Australian Credit Licence: ACL or ACR?

An Australian credit licence (ACL) lets you run credit activities under your own licence. An authorised credit representative (ACR) works within another licensee’s written authorisation.

Choose the representative route if you want a licensee to supervise your work. Apply for your own ACL when your brokerage can fund and manage the licensing obligations itself. Either way, you need legal authority before providing regulated credit assistance.

Choose the Right Licensing Route

Mortgage brokers generally need an ACL or permission to act for a credit licensee when assisting consumers with regulated loans. The Australian Securities and Investments Commission (ASIC) explains the boundary in RG 203: Do I need a credit licence?

The test concerns what you do and which credit contracts you handle. Suggesting a particular regulated loan or helping a consumer apply can be credit activity. A business name, qualification or lender accreditation alone does not authorise it.

Decision	Your Own ACL	Credit Representative
Authority	ASIC grants your entity a licence with specified authorisations.	A licensee authorises specified activities on its behalf.
Supervision	Your business runs its compliance and supervision arrangements.	The appointing licensee monitors your work.
Operating limits	Your licence conditions and applicable law set the limits.	Your written appointment and the licensee’s licence set the limits.
Fit	You can resource the compliance function and want to control it.	You want to work within an established licensee’s framework.

Employees and directors can have a different route to acting for their employer licensee without a formal credit representative appointment. Identify the entity and individual doing each activity before choosing the appointment structure.

Become an Authorised Credit Representative

A licensee must appoint you in writing after completing its checks. The authorisation identifies the work you can perform on its behalf. ASIC’s INFO 126: Credit representatives describes the appointment requirements.

1. Give the licensee your identity, qualifications and work history. Expect background and reference checks.
2. Meet its training standards. ASIC requires at least the relevant Certificate IV for third-party home loan credit assistance and 20 hours of continuing professional development each year.
3. Arrange Australian Financial Complaints Authority (AFCA) membership before authorisation. For a corporate representative, its sub-authorised directors and employees do not need separate membership.
4. Retain the written appointment. Confirm the activities it covers and who lodges the ASIC notification.

Your authorisation must fit within the licensee’s licence. It also depends on required AFCA membership continuing. Keep a copy of the appointment beside your onboarding records.

An aggregator agreement arranges commercial access and services. It grants credit authority only where the necessary licensee appointment is also made. Association membership is separate again. The Mortgage & Finance Association of Australia (MFAA) is an industry association, not your licensing authority.

Before signing, request the supervision schedule and fee schedule. Establish who reviews early files, approves advertising and answers compliance questions. Compare the support you will receive with the work you must still do yourself.

Prepare an Australian Credit Licence Application

An ACL application must show that your business can meet its obligations, with competent people and systems that suit its activities. ASIC assesses organisational competence under RG 206: Credit licensing: Competence and training.

A qualification alone does not establish organisational competence. Prepare the responsible managers’ qualifications and relevant experience, plus their roles in managing the proposed credit business.

Use ASIC’s application steps and RG 204: Applying for and varying a credit licence to assemble the application in this order.

1. Set the applicant entity and business model. Describe your services and select the authorisations they require.
2. Collect the supporting records. Prepare the business description, responsible-manager evidence and required criminal history and bankruptcy checks.
3. Document how the business will operate. Allocate compliance duties and prepare your complaints process, supervision procedures and risk controls.
4. Demonstrate adequate resources. Prepare financial forecasts and explain how you will fund staffing, technology and the compliance work.
5. Arrange AFCA membership and professional indemnity insurance. Keep the insurance questionnaire and certificate of currency ready for ASIC’s assessment.
6. Update existing ASIC register details, complete the application and pay the applicable fee. Retain the submission and respond to requests for further information.

ASIC’s application guidance warns that incomplete or incorrect information can cause return, refusal or delay. Reconcile the entity names and supporting records before submitting.

Submitting the application does not authorise credit activity. Before operating under your own ACL, confirm that ASIC has granted it and that its authorisations cover your services.

Budget for Setup and Continuing Obligations

Budget separately for ASIC charges and the cost of operating the business compliantly. A licence application fee buys neither insurance nor ongoing compliance support.

Cost	Own ACL	Representative Route
ASIC application	Fee depends on applicant type and authorisations.	No application for your own ACL.
Insurance	Budget for the policy and its excess.	Establish whether the licensee’s policy covers your entity and work, plus any separate cover required.
Dispute resolution	AFCA membership and the work of handling complaints.	Membership appropriate to the appointment structure and the licensee’s complaint process.
Compliance support	Internal staff time or a quoted external service.	Charges under the licensee agreement, plus your own administration.
Training and systems	Qualifications, continuing training and business systems.	Training and systems required by the licensee.

ASIC’s schedule of credit fees separates licence applications, variations and lodgements. Use the category for your actual entity and authorisation when costing the application.

An annual compliance certificate is due within 45 days after the licensing anniversary. ASIC’s INFO 108: Fees for Australian credit licences and annual compliance certificates states that timely electronic certificates have no lodgement fee. Late or non-electronic lodgements attract charges. Industry funding levies are a separate budget item.

Obtain insurance and compliance-support quotes for your business model. Compare the total annual cost, including staff time, against the representative agreement’s fixed charges and commission deductions.

ASIC’s INFO 132: Details of professional indemnity insurance asks about insured entities and cover for representatives. Establish who is insured and who pays the excess before relying on a group policy.

Assign Responsibility Across the Brokerage

The licensee remains responsible for its licensing obligations under either model. A representative must follow the law and the appointment conditions, so supervision does not remove the broker’s own duties.

ASIC’s RG 205: Credit licensing: General conduct obligations covers adequate resources, dispute resolution and systems for compliance. Turn those obligations into named responsibilities before the first client file.

Task	Own ACL	Credit Representative
File supervision	Appoint a person to run reviews and record the results.	The licensee sets supervision and review requirements.
Records	Your business controls retention and access arrangements.	You keep the required file records and give the licensee access under its procedures.
Incident response	Your licensee business assesses the incident, remediation and any reporting duties.	Notify the licensee promptly and follow its escalation process.
Continuing training	Your business monitors competence and training.	Complete the licensee’s training requirements and keep evidence.

For example, if a file review finds missing client information, preserve the file and record what happened. Under an ACR appointment, escalate it to the licensee. Under your own ACL, your designated compliance person assesses the response and any reporting obligation.

The broader mortgage broker compliance guide covers the ongoing programme. Before choosing an ACL, name who will run that work and fund it. Before accepting an ACR appointment, obtain the written scope and escalation process.