Licensing Guide · Updated 18 May 2026
The two routes to writing loans legally in Australia: hold your own Australian Credit Licence (ACL), or operate as an authorised credit representative under another entity's ACL. This guide compares costs, compliance overhead, lender access, PII, AFCA, and switching aggregators in plain English.
At a glance
The ten dimensions that matter most when choosing between holding your own ACL or operating as a credit representative under an aggregator's ACL.
| Dimension | Own ACL | Credit Representative |
|---|---|---|
| Who applies | You apply directly to ASIC under RG 204. | Aggregator nominates you on the ASIC credit rep register. |
| Setup time | 4–6 months for ASIC approval (longer if RM thin). | 2–6 weeks (paperwork + aggregator onboarding). |
| Setup cost | $2,500–$8,000+ (application fee, legal, RM, compliance manuals). | $0–$2,500 in aggregator onboarding fees. |
| Annual compliance overhead | Full responsibility — RM, audits, ASIC annual statement, breach reporting. | Aggregator handles ACL-level compliance; you maintain client files. |
| PII | Your own policy. $1,500–$5,000/year typical for solo broker. | Usually included under aggregator's group policy. |
| AFCA membership | Required. Apply directly, pay annual fee. | Covered under aggregator's AFCA membership. |
| Responsible Manager | Must nominate a qualifying RM (you, if eligible). | Aggregator's RM covers all credit reps. |
| Commission control | 100% of commission paid by lender, less aggregator service fee. | Commission paid via aggregator, with split (typically 85–95% to you). |
| Switching aggregators | Simple — change aggregator agreement, retain ACL. | Re-authorisation required. CR number changes; clients should be re-disclosed. |
| Lender accreditation | Direct relationship with lenders (or via aggregator panel). | Via aggregator's lender panel. |
Pros
Cons
Pros
Cons
The default pathway
Around 90% of new brokers operate under their aggregator's ACL. Here's how the arrangement is structured and what each party is responsible for.
Your aggregator holds the ACL with ASIC. You're authorised on their licence as a credit representative (CR). Every credit-assistance interaction — fact-find, recommendation, lodgement — is captured under the aggregator's compliance framework. The CR number on the ASIC register links you to the aggregator's licence number.
Maintains the ACL, employs the Responsible Manager, runs annual compliance audits of credit reps, owns lender accreditations, manages AFCA membership, holds the group PII policy, lodges ASIC annual statements, and handles ASIC breach reporting where the breach is at the licence level.
Hold your own client files, document Best Interests Duty (BID) evidence per file, complete CPD, maintain industry-body (MFAA/FBAA) membership, keep your CR-level details current with ASIC, and report file-level breaches up the chain to your aggregator compliance team within agreed timelines.
Compliance is the most complex part of mortgage broking, and it's not the highest-leverage use of a new broker's time. Operating under the aggregator's ACL trades a slice of commission for compliance scaffolding — fair value for the first 2–5 years until you've built a book that justifies the fixed costs of your own ACL.
If you want your own ACL
Six steps from decision to licence. Realistic timeline: 4–6 months for ASIC processing, with a further 2–3 months of preparation before lodgement.
Decide what scope of credit activities you'll undertake — credit assistance (the standard broker scope), or also act as a credit provider. Most brokers stay credit-assistance-only. Authorisation scope dictates capital adequacy and RM requirements.
The RM must demonstrate at least 2 years' relevant problem-free experience in credit activities, plus a qualification at Cert IV or higher in finance/mortgage broking. The RM is the named person ASIC holds accountable for licence-level conduct.
Compliance manual, complaints policy, breach reporting register, RM oversight plan, training plan, conflicts of interest register, and supervision/monitoring framework. ASIC reviews all of these as part of RG 204.
Professional Indemnity Insurance meeting RG 210 minimums (typically $2m / $2m floor, often higher in practice), AFCA membership prior to commencement, and any other industry body memberships.
Show the licensee has sufficient financial resources to operate. For credit-assistance-only ACLs this is generally cash flow + working capital evidence rather than a strict regulatory capital floor.
