AFSL and Australian Credit Licence applications
We prepare and run Australian Financial Services Licence and Australian Credit Licence applications end to end, from choosing the right authorisations through to answering ASIC's requisitions. Your file is run by an experienced senior lawyer. Indicative fees start at $6,000 for an AFSL plus ASIC's own application fee.
An AFSL or ACL application is not a form. It is a written case put to ASIC that your business is competent to do the thing it wants to do, and ASIC tests that case against a number of proofs covering competence, compliance, conflicts, resources, risk and dispute resolution. The application succeeds or fails on how well that case is built, and on the judgement behind the choices made before a word of it is drafted.
We use technology to carry the repetitive parts of that build, so the time you pay for is the time that calls for legal judgement: selecting authorisations, structuring responsible manager arrangements, and dealing with ASIC. It makes us efficient, and it keeps our fees genuinely competitive, without turning the work into a production line.
Why clients come to us
Because licensing is not clerical work, and it should not be handed to someone treating it that way.
Every Dwyer Harris licensing engagement is led by a senior lawyer with more than three decades of experience in the financial services sector. That experience is what tells us which authorisations your business model actually requires and which it does not, which of your proposed responsible managers will satisfy ASIC and which will not, where an application will attract requisitions before it attracts them, and when the right answer is that you do not need a licence at all. Those are judgement calls.
Because we are a law firm, your instructions and our advice attract legal professional privilege, and our work is covered by a solicitor's professional indemnity insurance.
What we do
AFSL applications
Full preparation and lodgement through the ASIC eLicensing Portal, including all supporting proofs, and management of ASIC's queries and requisitions through to grant.
Australian Credit Licence applications
New Australian Credit Licence (ACL) applications for credit providers, brokers and intermediaries, prepared and lodged on the same basis.
Licence variations
Adding authorisations or products to an existing AFSL or ACL, and removing or replacing key persons and responsible managers.
Licence strategy
Advice on whether you need your own licence at all, or whether an authorised representative or credit representative arrangement, or acquiring a licensed entity, gets you to market faster.
New licensing obligations for digital asset and payments businesses
Two sets of reforms are bringing whole categories of business into the AFS licensing regime for the first time. If you operate in digital assets or in payments, you are likely to need a licence, or a variation to the licence you already hold.
Digital assets
The Corporations Amendment (Digital Assets Framework) Act 2026 (Cth) creates two new categories of financial product, digital asset platforms and tokenised custody platforms, and both require an AFS licence. Licensees take on the core Corporations Act obligations, including the duty to act efficiently, honestly and fairly, prohibitions on misleading conduct, clear disclosure of custody arrangements, governance and risk controls, dispute resolution and access to a compensation scheme.
The Act commences on 9 April 2027 with an 18-month transition. ASIC has published a roadmap of staged consultation and legislative instruments setting asset-holding, transactional and settlement standards and financial requirements for platform operators, with licence applications opening in the final six months of the transition and full supervision and enforcement from April 2027.
The deadline that bites first is 30 September 2026. ASIC requires firms dealing in existing digital asset financial products to apply for, or vary, an AFS licence. ASIC's no-action position now ends on 30 September 2026, covering market licence and clearing and settlement facility licence candidates and authorised representative and intermediary arrangements. AFCA membership must be in place before the application is made, and that deadline moved to the same date. If this affects you, the application needs to be underway now.
Payments
Treasury has released an exposure package for the payments licensing reforms, which defines "regulated payment functions" and brings participants across the payments value chain under ASIC oversight, proportionate to risk. Providers will need an AFS licence, either a new application or a variation, and will have to demonstrate organisational competence, adequate financial resources, dispute resolution arrangements, insurance and cyber resilience, alongside a requirement for certain providers to safeguard payment-related money. The package also carries a new prudential framework, exemptions and exclusions, transitional arrangements, and a rule-making power supporting a mandatory revised ePayments Code.
Consultation on the draft package closed on 9 April 2026 and the regime has no commencement date yet. That makes this the window in which to work out what your licensing position will be, while there is time to do it properly.
Many businesses affected by either reform already hold an AFS licence. In those cases the work is a variation rather than a fresh application, which is faster and less expensive, and we handle both.
How much does an AFSL or ACL application cost in Australia?
An AFSL or ACL application has two separate costs: the professional fees for preparing and running the application, and ASIC's own application fee, which is set by regulation, is GST-free, and is paid directly to ASIC. The ranges below are a guide to our professional fees, exclusive of GST. ASIC's fee is additional in every case.
| Engagement | Indicative fee range |
|---|---|
| AFSL, single product class, wholesale clients only | $6,000 – $9,000 |
| AFSL, retail clients or multiple authorisations | $9,000 – $15,000 |
| AFSL, complex mandates: custody, managed discretionary accounts, derivatives, responsible entity, foreign applicants | From $15,000 |
| AFSL variation, adding authorisations to an existing licence | $4,000 – $8,000 |
| Australian Credit Licence application | $3,500 – $6,000 |
| Australian Credit Licence variation | $2,500 – $4,500 |
| Licence readiness review, before you commit to applying | $1,500 – $3,000 |
These are estimates, not fixed quotes. We give every client a written costs disclosure and costs agreement with a scoped estimate before any work starts, so you know what you are committing to. If the scope changes, we tell you before the cost does.
ASIC's application fees
ASIC charges its own fee to lodge an application. It is GST-free, it is not part of our professional fees, and it is indexed on 1 July each year. Current fees as of August 2026 are shown below.
| Application | ASIC fee |
|---|---|
| AFSL, company applicant, according to the authorisations sought | $3,721 – $7,537 |
| ACL application | $1,798 – $4,624 |
| ACL variation | $1,156 – $2,826 |
What is included with our AFSL application service
Our standard AFSL engagement covers the whole application:
- Advice on the authorisations you need, and on whether you need a licence at all.
