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Training for AFSL holders providing services to Wholesale Clients only

How many Training Hours are required?

ASIC does not specify a minimum number of training hours for Responsible Managers and representatives who work under a wholesale AFSL. It is up to each individual AFSL holder to determine the number of hours each Responsible Manager and representative should complete to ensure compliance with the provisions of the Corporations Act that require an AFSL holder to ensure their representatives (including Responsible Managers) are adequately trained and competent to provide the financial services covered by the AFSL.

When determining the number of hours each Responsible Manager and representative should complete, AFSL holders should take into consideration the particular Responsible Manager and representative’s role and their contact with clients. For example, Responsible Managers and representatives that are involved in the provision of personal advice to clients should complete more training than representatives that are not.

Responsible Managers and representatives should consult their training plans (if applicable) or training policy (or Compliance Officer) to confirm the minimum number of training hours they are required to complete, and also ensure they are recording details of all training hours completed, including the following information as a minimum:

Responsible Managers must be able to demonstrate they have the training or qualifications needed to satisfy the organisational competence requirements outlined in RG105.

What areas of training are required?

All Responsible Managers and representatives must participate in continuing professional development in order to meet the training competency requirements set out in RG 104.

Training must be continuously conducted at an appropriately high level and cover:

  • all broad aspects of the AFSL obligations, such as general compliance, legislative knowledge and regulatory updates;
  • knowledge related to the products and services the AFSL is authorised to provide services in relation to; and
  • knowledge specific to the individual’s role within the organisation.


AFSL holders should also consider developing and implementing training plans for each Responsible Manager and representative to demonstrate how they are adequately trained and competent to provide the financial services covered by the AFSL. Where AFSL holders develop training plans for Responsible Managers and/or representatives, this should be done at least annually for the following twelve (12) month period.

Training plans should address how Responsible Managers and representatives will:

  • maintain and develop knowledge and skills that are appropriate for their responsibilities;
  • update their knowledge and skills, especially in areas where there is continual change (e.g. legislation, regulatory policies and standards, economic and financial developments, new financial products or new market practices); and
  • set objectives to be met, such as the desired changes in knowledge, skills and/or performance at the end of the training year.


Completing ongoing training each year is a simple way for AFSL holders to ensure they are maintaining their organisational competence to provide financial services. Because of the number of hours required to meet the requirements, Responsible Managers and representatives should ensure they are completing training hours continuously throughout the year rather than having to put aside a large allotment of time right before their company deadline.

Senior Management should review the training progress of all representatives as well as themselves to ensure they too are completing the required hours.

For more information on training requirements and how we can assist you, please contact us.

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