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Australian Credit Licence: Broker Application Guide

Opening a licensed brokerage? Check whether you need your own Australian credit licence, then prepare the people, systems, evidence and application costs.

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To get an Australian credit licence, prepare evidence that your brokerage can meet its credit obligations, then lodge Form CL01 with the Australian Securities and Investments Commission (ASIC). You need competent managers and operating systems that work before you apply. A credit representative arrangement is another route if you want to provide mortgage broking services under an existing licensee’s supervision.

An Australian credit licence (ACL) authorises the credit activities stated on the licence. Applying for one doesn’t authorise you to start those activities. A new brokerage must hold the required licence or have another valid authorisation before it starts regulated credit work.

Choose Licence or Representative Status

Choose your own licence if your brokerage can fund and manage the licensee’s ongoing obligations. Choose representative status if an existing licensee’s authorised activities and operating requirements suit your business. Both routes require competent brokers and compliant client work.

ASIC’s licensing guidance explains when credit activities require a licence or another authorisation. Mortgage broking for regulated consumer credit generally falls within this framework. Qualifications alone don’t authorise a person to provide credit assistance.

ResponsibilityYour Own Credit LicenceCredit Representative Arrangement
Authorised workYour licence defines the activities your business can performYour written authorisation must fit within the licensee’s licence
SupervisionYour business establishes supervision and monitors its representativesThe licensee supervises you and sets its monitoring requirements
ComplaintsYour business maintains its complaints system and external dispute resolution membershipFollow the licensee’s complaints process and escalation requirements
RecordsYour business sets compliant retention, access and file-review controlsKeep the records required by law and the licensee’s procedures
CompetenceDemonstrate organisational competence through responsible managers and maintain broker trainingMeet the training and competence standards for your authorised work
Operating decisionsYou control your systems and carry the licensee’s responsibility for themYour agreement can restrict systems, processes and permitted activities

Consider a hypothetical brokerage with a founder, another broker and an administrator. With its own licence, the founder must arrange file supervision, complaint handling and evidence of each broker’s competence. A compliance consultant can help prepare procedures, but the brokerage remains responsible for outsourced functions.

Under representative status, the same team works within the appointing licensee’s authorisation and procedures. Its agreement might require a particular file system or approval before a broker undertakes certain work. The team still records client enquiries and supplies files for supervision, but it follows the licensee’s compliance structure.

Compare the written agreement against how you intend to operate. Identify who reviews files, who handles complaints and what happens to client records if the arrangement ends. The credit representative guide explains that route in more detail.

Credit Licensing and Financial Services Licensing

An Australian financial services licence (AFSL) covers specified financial services under a separate regime. A credit licence covers specified credit activities. Holding one doesn’t automatically authorise the activities covered by the other, as ASIC’s guidance for dual licensees explains.

Check a Licence Number

Use ASIC’s professional registers search to check a credit licence or credit representative. Search by name or licence number, then select the correct register and match the legal entity. Check its current status before relying on the number.

A number such as 389328 or 389087 identifies a register entry. The number alone doesn’t establish who currently holds it, whether it remains active or whether it covers your proposed activities. Use the current register result and the relevant authorisation documents for those decisions.

Prepare People and Operating Systems

Prepare evidence of who runs the credit business and how the brokerage will comply in day-to-day work. ASIC needs more than a collection of policy documents. Its guidance for small credit businesses requires arrangements and documented systems to be in place when you apply.

Responsible Managers and Competence

Responsible managers are the people who make the day-to-day decisions about your credit activities. A person with a qualification but no real management responsibility doesn’t demonstrate how your business will operate.

Regulatory Guide 206: Credit Licensing: Competence and Training explains ASIC’s expectations. For third-party home loan credit assistance, responsible managers need at least a Certificate IV in Finance and Mortgage Broking and two years of relevant problem-free experience. Match each manager’s qualifications and experience to the activities they will manage.

Keep qualification records and a work history that explains the manager’s actual duties. Identify which activities each manager covers and who makes decisions when that person is absent. Use the responsible manager evidence template to organise this information.

Responsible managers must maintain their competence after grant. ASIC expects at least 20 hours of continuing professional development each year. Separately, ASIC’s credit representative guidance sets training expectations for brokers providing third-party home loan credit assistance.

Fit and Proper People

Identify everyone ASIC must assess under the fit and proper person requirements. This group can extend beyond the responsible managers to officers and controllers. Use the entity-specific list in ASIC’s information sheet on fit and proper people.

Collect the required personal information and supporting checks for each relevant person. National criminal history and bankruptcy checks must be no more than 12 months old. Match names and roles across the checks, company information and application.

Funding, Insurance and Complaints

Show how the brokerage will pay its debts and fund supervision and compliance. Regulatory Guide 207: Credit Licensing: Financial Requirements expects planning to consider at least the next 12 months. Keep evidence of available cash and any funding arrangements your plan relies on.

For example, a new brokerage can’t treat a forecast settlement commission as cash already available to pay its insurance premium. Put expected receipts beside the dates when wages, insurance and compliance costs fall due. Explain how confirmed funding covers any shortfall.

You must be a member of the Australian Financial Complaints Authority (AFCA) when you apply. Prepare an internal dispute resolution process that identifies who receives a complaint and who investigates it. The procedure must also explain how the consumer can escalate the complaint.

Most mortgage broking applicants meet the consumer compensation requirement through adequate professional indemnity (PI) insurance. ASIC needs confirmation of adequate arrangements before it can grant the licence. Its application instructions describe the insurance questionnaire and certificate of currency.

Submit and Budget the Application

Submit an application that connects the proposed credit activities to the people and systems that will perform them. Use Regulatory Guide 204: Applying for and Varying a Credit Licence alongside ASIC’s online application instructions.

