RG 234 is the Australian Securities and Investments Commission (ASIC) guide to advertising financial products and credit without misleading consumers. For mortgage brokers, the test is the impression the whole ad creates, including its headline and any qualifications.
A small disclaimer cannot repair a headline that promises something the brokerage cannot deliver. Apply the same review to a social post, landing page or testimonial before your licensee approves it.
What RG 234 Asks of Credit Ads
RG 234 explains how ASIC applies the bans on false or misleading statements and misleading or deceptive conduct to advertising. The guide helps advertisers apply the law. It does not replace the ASIC Act or credit legislation.
The 2026 RG 234 guide replaces the 2012 edition. It expressly includes intermediaries such as lead generators and advertising made with artificial intelligence (AI). It also addresses social media and sponsored content.
Brokers, aggregators and people advertising credit for them must assess the message consumers actually receive. Ask whether the ad promises access to lenders, approval or savings beyond what the business can substantiate. Review the image and spoken claims as well as the text.
For example, a headline promising approval to every applicant conflicts with a footnote saying approval depends on lender assessment. Remove the promise. Put any material eligibility condition where the reader encounters the offer.
Rate Claims and the Comparison Rate
An advertisement containing an annual percentage rate for a regulated home loan must also contain the relevant comparison rate. National Credit Code sections 160 to 164 set the requirements.
Identify it as a comparison rate and make it at least as prominent as the advertised interest rate or repayment amount. State the product name, example loan amount and term. The comparison-rate rules have exclusions, including continuing credit contracts, so a home-loan template does not automatically suit every credit product.
The comparison rate must carry the prescribed warning. Use the exact short or long statement in regulation 99, copied from your approved advertising template. The warning explains that the comparison applies to the stated example and that different amounts, terms or excluded costs can change the result.
For electronic ads, section 164 also controls how spoken rates and displayed rates are matched. A rate shown on screen needs its comparison rate on screen. Give the warning and calculation basis in the required spoken or displayed form.
Use these checks when drafting the offer:
- For an introductory rate, state the discounted period prominently and explain the rate or fees that apply afterwards.
- For a conditional rate, show the conditions that decide eligibility, such as loan purpose, repayment type or loan-to-value ratio (LVR).
- For a “from” rate, explain who can obtain it. A low rate available to a narrow group must not look available to the whole audience.
- For a lowest-rate claim, identify the comparison set and retain evidence. Comparing your panel does not prove a claim about the whole market.
- For a fixed savings claim, retain the calculation and disclose its assumptions, including fees and the comparison period. One client’s saving does not establish everyone’s saving.
Avoid guaranteed-approval claims when the lender still assesses the application. Evidence of a low rate across your panel cannot substantiate an unconditional approval promise.
Assign someone to review each active rate ad when the lender changes its source rate or conditions. Pause or replace affected creative, including scheduled posts and partner copies, before it continues circulating with an outdated offer.
Lead Generators, Paid Social and AI-Written Ads
A broker must review the advertising a lead generator runs for the brokerage, including the lead form and the page that collects contact details. Outsourcing the campaign does not remove the broker’s responsibility for claims made on its behalf.
Require access to the actual creative and all variants. A form labelled as an eligibility check must not imply that the consumer has lender approval. Make the business receiving the enquiry clear and remove unsupported claims about government backing or market-wide comparisons.
RG 234 expressly applies regardless of whether AI produced the advertising. Its warning about hallucinated or biased content means a plausible draft still needs human checking. Match every rate and claim to its source, check the qualifications and retain the approved version. Apply that process to AI-generated images and voiceovers too.
For campaign mechanics, use the separate guide to Facebook ads for mortgage brokers. For direct follow-up messages, apply the Spam Act rules for brokers as well.
Testimonials and Client Reviews in Ads
Use a testimonial only when it reflects a genuine client experience and remains accurate for the service you advertise. Obtain written permission for the words, name and any image you intend to publish.
Keep the original review and consent with the approved ad. Present outcomes fairly: an unusually large saving must not imply that the typical client receives it. Remove or update an endorsement when changed circumstances make it misleading.
