What is a Statement of Advice (SoA)?

A Statement of Advice (SoA) is the document an Australian financial adviser generally must give a retail client when providing personal advice. Required by the Corporations Act 2001, it sets out the advice, the reasons for it, the fees and benefits involved and any conflicts of interest, so the client can decide whether to act on it.

In financial advice, SoA means Statement of Advice, not service-oriented architecture.

The rules sit in Part 7.7, Division 3 of the Corporations Act 2001 (sections 946A to 947E). ASIC explains how it applies them in Regulatory Guide 175 (RG 175).

The SoA records the advice. It does not decide it. The best interests duty in Part 7.7A determines what advice is given (RG 175.85), and the adviser remains responsible for it.

An SoA is generally required whenever personal advice is given to a retail client (s946A). It is not required for general advice, or for advice to a client who is not a retail client (RG 175.79, RG 175.89).

• Timing. With the advice or as soon as practicable after it, and before the firm provides a further service connected with the advice, such as arranging for a product to be issued (s946C; RG 175.86).
• Time-critical cases. If the client expressly instructs that the further service happen immediately and an SoA cannot practicably be given first, it follows as soon as practicable, and within five days at the latest (s946C(3)).
• Fact-finding meetings. ASIC’s view is that no SoA is needed at a genuine fact-finding consultation, if the client is told at the start that the advice will be set out in an SoA and they should not act on what is said in the meeting (RG 175.91).

ASIC encourages giving the SoA early enough for the client to consider it (RG 175.92). Failing to give a required SoA is an offence, and so is giving a defective one (RG 175.137–175.139).

RG 175.96 lists what every SoA must include. In plain terms:

• The title. “Statement of Advice” on the cover, or at or near the front (s947A).
• Who is advising. Name, contact and licence details. For an authorised representative, also the licensee’s details and a statement that they act for it (s947C(2)(c)–(d)).
• The advice. A statement setting out the advice (s947B(2)(a), s947C(2)(a)).
• The basis for the advice. The scope, a concise summary of the client’s circumstances, the options considered, why the advice is appropriate and how the adviser acted in the client’s best interests (s947B(2)(b); RG 175.105).
• Remuneration and benefits. Fees, commissions, referral payments and other benefits that might reasonably influence the advice (s947B(2)(d); RG 175.96(f)–(g)).
• Interests and relationships. Associations that might influence the advice, such as links to a product issuer (s947B(2)(e)).
• A warning, if needed. Where the advice is based on incomplete or inaccurate information (s947B(2)(f), s961H).
• Switching information. If one product is to replace another: the costs, benefits that may be lost and other significant consequences (s947D).

The detail should be what a retail client would reasonably need to decide whether to follow the advice, presented clearly, concisely and effectively (s947B(3) and (6)). There is no one correct format. ASIC expects a short and simple SoA for short and simple advice, with key information in the body and nothing generic (RG 175.126, RG 175.129). An SoA cannot be combined with a Financial Services Guide or Product Disclosure Statement (s947E).

A Record of Advice (RoA) is a shorter record of personal advice, allowed in place of an SoA only in set situations. ASIC’s Information Sheet 266, FAQs: Records of advice (INFO 266) describes three.

In every case, conflicts of interest must still be disclosed and the RoA kept for at least seven years. It can be written, or an audio or video recording. For further advice, it sets out the advice, or brief particulars of the recommendations and their basis, plus any switching information disclosed (RG 175.95).

“Significantly different” is a professional judgement. INFO 266’s examples include separation, a new baby, redundancy, an inheritance and retirement. A new area of advice can change the basis: in ASIC’s example, a client with an SoA on super and insurance who now wants to switch super funds needs a new SoA. Record why you concluded nothing significant changed.

Not yet. As at 21 October 2026, the SoA and RoA rules on this page still apply, and the SoA provisions remain in the Corporations Act as currently compiled. Firms should keep giving SoAs and RoAs under the current law.

What has already changed

The first tranche of the Delivering Better Financial Outcomes (DBFO) reforms received Royal Assent on 9 July 2024. According to ASIC’s DBFO summary, it changed Financial Services Guides and conflicted remuneration (10 July 2024), ongoing fee arrangements, including removing the fee disclosure statement (10 January 2025, with transition), advice fees paid from super (10 January 2025) and insurance commission consent (9 July 2025). It did not replace the SoA. ASIC updated RG 175 and INFO 266 on 21 November 2024.

