Australian Financial Services Licensing (AFSL) Forum


There is no ASIC policy which sets out how many AFSLs a Responsible Manager (“RM”) can act for.  We know from experience that ASIC is reluctant to allow an RM to be on more than 3 AFSLs.  However, depending on how many other RMs there are on each licence, and the nature of your role in each licence, ASIC may only allow you to be on 1 or 2 AFSLs.  As you may know, it is through its RMs that a licensee maintains its competency (competency requirements are summarised in ASIC’s RG 105).  ASIC considers that an RM should:

  • be directly responsible for significant day-to-day decisions about financial services;
  • decide how financial services are provided and supervise the provision of those services;
  • play an active role in fostering compliance culture; and
  • oversee the financial services being provided.

Before agreeing to join more than one AFSL, you should also also consider: your availability, potential conflicts of interest, confidentiality and how your experience matches up with each AFSL’s licence conditions.

Author: Paul Derham
Co-contributor: Sarah Holley
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