Every Step Counts: Your FAR Destination Must Be Reached in 11 Months

While the financial advice profession digests this week's announcement about changes to education requirements for new financial advisers, a more pressing deadline faces thousands of existing advisers. The requirement to update Financial Adviser Register (FAR) records by 31 December 2025 represents a critical compliance obligation that could determine many advisers' ability to continue practising in 2026 and beyond.

A recent analysis by Adviser Ratings of current FAR data reveals a concerning picture of the profession's preparedness for this looming deadline. Of the 15,540 currently registered advisers, only about 22% are definitively positioned to meet the 1 January 2026 requirements through their existing qualifications or new entrant status. Breaking down the numbers provides a clearer picture of the challenge ahead.

Where we are today

Currently, 2,365 advisers hold approved degrees listed in the Corporations (Relevant Providers Degrees, Qualifications and Courses Standard) Determination 2021 legislative instrument, have these recorded on the FAR and, therefore, fully comply with the education and FAR recording requirements. Another 1,085 advisers entered the profession after FASEA implemented the professional standards obligations on 1 January 2019. These new entrants also meet current requirements and have their education recorded on the FAR correctly.

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.

The Experience Pathway

The larger of the two remaining groups are the 7,800 advisers who potentially meet the "education" requirements through the experience pathway. These advisers provided personal advice to retail clients for at least ten years between 1 January 2007 and 31 December 2021. The implementation of the experience pathway (as detailed in ASIC’s INFO Sheet 281) 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.

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.

Currently, the 10-year experience pathway is not visible on the FAR. Advisers are, therefore, unable to check whether their declaration has been correctly lodged (unlike the qualifications framework, which has been integrated into the FAR for the last 5 years). 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.

Relevant or non-relevant degree pathways

The last group comprises approximately 4,100 advisers with six to twelve years of experience. Critically, the professionals in this group did not qualify for the experience pathway and were not new entrants after 2019. Therefore, advisers in this group must complete their education requirements and have them recorded on the FAR by the deadline. Time is rapidly running out for these advisers to meet the necessary education requirements. As highlighted above, it is equally essential to ensure the FAR has been updated correctly with the education that ensures they meet the standards.

The Consequences

The consequences of missing the 31 December deadline are severe and could be career-altering for many advisers. For any of the nearly 12,000 advisers who fail to complete the education requirements in time or have their FAR records updated correctly, 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. For some, paying for an incorrect (or missed) notification to ASIC would be a heavy price.

The Ministers Parting Declaration

Returning to this week's ministerial announcement about streamlining education pathways for new entrants, it is worth noting that this has created some confusion in the profession. Understanding that these proposed changes do not impact existing advisers' obligations to meet the 31 December 2025 deadline is crucial. The new standards, which include accepting any related field bachelor's degree and completing specific financial advice subjects, will only apply to new entrants to the profession (noting those who miss the 31 December 2025 deadline would also fall into this category).

The pathway remains unchanged for existing advisers, particularly those in the critical 6-12 years' experience group. They must either complete the current education requirements or risk losing their ability to practice. The proposed reforms, while promising for the future of the profession, do not provide any relief from the immediate obligation to update FAR records by year's end (assuming that the required education has been completed).

The Dual Purpose of the FAR

Maintaining accurate FAR records extends beyond individual adviser compliance. The register serves as the profession's primary regulatory tool for ensuring adviser competency and protecting consumer interests. Inaccurate or incomplete records not only jeopardise individual advisers' ability to practice but also undermine the profession's broader efforts to maintain high standards and public trust. While licensees hold the access keys to updating the FAR, as a professional financial adviser, it is your record they are updating. Therefore, your role in this process is crucial and should not be taken lightly.

For self-licensed advisers, the responsibility for updating FAR records falls directly on their shoulders. These professionals must take immediate action to ensure their records accurately reflect their qualifications or experience. For advisers operating under a licensee, the licensee may handle the administrative process of updating FAR records. However, the ultimate responsibility for ensuring accuracy and compliance rests with the individual adviser as part of their professional responsibilities. Advisers should proactively communicate with their licensees about the process and ensure that all necessary steps are taken to update their records.

The Final Countdown

Time is now the critical factor. With less than eleven months remaining until the deadline, advisers who still need to complete education requirements face a particularly pressing challenge. Completing qualifications, having them recognised, and updating FAR records can be lengthy; delays in beginning this process could prove costly.

Advisers should:

1. Verify their current FAR status immediately.
2. Contact their licensee about updating FAR information, or if self-licensed, prepare to update records directly.
3. For those meeting the experience pathway, ensure all necessary documentation has been provided to your licensee or is ready for submission.
4. For those needing to complete education requirements, commence your studies without delay.

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 alternative - losing the ability to practice and facing a lengthy re-qualification process - is a scenario no adviser can afford to risk.

Article by:

Adviser Ratings

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