SOA to ROA: ASIC Compliance Rules 2025

1. SOA to Advice Record: ASIC Rules & Compliance Duties in 2025 brokerssupport.com.au/blog/soa-to-advice-record-compliance/ Aneri Shah August 20, 2025 The financial advice industry in Australia is in the middle of an important shift. For years, the Statement of Advice (SOA) was the cornerstone of compliance. But in 2025, with financial advice reforms in Australia pushing for shorter, clearer, and more meaningful documentation, the focus is increasingly moving from SOA to Advice Record (ROA). This change is more than a technical adjustment. It requires licensees, advisers, and paraplanners to rethink their roles, understand ASIC advice record guidelines, and align with new adviser documentation requirements in 2025. When executed well, this shift can create efficiency and a better client experience. Done poorly, it risks ASIC scrutiny, reputational damage, and financial penalties. For many firms, one way to manage this shift efficiently is by exploring outsourced paraplanning services, which can provide additional support in adapting to new compliance demands while keeping the focus on clients. Key Takeaways The shift from SOA to Advice Record in 2025 is about smarter, not lighter, compliance. Licensees must strengthen frameworks, invest in digital compliance systems, and train advisers and paraplanners. 1/6

2. Advisers need to document their rationale carefully, prioritise best interest duty, and make sure every ROA meets advice record compliance requirements. Paraplanners carry greater responsibility for accuracy, consistency, and ensuring files align with ASIC advice record guidelines. Overusing ROAs, failing to justify their use, or poor record-keeping are the biggest compliance risks in 2025. So, what does this shift mean, and how should each role in the advice chain prepare? Why is the industry moving from SOA to ROA? The move from SOA to Advice Record reflects a bigger theme: simplifying advice without compromising compliance. SOAs are still critical where new client relationships or significant strategy changes are involved. They remain detailed, disclosure-heavy, and often overwhelming for clients. ROAs, on the other hand, can be used in ongoing advice scenarios, for instance, top-ups, small adjustments, or strategy tweaks. They’re shorter, quicker to prepare, and more client-friendly. The challenge? Getting the balance right. The advice record vs SOA decision is one of the most important compliance calls advisers will need to make in 2025. ASIC’s 2025 Expectations Under ASIC advice record guidelines, the regulator is paying closer attention to: 1. Clearer, shorter documents – no unnecessary jargon or repetition. 2/6

3. 2. Audit evidence – firms must demonstrate why they used an ROA instead of an SOA. 3. Digital record-keeping – electronic SOAs and ROAs are fine, but they must meet advice record compliance requirements (timestamps, client acknowledgments, storage security). ASIC isn’t asking for less rigour, it’s asking for smarter documentation. A June 2025 update from Dentons highlighted that the Delivering Better Financial Outcomes (DBFO) reforms are progressing, with draft legislation including the proposed replacement of SOAs with Client Advice Records (CARs). While the details are still evolving, licensees need to prepare for stricter oversight of advice documentation and align policies with upcoming financial advice reforms in Australia. What Licensees Must Do Licensees sit at the top of the compliance chain, and in 2025, they carry ultimate responsibility for ensuring advice files hold up to ASIC scrutiny. Key actions include: Frameworks & Policies: Licensees must provide clear rules for when an SOA is mandatory and when an ROA can be used. System Investment: Digital compliance platforms should capture ROAs, file notes, and approvals in a secure and auditable way. Training & Supervision: Advisers and paraplanners need structured training around advice record compliance requirements. Without this top-level oversight, inconsistencies in adviser documentation requirements 2025 can create major compliance risks. What Advisers Must Do For advisers, the shift from SOA to Advice Record is both an opportunity and a challenge. The opportunity lies in providing faster, more client-friendly advice; the challenge is proving to ASIC that an ROA was the correct choice. In practice, advisers must: Document rationale: Every file should explain why an ROA was used instead of an SOA. Prioritise best interest duty: Even a shorter ROA must show how advice serves the client. Engage with clients clearly: Shorter documents mean verbal explanations become more important. File notes must capture this. 3/6

4. Ultimately, advisers must see ROAs not as shortcuts, but as tools that still meet full compliance standards. What Paraplanners Must Do For paraplanners, this shift changes the type of work they do. Instead of drafting lengthy SOAs every time, they will increasingly be called on to create well-structured ROAs that still satisfy ASIC advice record guidelines. Key paraplanner responsibilities advice record in 2025 include: Template accuracy: Ensuring ROAs reflect current regulatory wording and requirements. Consistency: Keeping client files aligned across advisers and within the licensee’s framework. Supporting audit-readiness: Paraplanners must maintain file quality so an external review can quickly confirm compliance. As ROAs become more common, paraplanners move from being document drafters to becoming true compliance guardians. Benefits of Embracing ROAs When done correctly, shifting from SOA to Advice Record brings several benefits: Efficiency: Advisers and paraplanners spend less time drafting long documents. Cost-effectiveness: Lower paraplanning costs per advice instance. Client experience: Clients get shorter, easier-to-read advice records. Scalability: Firms can handle more ongoing advice relationships without drowning in paperwork. These benefits also tie into the rise of financial services outsourcing, where firms look externally for scalable solutions that can balance compliance with cost efficiency. Risks to Watch in 2025 As with any shift, risks exist: Overusing ROAs when SOAs are required. Generic ROAs that don’t show how the advice fits the client. Weak record-keeping, particularly around verbal client discussions. Failing to meet new adviser documentation requirements under digital compliance systems. Each of these mistakes could attract ASIC penalties or trigger remediation exercises. As reported by The Australian, industry bodies have already warned that new regulatory costs, such as the government’s proposed compensation levy, could ‘drive advisers out of the industry.’ 4/6

5. Against this backdrop, using ROAs correctly and meeting adviser documentation requirements isn’t just about compliance, it’s also about survival for many small practices. How to Prepare – Practical Steps So, what should licensees, advisers, and paraplanners do now? Licensees: Update policies, invest in systems, and run training programs. Advisers: Build habits of documenting rationale and maintaining strong file notes. Paraplanners: Enhance knowledge of ROA drafting and compliance checkpoints. Together, these actions create a compliance chain that can withstand ASIC audits while delivering advice efficiently. Looking Forward The industry’s shift from SOA to Advice Record is part of broader financial advice reforms in Australia. The trend points toward more digitisation, greater reliance on technology, and the possibility of ASIC introducing standardised templates. In the future, AI-driven compliance checks and audit automation could make advice record vs SOA decisions even more streamlined. But until then, it’s up to human judgment, and strong paraplanning support, to ensure advice remains compliant and client-focused. According to The Australian, industry leaders have also called on the federal government to allocate $10 million to address the declining number of advisers in Australia. With adviser numbers falling, efficiency tools like ROAs, when applied correctly, may become 5/6

6. essential for maintaining access to advice while ensuring compliance with ASIC advice record guidelines. Conclusion The move from SOA to Advice Record in 2025 is not about reducing compliance, it’s about reshaping it. For licensees, it means building robust frameworks. For advisers, it means making smarter documentation choices. For paraplanners, it means taking greater ownership of compliance details. By embracing these changes now, all parties can align with ASIC advice record guidelines, meet their adviser documentation requirements, and build a more efficient, client-friendly advice process for the future. Ultimately, whether handled in-house or through a trusted paraplanning expert, the move from SOA to ROA will demand a careful balance of compliance, efficiency, and client focus. 6/6