The Australian Competition and Consumer Commission (ACCC) review guidance rejects fake or misleading reviews. Its guidance also addresses undisclosed incentives and review selection that distorts consumer opinion. For credit advertising, apply ASIC’s financial-services rules alongside the relevant consumer-law and platform requirements.
Google’s Maps review policy prohibits incentives for reviews, even when the reward does not depend on a positive rating. It also prohibits selectively asking satisfied customers for public reviews. Disclosure of an incentive does not make that practice acceptable on Google.
A review being publicly visible does not give your brokerage permission to reuse the client’s photo in an ad. The guide to filming mortgage client testimonials covers the filming and consent process.
Influencer and Referrer Content
Treat paid or gifted creator content promoting your brokerage as credit advertising and submit it through your licensee’s approval process. Require an immediately obvious disclosure of the payment or gift.
The ACCC’s influencer guidance warns against hidden sponsorship and vague disclosure labels. A creator’s personal tone does not justify a claim your brokerage could not make itself.
Apply the same review when a real estate agent promotes your service in a post or a financial planner recommends it in a newsletter. Give the referrer approved wording, require approval before publication and monitor the published result. An edited caption can change the claim after sign-off.
Use the mortgage broker influencer marketing guide for choosing creators and organising the campaign.
Calling Your Business Independent
A commission-paid brokerage generally cannot describe its credit service as independent, impartial or unbiased. Section 160B of the National Consumer Credit Protection Act 2009 restricts those words and terms with similar meaning.
The defence requires all relevant conditions to hold. Indirect remuneration must be fully rebated to clients. The licensee must also be free of gifts or benefits from credit providers or lessors that could reasonably influence it. It also requires freedom from relevant restrictions and conflicts, with conditions extending to the licensee’s employer and prescribed persons.
Being privately owned or having a broad lender panel does not satisfy those conditions by itself. Apply the restriction to business names, taglines and profile bios as well as individual ads.
If accurate, describe the business as broker-owned or locally owned. Those statements describe ownership without promising independence from remuneration or lender relationships. The independent mortgage broker guide explains that distinction further.
What Every Broker Ad Must Show
Use your licensee’s approved identification block on every ad. Include the licensee’s name and Australian credit licence (ACL) number, plus your credit representative number where your appointment and licensee policy require it.
Distinguish that practical policy from the specific statutory rule. Section 52 requires a licensee identifying itself in prescribed documents to include and identify its ACL number. Regulation 13 expressly covers printed advertisements about regulated credit. It does not create a blanket requirement for a credit representative number on every ad in every medium.
For digital and audio formats, follow the identification wording your licensee approves and make the provider clear. Do not imply that the broker personally holds the licensee’s ACL. Where an ad contains a rate, add the comparison-rate disclosures that apply to that offer.
A landing-page link to your credit guide gives visitors access to your details and disclosures. It does not replace giving the credit guide when the credit legislation requires it, including at the relevant stage of providing credit assistance.
Approving Ads Through Your Licensee
Submit the complete advertising journey to your licensee for approval before it runs. A compliant landing page cannot repair a misleading ad that sends people there.
- Submit the creative and every format variant with the landing page and lead form. Include scripts for audio, video and partner posts.
- Attach the source material for rates, savings calculations and other factual claims. Include testimonial permissions and sponsorship disclosures where used.
- Record the approved version, approver and approval date. Keep each version and its supporting evidence for the licensee’s record period.
- Check the published ad against the approved copy, then monitor rate changes and partner edits. Send changed claims through approval again.
ASIC’s enforcement examples show why both the headline and the omitted conditions need review. In 2026, Fundo Loans paid a $19,800 infringement notice over an allegedly misleading no-credit-check claim. ASIC alleged Fundo required consent to checks and checked some applications. Payment was not an admission of liability.
In another 2026 action, the court ordered Harvey Norman to pay $35 million and Latitude to pay $20 million. Their interest-free advertising failed to adequately disclose the credit card requirement and fees.
Before approving your next ad, read it once without its footnotes. If that reading promises more than the supported offer, change the main claim before seeking sign-off.
