There is less than 11 months left until the transition period for financial advisers to meet the professional standards framework that commenced in 2019.
Key to remaining as a financial adviser after the 1 January 2026 deadline is ensuring that Financial Advisers Register (FAR) records are updated by 31 December 2025.
Adviser Ratings analysis of the FAR has revealed a “concerning picture of the profession’s preparedness” to comply with these requirements, with around 22 per cent of the roughly 15,000 advisers on the register in the clear.
This is made up of 2,365 advisers that hold approved degrees and have them recorded on the FAR and 1,085 advisers who entered the profession after the Financial Adviser Standards and Ethics Authority (FASEA) implemented the professional standards obligations on 1 January 2019.
Both of these categories meet current requirements and have their education recorded on the FAR correctly, Adviser Ratings said.
“This leaves approximately 12,000 advisers who must ensure their FAR records accurately reflect their qualifications or that they meet the 10-year experience pathway by the end of the year. Otherwise, they could lose their existing adviser status, with devastating consequences,” it said.
The experience pathway was passed in September 2023 and allows advisers with at least 10 years of experience during the period from 1 January 2007 to 31 December 2021 to remain in the profession, provided they had a clean disciplinary record as at 31 December 2021.
While many advisers potentially meet these requirements – Adviser Ratings puts the number at 7,800 – their status on the FAR is less clear.
“The implementation of the experience pathway … requires them to declare they have met the 10-year experience requirement to their licensee, who must then validate the declaration and update the adviser’s record on the FAR,” Adviser Ratings said.
“Many had otherwise met the education requirements before the government introduced the new experience education pathway in September 2023. Others will rely on the declaration process ASIC instigated to demonstrate that they had completed 10 years of experience over the 14-year window.
“For the latter group, ensuring that this experience is declared correctly to their licensee and then recorded on the FAR is critical. To this point, simply meeting the experience requirement is not enough – it must be officially documented through an attestation to your licensee, verified by the licensee, and then recorded on the FAR.”
As the experience pathway is not currently visible on the FAR, advisers who are relying on this process are unable to check that it has been correctly lodged.
“It is, therefore, important for existing advisers who made a declaration to check with their licensee that their use of this pathway is correctly recorded where it is being relied upon,” the research firm added.
The other group is the 4,100 existing advisers that do not meet the experience pathway requirements and were not new entrants after 2019.
“Time is rapidly running out for these advisers to meet the necessary education requirements,” Adviser Ratings said.
“As highlighted above, it is equally essential to ensure the FAR has been updated correctly with the education that ensures they meet the standards.”
Adviser Ratings explained that for advisers who fail to meet the requirements before the deadline, their path back gets tougher as they will lose their existing adviser status.
“This loss will result in a cascade of additional requirements before they can resume practice. These advisers would need to demonstrate completion of a full bachelor’s degree (or higher postgraduate qualification) in financial advice (or yet to be finalised) related discipline, either including or separately complete the four newly proposed financial advice subjects, pass the adviser exam (although this should already have been completed for existing advisers) and complete a professional year – all while being unable to practice or generate income from providing financial advice themselves,” the firm said.
Keddie Waller, policy manager at the SMSF Association, added that there is no specified time limit on when the study must be completed and as long as the financial adviser is not authorised on 1 January 2026, “the study can be completed at any time”.
“After 1 January 2026, an existing financial adviser must have completed the required study before they can become authorised again,” Waller said.
However, she cautioned that licensees could set their own education standards, provided it complies with the legislated requirements.
“This could mean, for example, an AFS licensee requires the completion of specific qualifications to be authorised that exceed the legislated requirements or have a time frame in which it will accept the completion of ‘approved qualifications’,” Waller said.
“Post 1 July 2026, it is also likely that approved education providers may wind back or cease offering approved bridging units.”
She added: “For those who will continue to be registered into 2026, time is running out. You need to ensure that you will meet the education requirements as they apply to you. Don’t leave it to the last minute.”
Adviser Ratings shared a similar sentiment, urging advisers to verify their current FAR status immediately.
“The message could not be clearer: regardless of future changes to education standards for new entrants or other reforms like removing SOAs or a new class of advisers, existing advisers must ensure their FAR records are current and accurate by 31 December 2025,” the firm said.
“The alternative – losing the ability to practice and facing a lengthy requalification process – is a scenario no adviser can afford to risk.”