Changing Licensee as a Financial Adviser: A 2026 Step-by-Step Checklist

By Anthony Zaman, Director and Responsible Manager, Core Advice Collective. Reviewed by Anthony Zaman. Last reviewed 27 October 2026.

Changing licensee as a financial adviser means your new licensee obtains a reference under ASIC’s protocol, authorises you in writing, notifies ASIC within 30 business days and registers you before you advise. Your old registration ends when your old licensee ceases your authorisation, so the order and timing of each step matter.

This checklist is for advisers and practice owners who provide personal advice to retail clients and are moving from one licensee to another. It sets out each step in order, who is responsible, and the client arrangements to plan for. Every regulatory fact is dated and linked to the ASIC page it comes from, checked on 27 October 2026. If your practice operates through a company, our guide to the corporate authorised representative structure explains how the company and its advisers are authorised.

Changing licensee as a financial adviser: the steps in order

The safest way to change licensee is to work through the steps below in sequence and agree the dates with both licensees before you resign. The main risk is a gap: a period where your old authorisation has ended but your new registration is not yet in place.

Step	What happens	Who does it	Timing (ASIC)
1. Choose and agree terms	Due diligence on the new licensee, its authorisations, policies and support; agree the commercial terms in writing	You and the new licensee	Before you resign
2. Consent to a reference	You give written consent for the new licensee to request references	You	Consent ceases 12 months after it is given unless withdrawn earlier
3. Reference check	The new licensee requests references from the relevant current and former licensees using the ASIC protocol	New licensee (recruiting licensee)	Referee responds within 10 business days, or up to 30 business days if both agree
4. Old authorisation ceases	Your old licensee ceases your authorisation and notifies ASIC; your registration ceases at the same time	Old licensee	ASIC notified within 30 business days of the cessation
5. New authorisation	The new licensee authorises you by written notice and appoints you on the Financial Advisers Register	New licensee	ASIC notified within 30 business days of the authorisation
6. Registration	The new licensee applies to register you through ASIC Connect	New licensee	Before you give personal advice; takes effect when ASIC records it on the register
7. Client transition	New Financial Services Guide, ongoing fee arrangements, consents and account provider notices	You and the new licensee	Before you provide services to each client under the new licensee

Sources: ASIC reference checking and information sharing protocol (page dated 15 April 2026); ASIC, Appointing and ceasing authorised representatives (7 April 2025); ASIC INFO 276 (2 April 2026). Checked 27 October 2026.

What does the reference check involve when you change licensee?

Your new licensee must take reasonable steps to obtain a reference from a referee licensee before it employs or authorises you. Since 1 March 2025, all references must be requested under the ASIC protocol, which is a licence obligation under section 912A of the Corporations Act. Source: ASIC reference checking and information sharing protocol, page dated 15 April 2026.

Which licensees are asked depends on your history:

• If you are currently employed or authorised, the reference comes from your current licensee or licensees.
• If you have been with your current licensee for less than 12 months, the most recent former licensee in the past five years is also asked.
• If you are not currently employed or authorised, the most recent former licensee in the past five years is asked.

The protocol requires your written consent before a reference is requested, and a referee must not give a reference without a copy of it. The referee must respond in writing within 10 business days unless both licensees agree to a longer period, up to a maximum of 30 business days. References cover conduct up to five years before the reference is given, and licensees have qualified privilege when they share information in accordance with the protocol.

How can you avoid delays at this step?

Sign the consent form promptly, tell your current licensee that a request is coming, and make sure your records of training, CPD and any compliance matters are up to date. A reference request sits with the referee licensee for up to 10 business days, so build that time into your planned start date.

What happens to your registration when you change licensee?

Your registration ends. ASIC states that “a relevant provider’s registration ceases when the registering AFS licensee ceases the relevant provider’s authorisation to provide personal advice (for example, when the relevant provider changes AFS licensees or goes on a career break)”. ASIC will not ordinarily send a notice that registration has ceased. Source: ASIC INFO 276, Registration for relevant providers, 2 April 2026, Q19.

Your new licensee then needs to register you. Applications to register relevant providers are lodged by the licensee through ASIC Connect, and a licensee can only apply to register relevant providers it has appointed and who are recorded on the Financial Advisers Register. Registration takes effect once ASIC records it on the register, which ASIC says generally happens within one business day of an application being approved. Notices of registration or refusal are issued within five business days of the decision. Sources: ASIC INFO 276 (2 April 2026); ASIC, Registering a relevant provider with ASIC (30 July 2026).