What is still proposed

Treasury’s December 2023 DBFO roadmap proposed replacing SoAs with a principles-based advice record covering the scope, the advice, the reasons and the cost or benefits, still given to the client. Draft legislation for a “client advice record” followed in March 2025, and consultation closed on 2 May 2025.

On 19 August 2026, at the National Press Club, the Minister for Financial Services said the government would move forward with streamlined statements of advice. No bill had passed and no start date was set at the time of writing, so the detail may change.

Terms you may see

• Client advice record (CAR). The name in the 2025 draft legislation. Not yet law.
• Advice record. The 2023 roadmap’s term for the proposed replacement.
• Record of Advice (RoA). Current law, in the situations above.
• Fee disclosure statement (FDS). A separate ongoing fee document, removed by the first DBFO tranche. Never part of the SoA.

ASIC has published example SoAs. RG 90 (December 2017) shows scaled advice on personal insurance for a new client, and RG 244 has further examples. The outline below is a structure only, for fictional clients Sam and Alex Example. Your licensee’s template takes priority.

Licensees set their own review rules. A common workflow, covering stages 5 and 6 of the financial advice process:

1. Confirm the inputs. The adviser confirms the fact find and goals with the client and agrees the scope.
2. Decide the strategy. The adviser researches, models and decides the recommendations. The client agrees to go ahead.
3. Send a complete request. The adviser sends the paraplanner a request pack: the recommendations, reasons and evidence.
4. Draft. The paraplanner drafts the SoA, runs product comparisons and raises questions rather than filling gaps.
5. Check. A technical review, plus licensee pre-vetting where required.
6. Approve and present. The adviser approves and presents the SoA and records the client’s authority to proceed.

What goes in an SoA request pack

• Confirmed fact find. Dated, with the client’s risk profile and goals.
• Scope. What the advice covers and what it does not.
• Strategy notes. Each recommendation and the reasons, including alternatives ruled out.
• Modelling. Outputs and assumptions.
• Existing products. Holdings, fees and cover, for any replacement comparison.
• Fees. The advice fee, any ongoing fee arrangement and any commissions.
• Known gaps. Incomplete or conflicting information, and what the adviser decided.

Where AI can help. Assemble the request pack from confirmed records, with sources linked and gaps flagged for a person to resolve. AI does not decide the advice: the adviser is responsible for it, and people check everything before it reaches the client.

There is no standard price. Each firm sets its own fees, and the SoA must disclose the remuneration the firm receives (s947B(2)(d)). We don’t quote typical figures, because costs vary too widely between firms and types of advice. For the firm, the cost is mostly time: adviser, paraplanner and reviewer hours, plus days spent waiting.

Check, too, whether an SoA is needed at all: where the further advice conditions are met, an RoA may be enough. To understand your own costs, time recent SoAs from request to presentation, including review and waiting time, then test a change in the cost and capacity calculator.

Most rework starts before drafting:

• Unclear scope. The paraplanner guesses what is in and out, or the scope changes after the request.
• Stale fact find. Details not confirmed, or changed since discovery.
• Missing product data. Existing holdings, fees or cover not to hand.
• No reasons. Notes state the recommendation but not why.
• Fee mismatches. Draft fees differ from the quote or the ongoing fee arrangement.
• Generic content. Boilerplate that is not relevant to the client (RG 175.126(b)).
• Late client changes. New instructions after the strategy was agreed.

A complete request, checked by the adviser before paraplanning, prevents many of these.

This guide is general information, not legal or compliance advice. Confirm how these rules apply to your firm with your licensee or compliance adviser.

Bunya AI builds Bunya Command Centre, the practice operating system for Australian financial advice firms, inside your firm’s own Microsoft 365. For SoA work, Command Centre gathers the fact find, documents, strategy notes and modelling into one request pack, sources linked, for the adviser to check before it goes to paraplanning.

Bunya does not write or decide the advice. Your paraplanner prepares the SoA, your adviser approves it, and a person on your team checks every step. Supported sources are agreed for each firm in its Blueprint.

• SoA preparation: from meeting notes to a verified request.
• The financial advice process: where the SoA fits.
• Cost and capacity calculator: your own numbers.