Advice File Reviews and Pre-Vetting: What a Licensee Checks and Why (2026)

By Anthony Zaman, Director and Responsible Manager, Core Advice Collective. Reviewed by Anthony Zaman. Last reviewed 29 October 2026.

Advice file reviews are checks a licensee runs on its advisers’ client files to test whether personal advice met the law: the best interests duty, appropriate advice, conflicts priority, Statement of Advice content and record keeping. Pre-vetting applies the same checks before the advice is given, so problems are fixed before the client acts.

This guide explains why licensees review advice, what a file review checks, how pre-vetting differs from a post-advice audit, and what advisers can do to make reviews faster. Every regulatory fact is dated and linked to the ASIC or legislation page it comes from.

Why do licensees review advice files?

Because the law makes the licensee responsible for its representatives. Under s912A(1)(ca), a licensee must “take reasonable steps to ensure that your representatives comply with the financial services laws”, and ASIC says that to do this “you need to monitor and supervise them” (ASIC RG 104, issued June 2022, updated March 2026).

ASIC does not expect a licensee to scrutinise every activity of its representatives. It does expect a robust way to remedy breaches and appropriate background checks before new representatives are appointed (RG 104). For financial advisers, those checks include a reference under the reference checking protocol. For personal advice, s961L adds a specific obligation: a licensee must take reasonable steps to ensure its representatives comply with the best interests obligations (ASIC RG 175, November 2024).

ASIC’s report on how large institutions oversee their advisers, REP 515, includes checklists for background checking advisers and for reviewing personal advice as part of an adviser audit (ASIC REP 515, March 2017). It remains a useful reference point for how ASIC thinks about advice monitoring.

What does an advice file review check?

A file review tests the advice against the obligations in Part 7.7A of the Corporations Act and the disclosure rules in Part 7.7, as summarised by ASIC in RG 175.

Obligation	What the reviewer looks for
Best interests duty (s961B)	The client’s objectives, needs and circumstances were identified, and reasonable inquiries were made where information was incomplete
Appropriate advice (s961G)	It is reasonable to conclude the advice is appropriate for the client, and the reasons are recorded
Conflicts priority (s961J)	Where there was a conflict, the client’s interests were put first
Statement of Advice content (RG 175)	The advice and its basis, remuneration and benefits, interests and associations, and any warning about incomplete information
Product replacement (s947D)	The cost of switching, benefits lost and other significant consequences are disclosed
Record keeping (s912G)	The file shows the information relied on and why the advice was appropriate

Table based on ASIC RG 175 (November 2024) and ASIC Instrument 2024/508 (record keeping for personal advice). Checked 29 October 2026.

What records must an advice file keep?

ASIC Instrument 2024/508 inserts a modified s912G. For personal advice to retail clients, the licensee must keep records of the information relied on and the actions taken to meet the best interests duty, the advice and why it was reasonable to conclude it was appropriate, and, where there was a conflict, how the client’s interests were given priority. The records must be kept “for 7 years after the day the personal advice was provided to the client” (ASIC Instrument 2024/508, registered 24 September 2024). The instrument is stated to be repealed at the start of 1 October 2029.

What is pre-vetting, and how is it different from a file review?

A post-advice file review, or audit, looks at advice that has already been given. If it finds a problem, the licensee has to work out whether the client was affected and whether remediation or a report to ASIC is needed.

Pre-vetting applies the same checks before the Statement of Advice goes to the client. We could not find an ASIC requirement to pre-vet every piece of advice, so it is a licensee practice rather than a legal obligation. Its value is timing: gaps in inquiries, appropriateness reasoning or switching disclosure are fixed while the advice can still be changed.

At Core Advice Collective, advice is pre-vetted before delivery, with file reviews within hours and peer review included. The aim is for review to support the adviser’s client timeline rather than hold it up.

What does ASIC’s 2026 enforcement show reviews should catch?

ASIC’s September 2026 financial advice update (9 September 2026) summarised several outcomes that line up with what a file review is meant to test:

• On 10 June 2026 the Financial Services and Credit Panel gave a written direction requiring specified supervision for an adviser who had not made reasonable inquiries about a client’s pre-existing medical condition or adequately investigated replacement insurance.
• On 18 March 2026 a reprimand covered breaches of ss961B(1), 961G and 947D.
• On 4 March 2026 a registration prohibition included a failure to provide required Statements of Advice.
• In June 2026 ASIC cancelled the licences of Freedom Wealth Services. The update records conduct by an individual that included creating file notes that did not accurately reflect client interactions.

The same update said licensees “should also supervise advice quality, identify deficiencies and remediate affected clients”, and that records “should clearly show the inquiries made, information relied on and reasons why the advice is appropriate”. It also asked licensees to give specific consideration to supervising authorised representatives who have moved from licensees with known compliance concerns, which is relevant if you are changing licensee.

Is the Statement of Advice changing?

Not yet. The second tranche of Treasury’s Delivering Better Financial Outcomes reforms proposes to replace the Statement of Advice with a “client advice record”. Treasury consulted on the exposure draft from 20 March to 2 May 2025. As at 29 October 2026 we could not find an official confirmation that this change has become law, so the current SOA requirements in RG 175 continue to apply.

How can advisers make file reviews faster?

• Record the inquiries, not just the answers. Note what you asked when information was missing and what the client said.
• Write the appropriateness reasons in the file. Explain why each recommendation suits the client’s objectives and circumstances.
• Show the comparison for any switch. Costs, benefits lost and other significant consequences should be in the file and the SOA.
• Keep file notes contemporaneous and accurate. Notes should match what happened with the client.
• Flag conflicts early. If there is a conflict, record how the client’s interests were put first.

Frequently asked questions