed legal entity, and a transaction involving assets or a loan portfolio does not transfer the licence to the buyer. The transferee must verify its own licence or applicable exemption, contractual rights and arrangements for the original assessment materials; acquiring pre-2010 contracts now does not automatically confer the original lender’s COI lender status.RG207

ASIC's current authorisation guidance expressly states that all credit activities do not include debt management services, which are listed separately. Fee-charging assistance with debt or credit reporting issues requires separate verification of the activities, authorisation and exemptions involved; it cannot be summarised solely by reference to a broking authorisation or an all-activities category.ASIC authorisation FAQ

No. The 150-day/240-day figures are public processing targets for 70%/90% of applications respectively, not commitments for an individual case. Commercial preparation also involves personnel, background evidence, AFCA, funds, systems and further information requests. The 4–9 or 6–12 month ranges in this guide are non-official project-budget estimates only; the actual period may be longer, and a fixed approval promise should not be sold.ASIC REP825

An Australian company may use a third party’s physical Australian street address, such as an accountant’s, as its registered office, but the occupier’s written consent is required; a PO Box cannot be used. The principal place of business must be genuine and cannot be a post office box, while the mailing address may be a PO Box. Address compliance does not mean that ACL’s requirements for actual personnel, systems and supervisory capacity have been met.ASIC Company address

No. CL50 must be lodged within 45 days after the licence anniversary. The licensee must also maintain financial resources, staff competence, CPD, AFCA/compensation arrangements, client and representative supervision, and IDR data and reporting obligations. A certificate lodged electronically on time may have no lodgement fee, but this does not remove industry levies or other operating costs; ceasing to take on new business does not automatically remove obligations to existing clients.CL50

No. The amendments commencing on 5 September 2026 only extend the end date of the exception period specified in reg 28RB to the beginning of 3 October 2036, in relation to specified responsible lending obligations for loans that meet the genuine and non-minor/incidental small business purpose test. The borrower, purpose and each applicable condition must still be verified; this cannot be expanded into an exemption from all ACL licensing, disclosure or complaints obligations.Revised text