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AFS SoA and training requirements

Once licenced, accountants will need to comply with the AFS SoA and training requirements on an ongoing basis. With the current focus on getting licensed before the end of the transition period, these obligations haven’t received much attention. This blog explores these post-licensing obligations.


Statements of Advice have a bad reputation as an onerous and time-consuming obligation. While this may be true for financial planners, the picture should be very different for accountants.

SoAs are only required for financial product advice that’s tailored to clients’ needs and circumstances. For financial planners this is a daily activity, but for many accountants – other than SMSF specialists – it will only be required when:

  • recommending a client establish an SMSF;
  • advising the client about the ongoing suitability of their SMSF, i.e. every 1-2 years , or
  • providing tailored strategic advice about financial products e.g. a shares, life insurance etc.

For many accountants, this is not their core business of accountants, so unless you’re an SMSF specialist, it’s likely that you’ll only need to prepare SoAs occasionally.

Financial planning SoAs are typically lengthy and complex, but too often they contain superfluous or irrelevant information. Don’t fall into this trap! Given the limited extent of the advice accountants will provide, your SoAs can and should be short and concise.


There seems to be a similar misconception about the extent of the ongoing AFS training accountants will need. But accountants advising on financial products only need to be ‘adequately trained’ to provide the financial services for which they are authorised.

As accountants can only provide detailed advice on SMSFs and ‘class of product’ advice on products, they should only require:

  • Sufficient training on the purpose, use and structure of SMSFs to be able to appropriately recommend their use;
  • a general level of knowledge on the financial products on which ‘class of product’ advice is provided: and
  • periodic compliance training to ‘refresh’ your knowledge of the compliance requirements or on any changes.

It seems likely that this will only comprise a small part of most accountants’ annual training.

The Fold offers a range of AFS licensing services to accountants – from full service to DIY. Click here for more information.

If you have any concerns about any of these issues, please contact us.

Author: Jaime Lumsden

Related Blogs: Accountant’s Licensing – A Guide to Help You Choose, Limited Licence: Apply Early

June 2015

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