LicenseCompare

Australian Securities and Investments Commission

Australia custody/client assets licensing requirements

Safekeeping, client money, custody control, qualified custodian, safeguarding, asset segregation, and client asset operational models. This page maps the issue to Australia application evidence, individual roles, corporate controls, public registers, and official sources.

Who this page is for

  • - Custodians
  • - Managers with custody risk
  • - Platforms handling client money
  • - Brokers and fund operators
  • - Investment managers and managed account providers
  • - Financial product advisers

Likely route questions

  • - AFSL custody, depository, client money, and responsible entity analysis

Activity trigger map

  • - Can the firm move, instruct, deduct from, or otherwise control client assets?
  • - Are client assets held directly, by a custodian, by a fund vehicle, or through a platform?
  • - What audit, segregation, disclosure, capital, and reporting controls are needed?
  • - Which entity will hold, safeguard, control, or arrange custody of client assets?
  • - How will professional, accredited, institutional, or wholesale client status be evidenced and monitored?
  • - Which domestic permissions, representative approvals, and ongoing obligations apply before launch?

Individual requirements

  • - Responsible managers with appropriate competence and organisational capacity
  • - Authorised representatives where services are provided under another licensee
  • - Relevant provider registration on the Financial Advisers Register for personal advice to retail clients
  • - Training, competence, fit and proper, conflicts, and supervision controls

Corporate requirements

  • - AFSL authorisation by service and financial product type
  • - Financial resources, compliance arrangements, dispute resolution, insurance, training, and risk management
  • - Responsible manager proofs and business description matched to requested authorisations
  • - Retail or wholesale client controls and disclosure arrangements

People and key-person expectations

  • - Responsible managers with appropriate competence and organisational capacity
  • - Authorised representatives where services are provided under another licensee
  • - Relevant provider registration on the Financial Advisers Register for personal advice to retail clients
  • - Named owners should be able to explain the activity workflow, client type, controls, and evidence pack.

Documents and evidence checklist

  • - Custody and client assets
  • - Capital and financial resources
  • - Compliance framework
  • - Outsourcing and vendors
  • - Regulatory reporting
  • - Official-source route memo
  • - Public register verification plan
  • - Questions log for qualified advisers

Capital, timeline and bottlenecks

Financial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations.

Timeline estimate: Often 4 to 8+ months depending on authorisations and proof quality.

  • - Requested authorisations are broader than the actual operating plan can support
  • - Responsible manager evidence is thin or not matched to all authorisations
  • - Retail client disclosure, dispute resolution, and advice controls are incomplete
  • - The firm treats wholesale-only plans as low risk without documenting client classification and distribution controls

Common mistakes

  • - Saying the firm does not hold assets while retaining practical control over movements.
  • - Not documenting qualified custodian, CASS, client money, or safeguarding assumptions.
  • - Authorised representative status is not the same as holding your own AFSL.
  • - Retail advice introduces additional adviser registration and conduct questions.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.