File notes for financial advisers: template and example.

A file note is a dated, written record of a client interaction: who was there, how it happened, what the client said, what was decided and what happens next. In Australian financial advice, file notes are part of the records that show how the adviser acted in the client’s best interests. A good one is written promptly and checked.

File notes cover more than meetings. Phone calls and instructions received by email deserve one too.

ASIC lists file notes, including records of conversations, among the forms advice records can take, together with audio recordings, fact-finding documents, working papers and correspondence. Records do not have to be on paper (RG 175.337).

There are three main reasons, and the first is a legal one.

• Record-keeping rules. When personal advice is given to a retail client, the licensee must ensure records are kept of the information relied on and the action taken to act in the client’s best interests, the advice and why it is appropriate, and, where there is a conflict, how the client’s interests were put first. The records must be kept for seven years after the advice and be producible throughout. Authorised representatives have a matching duty (ASIC Instrument 2024/508, notional s912G; RG 175.339–RG 175.347).
• Complete and accurate client records. Standard 8 of the Financial Planners and Advisers Code of Ethics 2019 requires advisers to keep records of clients, including former clients, complete and accurate.
• Evidence if something goes wrong. In complaints, AFCA gives notes made at the time of an event more weight than later recollections (AFCA factsheet).

There is a simpler reason too: the next person to open the file should not have to guess what was agreed.

What has changed recently?

ASIC Instrument 2024/508, made in September 2024, carried over the earlier Class Order 14/923 with no significant changes. ASIC reissued RG 175 on 21 November 2024. The instrument is due to be repealed at the start of 1 October 2029 unless it is remade or extended.

The Delivering Better Financial Outcomes changes that started in July 2024 and January 2025 covered fees from super, ongoing fee arrangements, Financial Services Guides and commission consents. ASIC’s summary of those changes does not list a change to these advice record-keeping rules. In March 2025 the Government released draft law that would replace the Statement of Advice with a “client advice record” (Treasury, 21 March 2025). When this guide was reviewed we could not confirm that it had become law. Check the current position with your licensee.

Detail varies with the meeting and your licensee’s requirements. These ten items cover most interactions.

Keep what the client said separate from your interpretation. “Jordan may cut back to four days a week” should not become “Jordan is retiring” unless Jordan said so.

Copy this structure and adapt it to your licensee’s requirements. It is a starting point, not a prescribed ASIC form.

Fictional people and figures. A review meeting written up with the template, after the adviser checked and corrected an AI draft.

The corrections line matters. It shows the draft was checked, by whom, and that a possibility was not recorded as a decision.

A weak file note is usually vague, unattributed or written long after the meeting.

A good file note also records what did not happen. A client who declined to give information, or chose not to proceed, should be on the record.

Recording can make a file note more accurate, but it has its own rules. Laws on recording private conversations are set by each state and territory, and they differ; the Australian Law Reform Commission described the differences as significant (ALRC Report 123, 2014). Get advice on the rules that apply to your firm and your clients’ locations.

Privacy law applies too. The OAIC’s guidance on commercially available AI products says whether participants know a meeting is being recorded is relevant to whether collection is lawful and fair, and treats seeking consent as best practice. A practical routine:

• Tell the client before the meeting that you would like to record it, and why.
• Ask again at the start, before recording begins, and note who agreed.
• Offer to take notes instead, and make that easy to choose.
• Note any part of the meeting that was not recorded.
• Know where the recording is stored, who can access it and how long it is kept: ASIC counts audio recordings as advice records.

AI can turn an approved recording or transcript into a structured draft. That draft can still mishear a name, swap a figure, drop a “not” or turn a possibility into a decision.

The rules do not change because AI was used. ASIC has said the financial services framework is technology neutral, that licensees need staff who can review AI-generated outputs, and that licensees remain responsible for outsourced functions (REP 798). The OAIC says a person should verify the accuracy of personal information produced by AI, and recommends against entering personal information into AI chatbots.

Before an AI draft becomes the record, the adviser should check:

1. Names and roles. Each person is named correctly and each statement is attributed to the right speaker.
2. Figures and dates. Amounts, balances and dates match what was said and any documents supplied.
3. Decisions. Only what was actually agreed is recorded as agreed. Possibilities stay possibilities, and negatives stay negative.
4. Gaps. Anything the draft missed is added, and anything uncertain is marked or confirmed with the client, not guessed.
5. Review record. The note shows who reviewed it, when and what changed. Keep the draft separate from the approved note.

That last step matters for evidence too: AFCA treats records with controls over how they are created and changed as more reliable.

Sources checked 21 October 2026. This guide is general information, not legal or compliance advice. Confirm your firm’s file note and recording requirements with your licensee or compliance adviser.

Bunya AI builds Bunya Command Centre, the practice operating system for Australian financial advice firms, built in your firm’s own Microsoft 365. Bunya prepares the work, and a person on your team checks and approves every step.

For file notes, that means a draft for the adviser to check, never a finished record. Approved notes stay with the client record, with who approved them and when.

• Bunya Voice: an optional add-on. Supported calls and Teams meetings are captured under the recording and consent settings your firm agrees, and the adviser gets a drafted file note and proposed actions to check.
• Compliance and evidence: file notes, approvals and AI use kept with the client record, so your team can show what was done.
• The financial advice process: where file notes fit from the first meeting to implemented advice.