Six months on from the adviser education deadline, the regulator has announced the results of its review into qualification compliance across the register which led to intervention actions across 82 AFSLs. 

As of 1 January 2026, financial advisers were required to either meet a higher education standard if they didn’t qualify for the experience pathway (EP) exemption in order to continue practicing. 

The EP required advisers to have at least 10 years’ experience between 2007 and 2021, have a clean disciplinary record as of 31 December 2021, and have passed the financial adviser exam by 1 January 2022 – or 1 October 2022 if they were eligible for the exam extension – to be eligible for this option. 

For advisers who didn’t meet either of these pathways on 1 January were required to cease operating, leave the Financial Adviser Register (FAR), and complete the necessary study prior to rejoining. During this time, they were unable to provide financial advice, and doing so would be illegal. 

The overall impact of this event was unclear for some time after the deadline, however, as AFSLs have up to 30 days to update a relevant provider’s (RP’s) status on the FAR. 

Evaluating this in March, Padua Wealth Data noted that there were potentially 180 ARs still on the register who appeared not to meet the new standards, meaning these advisers may have been providing advice unlawfully. 

Speaking with Money Management at the time, an ASIC spokesperson said it had already begun assessing the situation. 

“We have commenced a compliance program, relying on Financial Advisers Register records, to identify relevant providers who remain authorised to provide personal advice to retail clients on relevant financial products, where they have not met the qualifications standard,” they said. 

In its latest update, ASIC confirmed its findings of a review into FAR records relating to compliance with the new qualification standards. 

“The review identified that of the relevant providers who are ‘existing providers’ and remained on the FAR, 132 individuals did not have any qualifications or training courses marked. Some only marked the exam administered by the former Financial Adviser Standards and Ethics Authority (FASEA) as going toward meeting the qualifications standard.” 

Since commencing the review in late February, ASIC said it had conducted intervention actions with the 82 AFSLs representing the 132 advisers. 

Breaking it down, the regulator explained that: 

  • 106 RPs records on the FAR have been updated to reflect that they meet the qualification standard, and 
  • 26 RPs have had their authorisation to give personal advice to retail clients on relevant financial products ceased. 

This isn’t the end of the matter, however, as ASIC has warned that it may yet undertake a further review looking at the details of the qualifications and training courses that AFSLs have marked on the FAR as going towards advisers meeting the higher qualification standards. 

“AFS licensees and relevant providers should review the information recorded on the FAR and ensure it accurately reflects how each relevant provider meets the qualifications standard.” 

 In particular, it said AFSLs and RPs should: 

  • Check that the financial adviser exam, also referred to as the FASEA exam, has not been incorrectly marked as going toward meeting the qualifications standard, 
  • Check all qualifications or training courses that go toward the relevant provider meeting the qualifications standard have been marked as such (i.e. marking only an ethics course is insufficient), and 
  • Ensuring the relevant provider is eligible to rely on the experienced provider pathway before lodging an experienced provider notification with ASIC. 

In a final word of warning, ASIC said: “It is a serious offence to knowingly provide false or misleading information to ASIC, or to fail to take reasonable steps to ensure that information provided to ASIC is true and correct.”