Application via ASIC Connect with supporting documents. Fees vary; processing typically 4–6 months. ASIC will revert with additional information requests — be prompt or the application stalls.
How aggregator transitions differ depending on whether you hold your own ACL.
Far simpler. You sign a new aggregator agreement, the lender panel access transitions, your commissions reroute. Clients don't need to be re-authorised because your ACL is the authority. The change is largely commercial — pricing, panel access, software stack — not regulatory.
More involved. Old aggregator removes your CR authorisation; new aggregator authorises you under their ACL. ASIC register updates (new CR number). Existing client trail commissions may or may not transfer (depends on aggregator agreement). Active applications often need to be relodged. Plan a 30–90 day transition during which you can't write new business.
Most successful brokers start as credit reps and consider their own ACL once they hit $30m+ in annual settlements. The aggregator's compliance scaffolding is genuinely valuable in years 1–3; the fixed costs of your own ACL only amortise at scale.
A 95/5 split with a small aggregator with weak tooling will cost you more in lost productivity than the extra 5% pays for. Lender panel depth, CRM, BDM access, and compliance support each matter more than the headline split for the first 5 years.
Aggregator agreements vary widely on whether trail commission continues after you leave. Some pay trail for 12 months post-departure; some clawback aggressively; a small minority pay perpetual trail on your existing book. Negotiate this on the way in, not the way out.
Whether you hold your own ACL or operate under another, thin Best Interests Duty files, weak ID verification, or missing fact-find notes will surface in an audit and put your authorisation at risk. The aggregator's compliance team is on your side — use them.
No. Around 90% of mortgage brokers in Australia operate as authorised credit representatives under their aggregator's ACL, not under their own. ASIC permits both pathways. The choice depends on your scale, business model, and appetite for compliance overhead.
Typically when you're writing $30 million+ per year, have 5+ years of broking experience, and want strategic flexibility (changing aggregators, direct lender deals, brand independence). At that scale the fixed compliance costs of your own ACL ($15,000–$30,000/year all-in) amortise against commission income. New brokers almost always start as credit reps.
An RM is the named individual ASIC holds accountable for the conduct of a credit licensee. They must hold a Cert IV or higher qualification in finance/mortgage broking and demonstrate at least 2 years of relevant, problem-free experience. The RM is required under ASIC RG 204; without one, you can't hold an ACL.
You're covered under your aggregator's AFCA membership — you don't sign up separately. If you hold your own ACL you must apply for and pay AFCA membership directly before commencement. AFCA is the external dispute resolution body for all credit-assistance providers and is non-negotiable.
All credit reps under that ACL lose their authorisation immediately. You'd need to be re-authorised under another aggregator's ACL (or apply for your own) before writing further loans. This is rare — ACL cancellations of major aggregators are extraordinary events — but it's a risk credit reps wear that ACL holders don't.
Own ACL: lender pays your ACL entity directly (or via aggregator's clearing house with a service fee deducted). Credit rep: lender pays the aggregator's ACL, who then pays you per the commission-split agreement (typically 85–95% upfront and trail). Either way, AFCA-compliant remuneration disclosure is required.
OneBookPlus is the all-in-one client + pipeline platform for Australian mortgage brokers — fact-find, BID evidence, document storage, and review nudges. Works whether you're a credit rep or hold your own ACL.
Last reviewed and updated: by Bishal Shrestha
About the author
Founder & CEO, OneBookPlus
Bishal has over a decade of experience in digital marketing, web development, and small business consulting across Australia. He has advised brokers weighing their own ASIC ACL under RG 204 against the faster credit-rep route under an aggregator's licence.
More in this guide
8-step founder guide — ACL/credit rep, MFAA/FBAA, aggregator, PII, software stack, first clients.
Read →ComplianceReg 28HA Best Interests Duty, suitability assessment under s 128 NCCP, conflict-priority rule.
Read →ReferenceMFAA Code of Practice vs FBAA Code of Conduct, member benefits, professional development, fees.
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