- Preparing and lodging the application through the ASIC eLicensing Portal.
- Preparing and settling every supporting proof ASIC requires, including the business description, organisational competence, the development program for responsible managers, conflicts of interest arrangements, compliance arrangements, the outsourcing statement, the program for monitoring, supervising and training representatives, financial statements and financial resources, human resources and information technology capacity statements, the dispute resolution system statement, the risk management system statement, and the compensation capacity statement.
- Reviewing your comments and feedback on the application and the supporting documents.
- Liaising with ASIC on progress, and dealing with ASIC's queries and requisitions.
- All related advice and correspondence through to the grant of the licence.
What is included with our ACL application service
An ACL engagement is built the same way, against the proofs ASIC requires of a credit licence applicant:
- Advice on the credit activities you need to be authorised for, and on whether a licence or a credit representative appointment is the better route for your business.
- Preparing and lodging the application through the ASIC Regulatory Portal.
- Preparing and settling the supporting proofs, including the business description, the fit and proper evidence for your officers and controllers, organisational competence and the nominated responsible managers, financial resources, compliance and risk management arrangements, the arrangements for monitoring, supervising and training your representatives, conflicts of interest arrangements, your internal and external dispute resolution arrangements, and your compensation arrangements.
- Reviewing your comments and feedback on the application and the supporting documents.
- Liaising with ASIC on progress, and dealing with ASIC's queries and requisitions.
- All related advice and correspondence through to the grant of the licence.
What is not included
- Incorporating or restructuring entities, and related constitutional or shareholder documents.
- Establishing or registering a fund, and fund compliance documentation.
- AML and CTF programs, and AUSTRAC enrolment and registration.
- Client-facing documents: financial services guides, product disclosure statements, terms and conditions, and website disclosures.
- Commercial contracts, including outsourcing, banking, custody and payment processing agreements.
- Professional indemnity insurance and AFCA membership arrangements.
- Ongoing compliance support after the licence is granted.
We can assist you with most of these requirements if needed. We cannot assist you with setting up a company or a fund, but we can direct you to people who can.
Who we act for
We act for businesses that need a licence in order to launch, and for licensees that need to extend one. We accept instructions from digital asset platforms and custody providers, payments and fintech businesses, fund managers and venture capital managers, credit providers and finance brokers, corporate advisory and wholesale advice businesses, and foreign financial services providers establishing an Australian presence.
How long does an AFSL or ACL application take?
ASIC works to a 120-day target for deciding a complete AFSL application, but a realistic end-to-end timeframe is four to eight months from first instruction to grant, and longer where the authorisations are complex or the applicant is foreign. The single largest variable is how quickly the applicant produces its financial information and its responsible managers' evidence of competence. An AFSL variation usually runs four to six months.
An ACL application is generally quicker. A straightforward application is often decided within about three months of lodgement, and a variation faster again. The preparation that sits in front of lodgement, though, is much the same in kind: the proofs have to be complete and the responsible managers settled before anything is filed, and that work is where the time goes. An application lodged incomplete is not a faster application, it is a slower one.
Common questions
What is a responsible manager, and how many do I need?
ASIC assesses an applicant's organisational competence through its responsible managers, who are the people with direct responsibility for the significant day-to-day decisions about the financial services the licence covers. There is no fixed number. It depends on the authorisations sought and how the business is structured, and each responsible manager has to satisfy one of ASIC's recognised combinations of qualifications and experience. Getting this wrong is the most common reason applications stall, which is why we work through it before anything is drafted.
I already hold an AFS licence. Do I need a new one?
Usually not. Where a business already holds a licence and the reforms bring a new activity within scope, the work is generally an application to vary the existing licence to add the authorisations, which is faster and less expensive than a fresh application. Whether a variation is enough depends on what you are already authorised to do and how the new activity is characterised.
Can I apply myself, or use a template?
You can. ASIC's portal is open to any applicant, and template proof documents are widely sold. What a template cannot do is choose the right authorisations for your business model, defend those choices when ASIC asks about them, or tell you which of your proposed responsible managers will not pass. Applications prepared without that judgement tend to attract requisitions, and requisitions are where the delay and the unbudgeted cost live.
Am I better off becoming an authorised representative instead?
Sometimes, particularly early on. Operating under another entity's licence avoids the application cost and gets you trading sooner, but you take on supervision, reporting and contractual restrictions, you pay fees to the licensee, and you do not control your own authorisations. It is a genuine question of strategy rather than a fallback, and we would rather tell you that than sell you an application you do not need.
Do you help after the licence is granted?
Yes. Licensing is the start of the obligations, not the end of them. We can put ongoing compliance support in place separately, so you are not carrying the regulatory load alone once the licence arrives.
Talk to us before you apply
The cheapest point at which to fix a licensing problem is before the application is lodged. If you are weighing up an AFSL or an ACL, a short conversation about your authorisations and your responsible managers will tell you what the application is likely to cost and how long it will take.
This page is general information, not legal advice, and does not take account of your circumstances. Fee ranges are indicative estimates, exclusive of GST, and are not fixed quotes; a written costs disclosure and costs agreement is provided before work commences. ASIC fees are set by regulation, are GST-free, are indexed annually on 1 July, and are stated as at August 2026. The reform position stated on this page is current as at August 2026 and is subject to change. Liability limited by a scheme approved under Professional Standards Legislation.