Submissions to Treasury’s consultation on education reform for financial advisers back the government’s proposed three-part framework and urge the introduction of enabling legislation as soon as possible.
A framework unveiled for consultation by the Minister for Financial Services Daniel Mulino on 17 March, and which closed last Friday, would require new entrants to hold a bachelor’s degree or higher qualification, complete four financial concepts subjects, and complete four accredited financial advice subjects.
Submissions from organisations including the Financial Advice Association Australia, the Financial Services Council, the SMSF Association, the Joint Associations Working Group (which represents 11 industry and professional bodies including the aforementioned associations) and the Super Members Council support the package, which they say is critical in attracting new entrants to a severely diminished profession.
The number of registered financial advisers has fallen from about 29,000 at the start of 2019 to 15,059 as of 9 April this year, according to Wealth Data. The FAAA says only 464 advisers provided advice for the first time in 2025, and the flow of new entrants is insufficient to hold adviser numbers even at their current level. JAWG’s submission quotes Investment Trends research putting the number of Australians with unmet advice needs at 15.9 million.
“Improving access to trusted, professional financial advice is critical to strengthening consumer protection and will mean fewer consumers will be susceptible to unlicensed operators, predatory forms of lead generation and high-pressure sales tactics that can cause significant consumer harm,” the JAWG submission says.
The FSC says the cost of financial advice has reached more than $5000 in some cases, putting it out of reach for millions of consumers. It says a new framework will expand the supply of new advisers as a necessary step to making advice more affordable.
Shortcomings in the current education standard are a major contributor to “the decline in numbers and the lack of new entrants”, according to the FSC.
“It is unnecessarily restrictive, creating high barriers to entry for both aspiring advisers and existing professionals trying to meet the requirements,” the FSC submission says.
Costly and time-consuming
JAWG and the FAAA say graduates of accounting, commerce, economics and finance degrees cannot currently enter the profession without undertaking costly and time-consuming additional study. Yet JAWG says six qualifying courses were discontinued last year due to lack of enrolments.
“The lack of recognition of completed qualifications such as accounting, business, commerce and economics has made it challenging to attract new entrants as they are currently required to incur significant additional costs and time to complete an approved financial planning degree,” the JAWG submission says.
The proposed reforms would shift the focus from whole degrees to individual, relevant subjects, which would allow candidates to rely on study already completed to meet entry criteria, and also open new pathways for career changers who hold adjacent professional qualifications.
“At present, graduates of the universities who do not have an approved degree are unable to join the financial advice profession,” the FAAA submission says.
“This impacts the graduates of many of Australia’s leading universities. They are effectively excluded from the profession in the absence of undertaking significant costly additional study, with no capacity to recognise relevant study that they have previously undertaken.”
The submissions call for clear guidance for licensees on how to assess new entrants’ qualifications under the more flexible framework, while the FAAA and FSC both support a public register of approved subjects so licensees and prospective students know what units are eligible.
Both the FAAA and SMC raise concerns about Qualified Tax Relevant Provider status, which the FAAA says is held by almost 90 per cent of advisers, and that excluding taxation and commercial law subjects from the core curriculum means most new entrants will not automatically qualify as QTRPs, requiring additional study.
The SMC recommends the QTRP requirements be incorporated into the accredited subjects.
Broad agreement
The submissions broadly agree that students currently enrolled in approved programs must be protected, and that universities need adequate time to adjust and restructure courses. The FSC says the new and old standards should operate in parallel for two years from the date the new legislation comes into effect; but the
FAAA says an end date for the old standard may not be appropriate at all, given that it may take part-time students six years or more to complete their study.
“We are particularly concerned to avoid a situation where existing students are left in limbo, new students hold off enrolling until new courses are available (which could take some time), and the pipeline of new entrants dries up,” the FAAA submission says.
The SMSF Association submission says the failings of “the existing rigid education standard are evident in the declining number of enrolments in the currently prescribed qualifications, resulting in several tertiary providers ceasing to offer their financial planning qualifications in recent times”.
“It is very unlikely that a prospective new entrant who needs to complete one or all four accredited financial advice subjects would be able to enrol with a [higher education provider] to complete these subjects, rather they would likely need to enrol in a full qualification,” it says.
“This would require them to meet the qualification entry requirement and bear the cost of study, which is likely to present a similar barrier to entry as the current education standard.”
While the aim of the proposed standards is to increase the number of new entrants to the profession to close the advice gap, the SMC says that on their own the reforms will have little effect. It says completion of Tranche 2 of the Delivering Better Financial Outcomes legislation is also critical.
The industry super fund representative body says that “even with a stronger professional adviser intake pipeline under the proposed education settings”, adviser numbers are unlikely to exceed 17,500 by 2030 and 20,000 by 2035, still 30 per cent below the 2019 level.
The SMC says DBFO Tranche 2 would expand intra-fund advice and introduce a new class of limited-scope adviser.
“If comprehensive advice cannot scale to meet mass-market retirement demand, policy settings must support the expansion of safe complementary advice models such as intra-fund advice with its strong legal safeguards, consumer protections and trustee oversight duties,” it says.