Is being “current” on the Financial Advisers Register the same as being registered?

No. ASIC states that a relevant provider “being listed as ‘current’ on the Financial Advisers Register does not mean they are registered”. Check the registration status itself, not just the appointment, before you give personal advice under the new licensee. Our guide on how to become an authorised representative explains the difference between being authorised, appointed and registered.

What if you give advice before you are registered?

The consequences fall on both of you. ASIC says an adviser who provides personal advice while unregistered breaches a restricted civil penalty provision, and the licensee commits an offence of strict liability and contravenes a civil penalty provision. ASIC also states that both the licensee and the relevant provider are responsible for making sure the relevant provider does not advise while unregistered. Sources: ASIC, Registering a relevant provider with ASIC (30 July 2026); ASIC INFO 276 (2 April 2026), Q5.

What notices must the licensees give ASIC?

Both licensees have notification obligations, and both run on a 30 business day clock:

• The new licensee must notify ASIC within 30 business days of the date an authorisation is issued.
• The old licensee must notify ASIC within 30 business days of ceasing an authorisation.
• Licensees must update the Financial Advisers Register within 30 business days when they authorise a relevant provider, when a relevant provider no longer works under their licence, and when a relevant provider’s details change.

Sources: ASIC, Appointing and ceasing authorised representatives (7 April 2025); ASIC, Financial Advisers Register (11 August 2026).

These are the latest dates for notifying ASIC. They are not the time you can wait before registration: registration must be in place before you give personal advice, whatever the notice deadline.

How do you move your clients to the new licensee?

Treat the client transition as its own project. The rules below are the ones ASIC sets out; how they apply to your clients depends on your arrangements with both licensees, so confirm the approach with your new licensee before you contact clients.

Financial Services Guide

The obligation to give a Financial Services Guide applies to AFS licensees and authorised representatives that provide financial services to retail clients, and as a minimum the FSG must be given before a financial service is provided, unless an exemption applies (ASIC INFO 291, 3 December 2025). Agree with your new licensee which FSG you will use from your first day under its licence.

Ongoing fee arrangements and consents

ASIC defines the fee recipient as the licensee or representative that enters into the ongoing fee arrangement or, if the rights have been transferred, the person who now holds them. Where rights under an arrangement are transferred, ASIC says this does not invalidate the client’s written consent if the consent and arrangement remain the same in all other respects, and clients should be notified of the change in fee recipient by both the existing and the new fee recipient. Fees can only be deducted from a client’s account with written consent, and a copy of that consent must be given to the third-party account provider. Source: ASIC INFO 286, FAQs: Ongoing fee arrangements and consents, 6 June 2025, Q1, Q4 and Q9.

ASIC’s FAQs do not set out a specific rule for an adviser changing licensee. Work out with both licensees who the fee recipient is under each arrangement, whether rights will be transferred or new arrangements entered into, and what each account provider needs. Remember the renewal window under the current rules runs from 60 days before to 150 days after the reference day or anniversary, so check where each client sits in that cycle.

Changing licensee checklist

• Confirm the new licensee’s authorisations cover the advice you provide now and plan to provide.
• Agree the commercial terms, support and start date in writing.
• Sign the written consent for the reference request.
• Agree a cessation date with your old licensee and a written authorisation date with your new licensee.
• Confirm the new licensee will lodge your registration and when.
• Check the Financial Advisers Register shows you as registered, not just current, before you give personal advice.
• Prepare the FSG you will give clients under the new licensee.
• Map every ongoing fee arrangement: fee recipient, reference day, consent and account provider.
• Plan client communications, including notice of any change in fee recipient.
• If you are a provisional adviser, remember provisional relevant providers cannot be registered, and agree supervision arrangements with the new licensee.

Common mistakes when changing licensee

• Assuming registration transfers. It ceases when your old authorisation ceases. Your new licensee must register you again.
• Relying on “current” status. Being listed as current on the register does not mean you are registered.
• Treating 30 business days as a grace period. The notice deadline does not permit advice before registration.
• Leaving the reference to the last week. Referee licensees have 10 business days to respond, and up to 30 if both agree.
• Forgetting the account providers. Fees cannot be deducted without the client’s written consent, and the account provider needs a copy.
• Moving to a licensee without checking scope. You can only advise within the new licensee’s authorisations. If you are weighing your own licence instead, see our comparison of AFSL vs authorised representative.

Frequently asked questions