  1. Confirm the applicant entity and its proposed activities. A brokerage providing credit assistance generally selects the authorisation for activities other than as a credit provider or lessor. Lending money yourself changes the authorisation you need.
  2. Update existing ASIC register details before starting the application. Pre-filled information comes from those registers, so an incorrect company record needs correction at its source.
  3. Assemble the summary business description and people evidence. Include the required checks and responsible manager information, with a consistent description of the brokerage’s work.
  4. Connect each activity to an accountable person and a working procedure. Keep an example record that shows how staff will follow the procedure.
  5. Open ASIC’s start or resume credit licence application page. Use Form CL01 and follow the application route for your existing portal access.
  6. Review the declarations and submit the application through the authorised person. Pay the application fee and retain the submitted application, attachments and payment record.
  7. Respond to ASIC’s assessment requests. If ASIC asks about a system, supply the procedure and the evidence showing how your brokerage will use it.

For the hypothetical two-broker business, the operating evidence could look like this. These examples show a workable evidence chain, not extra prescribed application forms.

Proposed WorkAccountable PersonProcedureSupporting Record
Give home loan credit assistanceResponsible manager oversees broker workGather client information, assess the file and review the recommendationExample assessment file with the reviewer’s sign-off
Supervise the second brokerFounder assigns a competent reviewerReview files and escalate errorsReview register with corrective actions and completion dates
Handle a complaintNamed complaints officerRecord, investigate and respond within applicable requirementsComplaint register and example response process
Maintain competenceResponsible manager oversees trainingIdentify training needs and confirm completionQualification evidence and continuing development register

Application Costs and Timing

As at 2 October 2026, ASIC’s published credit licence application fees list $1,798 for an individual applying without credit provider authorisation. The fee for an applicant other than an individual, without credit provider authorisation, is $2,055. These are Australian-dollar application fees.

For applications including credit provider authorisation, the listed fees are $3,468 for an individual and $4,624 for other applicants. ASIC’s statutory fee guidance states that its statutory fees aren’t subject to goods and services tax (GST). A mortgage broker’s application budget must also cover the business’s own preparation costs.

Budget separately for background checks, AFCA membership and PI insurance. Include qualification or training costs where needed, compliance support and the staff time required to operate the systems. An application service can help organise the submission, but hiring one doesn’t transfer the applicant’s responsibilities.

ASIC assesses the applicant’s fitness and ability to meet its obligations. Complexity and requests for further information affect the time needed, so don’t set your opening date on an assumed approval date. Keep any existing valid authorisation in place for work you continue while the application is assessed.

Evidence Gaps That Delay Progress

An expired check needs a replacement before submission. A missing controller or officer needs to be added using the fit and proper person requirements. If the business description and selected authorisation disagree, correct the activity description or authorisation before lodging.

A generic compliance manual also needs work if it names nobody to carry out its procedures. Assign the person, show where the record will be kept and explain how management reviews failures. ASIC can return or refuse an incomplete application, or seek further information that delays assessment.

Plan Ongoing Obligations

Keep the people and controls in place after ASIC grants the licence. Application evidence establishes how the business intends to comply. The operating records must then show what the brokerage actually does.

ASIC’s ongoing obligations guidance covers competence, supervision and compliance systems. It also covers complaints, compensation arrangements, resources and conflicts of interest. Responsible lending obligations apply to the relevant credit work.

Mortgage brokers must also meet the best interests duty. Keep evidence of why the recommendation serves the client, including how you handle a conflict between the client’s interests and your own.

Keep file-review results and training records current. Monitor complaints and correct recurring failures. Review the controls when you add a broker, change your activities, replace a responsible manager or change an outsourced service.

Loss of insurance cover or a funding shortfall also needs immediate attention. A departure matters especially where the licence contains a condition naming a particular manager. Read the condition and arrange the required response before assuming another employee can fill that role.

Use a documented process to assess reportable situations and take required action. ASIC’s notify, investigate and remediate guidance explains obligations triggered by certain breaches affecting mortgage broking consumers. Keep records of the investigation and any consumer remediation.

Licensees also have annual reporting and industry funding obligations. ASIC’s annual compliance certificate guidance requires lodgement no later than 45 days after the licensing anniversary. Certificate preparation and lodgement are covered in the annual compliance certificate guide.

Ending a Licence Requires Cancellation

Missing an annual compliance certificate doesn’t make a credit licence lapse. It breaches the filing obligation while the licence remains in force. Stopping new business or asking ASIC to cancel the licence also doesn’t establish that cancellation has occurred.

ASIC’s credit licence cancellation route uses Form CL08, lodged online through the Credit registers portal. The request needs an appropriately authorised signatory. ASIC reviews the request and sends a letter and notice when it cancels the licence.

Form CL08’s instructions list no fee for an electronic request. Keep meeting applicable obligations while ASIC considers the request. Plan who will handle live client files and complaints before the business closes or moves to representative status.

Record the status of each open application and identify who will deal with it under valid authorisation. Preserve access to records needed for past work and complaints. Ending the licence doesn’t erase responsibility for work already performed.

Read the cancellation notice for any continuing terms. Section 62 of the National Consumer Credit Protection Act 2009 allows ASIC to continue a cancelled licence for specified purposes. Those terms can govern what remains to be done after cancellation.

Before starting under a newly granted licence, confirm its legal entity, authorised activities and conditions against your operating plan. Every activity needs a competent person, an implemented procedure and a record staff can actually produce. If you later leave that licence, confirm ASIC’s cancellation notice and the arrangements for outstanding client work before treating the transition as complete.

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