ASIC Reissues RG 146 Guidance on Training Standards for Financial Product Advisers

Key Takeaways

• ASIC's Regulatory Guide 146 sets out minimum training standards for AFS licensees and representatives who provide financial product advice to retail clients, outlining Tier 1 and Tier 2 education requirements based on advice type and product category.
• Compliance teams must ensure adviser training, assessment, and continuing education policies align with these standards, as licensees bear ultimate responsibility for adviser competency.

Deep Dive

RG 146 establishes the framework ASIC uses to assess whether financial product advisers are adequately trained to provide advice to retail clients, and it remains a foundational compliance document for AFS licensees. The guide applies to all natural persons providing general or personal financial product advice to retail clients, with limited exemptions for wholesale client advice, scripted customer service interactions, clerical conduct, and other narrowly defined categories. Compliance and training teams must map their adviser population against the Tier 1/Tier 2 and general/personal advice matrix in Table 1 to confirm each adviser's training course, or individual assessment pathway, matches the relevant knowledge and skill requirements.

A key structural feature is the reliance on the ASIC Training Register and authorized assessors (RTOs, SAOs, or accredited industry associations) to validate training courses, except for basic deposit products and related non-cash payment products, which licensees may self-assess. Compliance teams should verify that any internally approved training courses for basic deposit products are properly documented and that evidence of adviser competency assessments is retained and auditable. Licensees are explicitly responsible for ensuring their representatives meet training standards, meaning gaps in individual adviser qualifications become direct licensee compliance failures.

Note that the document includes an editor's note indicating Sections D and E (course approval and assessment methodology) were under review following Consultation Paper 153 on a professional development framework, with historical consultation anticipated around December 2012. Firms should verify current applicability of this version against subsequent ASIC updates (e.g., FASEA standards and later professional standards reforms), since this guide reflects a 2012 position and may have been superseded by newer licensing and education requirements for financial advisers.

Recommended actions include: (1) auditing current adviser training records against RG 146's knowledge/skill matrix; (2) confirming continuing training policies and procedures are documented per RG 146.14; (3) ensuring customer service representative scripts and supervision arrangements meet the carve-out conditions in RG 146.22–146.25; and (4) cross-referencing this guide against more recent ASIC and professional standards body requirements to avoid relying on outdated training benchmarks. Failure to maintain adequate training records exposes licensees to enforcement risk, AFS license conditions breaches, and potential consumer harm claims from inadequately trained advisers.

Source: Australian Securities and Investments Commission