What ASIC told licensees on 9 November 2026
ASIC's message was blunt: using lead generators, or letting them operate inside an advice process, may put an Australian financial services licence at risk. The regulator issued that as a final warning to AFSL holders on 9 November 2026, alongside Report 845, Lead generation advice models: Putting consumers and licensees at risk.
The review behind the report covered 15 AFS licensees and their representatives who had been identified as having links to lead generation activity. It found examples of unlicensed or unqualified lead generators taking part in the advice process. Some licensees allowed them to handle fact-finding, assess clients' risk profiles and discuss advice recommendations.
ASIC also set out the supervision gaps behind those examples: limited access to lead generator call recordings, heavy reliance on manual supervision, insufficient monitoring of product recommendation patterns, and inadequate limits on adviser client volumes.
Commissioner Alan Kirkland said commercial incentives must not come at the expense of consumers, and that licensees must ensure only authorised advisers provide personal advice and that those advisers act in their clients' best interests.
The review in numbers
The figures below cover the 18 months between January 2025 and June 2026.
- 15 AFSL organisations reviewed, together with their representatives.
- About 7,639 new clients obtained through lead generation services, roughly 35% of those licensees' total new clients.
- About $678 million invested by the targets of lead generators after referrals.
- 90.6% of that money related to superannuation funds.
- $9.8 million deducted in upfront fees, plus $4.5 million in annual ongoing fees.
The superannuation skew is the part that matters for anyone weighing income protection. A referral conversation that starts and ends with a fund switch may never price the cover sitting inside the existing fund. ASIC has previously observed switching models that failed to consider insurance held through a client's existing super arrangements, at least initially, so the transaction could move quickly.
Recognising a lead-generation referral
A lead generator is a marketing channel. These are the patterns its reviews describe.
- A review with a foregone conclusion. In the cold-calling super switching models ASIC examined, the review always ended in a recommendation to switch, either to another APRA-regulated fund or to a self-managed super fund.
- Fear about the fund you already hold. ASIC described cold callers making misleading statements about a member's existing fund fees and performance and casting doubt on its ability to fund retirement.
- Comparisons that are not like-for-like. The lead generation review found some lead generators using non-like-for-like performance comparisons to encourage consumers to review or switch their superannuation arrangements.
- Pressure to decide now. ASIC's stated position is that consumers should not feel pressured or be misled when making important financial decisions.
- Someone unauthorised doing the technical work. Fact-finding, risk profiling and discussing recommendations are the tasks ASIC found being handed to lead generators in some cases.
The licence details worth confirming
Two public records sit behind the basic questions. ASIC's professional registers search covers AFS authorised representatives and can be searched by individual or company name, registration or licence number, ACN or ABN; it shows whether a person or organisation is registered or licensed and the services they are licensed to provide. The Authorised Representative Register is a public record of representatives authorised to provide specified financial services on behalf of a licensee, and it shows a representative's status, their associated licensee and whether they can sub-authorise others. Licensees are responsible for adding and updating that information.
Before a first substantive call, the details worth having in front of you are:
- whether the individual is on the Authorised Representative Register and which licensee they are linked to;
- which services that person is authorised to provide;
- who pays the person who contacted you, and how;
The first three are items with a public record behind them. The last two are questions for the firm, and the answers belong in writing before you agree to anything.
What the warning does not change about income protection
Report 845 examined how advice licensees supervise and monitor lead generation in personal financial advice. Its findings, and the licence-risk warning built on them, are about licensing, authorisation and supervision. They do not set income protection definitions, waiting periods, benefit periods or claim assessment. Those come from the policy wording and from the insurer's assessment of a claim.
That distinction matters if you hold cover inside super. Structural questions sit elsewhere. Does the comparison cover cover held inside super against a retail policy? What happens to the cover if the fund changes?
Treat insurance as a separate line of enquiry rather than a by-product of the switch.
The reforms ASIC pointed to, and where they stand
On 19 August 2026 the government announced a package titled Protecting Consumers and the Promise of Superannuation in an Evolving Financial Ecosystem. It is framed around three aims: strengthening protections across the superannuation, advice and investment ecosystem; improving access to safe, secure financial advice; and placing the Compensation Scheme of Last Resort on a firmer and fairer footing.
The stated context was the collapses of the Shield and First Guardian Master Funds, which affected almost 12,000 people and around $1 billion in retirement savings. The government said it would continue consulting industry, consumer groups, regulators and other stakeholders to progress legislation implementing the package. No commencement date appears in the published material, so treat the package as a proposal rather than rules in force.
ASIC said it welcomed the proposed reforms and would keep taking enforcement action under current laws where it finds evidence of serious consumer harm.
If a referral has already happened
Keep a record of the caller's name and the firm they said they were from; the date and time of each call; any recording or transcript offered; the advertisement, email or message that led to the call; the comparison or performance figures shown to you; and the advice documents and fee disclosures you received.
ASIC provides a channel for reporting misconduct. A report is easier to act on when it names the licensee, the representative, the dates and the specific conduct.
Questions readers ask
What did ASIC's review actually find?
It found examples of unlicensed or unqualified lead generators taking part in the advice process, including fact-finding, risk profiling and discussing recommendations, plus supervision gaps at some licensees. The review covered 15 AFS licensees between January 2025 and June 2026.
How do I confirm someone is licensed or authorised?
ASIC's professional registers search shows the services a person or organisation is licensed to provide.
Which tactics should make me slow down?
A review that always ends in a switch, misleading statements about your existing fund's fees and performance, fear-based claims about retirement, and non-like-for-like performance comparisons. If the person doing the fact-find is not authorised to give advice, that is the pattern ASIC's report flags.
Does the warning change income protection inside super versus retail cover?
No. The report concerns how licensees supervise lead generation in personal financial advice. Policy definitions, waiting periods and claim assessment are set by the policy and the insurer, not by this warning.
What fees came up, and what should I ask about?
The review recorded $9.8 million in upfront fees and $4.5 million in annual ongoing fees deducted by the 15 licensees. Ask which fees are one-off and which recur, who deducts them, from which account or fund, and what the total cost is over the expected life of the arrangement.
Sources and dates
ASIC's findings and final warning are set out in Report 845, Lead generation advice models: Putting consumers and licensees at risk, and media release 26-270MR, ASIC's final warning to licensees – using lead generators may put your licence at risk. The review period ran from 1 January 2025 to 1 June 2026. Trade coverage in SMS Magazine dates the warning to 9 November 2026.
The cold-calling and click-bait switching descriptions come from ASIC's page on high-pressure cold calling tactics and social media click-bait leading to superannuation switching, also undated in the material reviewed.
The reform package is described in Treasury's Protecting Consumers and the Promise of Superannuation in an Evolving Financial Ecosystem and the Assistant Treasurer's release of the same title, both dated 19 August 2026.
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