Most firms entering Australian financial services don’t start by applying for a licence. They start by being authorised under someone else’s. The vehicle for that is the corporate authorised representative — a structure the Corporations Act defines with more precision than the shorthand suggests.
A corporate authorised representative is a company authorised in writing by an AFS licensee, under s 916A of the Corporations Act 2001, to provide specified financial services on that licensee’s behalf. It doesn’t hold its own licence, and its authorisation can’t exceed the licensee’s. The licensee carries the s 912A general obligations and is responsible to clients for the representative’s conduct — whether or not that conduct was within authority. ASIC must be notified within 30 business days, and the appointment appears on a public register. “Corporate authorised representative” is industry shorthand, not a statutory term.
The term isn’t in the legislation
Worth clearing up first, because it causes confusion in practice: “corporate authorised representative” and “CAR” are industry shorthand. Neither appears in the Corporations Act, and ASIC’s own guidance doesn’t use the phrase.
What the Act does define, in the s 9 Dictionary, is an authorised representative: a person authorised in accordance with s 916A or s 916B to provide a financial service or financial services on behalf of a licensee. ASIC confirms in INFO 91 that authorised representatives may be individuals, bodies corporate, partnerships, or trustees of a trust. A “corporate authorised representative” is simply the body corporate case.
The distinction matters when you’re reading the legislation: search for “corporate authorised representative” and you’ll find nothing. The obligations live under “authorised representative”.
How the authorisation works
Under s 916A(1), a licensee gives the representative a written notice authorising it to provide specified financial services on the licensee’s behalf. Two limits follow immediately:
- You can’t be authorised beyond the licence. Section 916A(2) confines the authorisation to services covered by the licensee’s own licence, and s 916A(3) makes an authorisation void to the extent it purports to go further. So the first question isn’t whether a licensee will authorise you — it’s whether their authorisations actually cover what you intend to do.
- ASIC must be told. Under s 916F, a notice must be lodged with ASIC in the prescribed form within 30 business days, covering the representative’s name and business address, the authorisation and its date, and every other licensee the person represents. The same window applies to changes and to revocation. Non-compliance is an offence.
The appointment is then public. ASIC allocates a number and the authorisation appears on the Authorised Representative Register, searchable through ASIC Connect, showing status, the associated licensee, and whether the representative can sub-authorise.
Who is liable — the part people get wrong
The common assumption is that a corporate authorised representative wears its own conduct risk. As between the licensee and the client, that is not what the Act says.
Division 6 of Part 7.6 applies to conduct relating to a financial service on which a client could reasonably be expected to rely, and did rely in good faith. Where the representative acts for one licensee, s 917B makes the licensee responsible for the representative’s conduct — and the words that matter are “whether or not the representative’s conduct is within authority”.
Two qualifications. Section 917D removes that responsibility where the conduct was outside authority and that was disclosed to the client beforehand with sufficient clarity and prominence. And s 917F(3) confines the Division to client-facing liability — it imposes no criminal responsibility on the licensee, and indemnities between licensee and representative are preserved.
Authorising your own people
A corporate authorised representative is a company, so someone has to act for it. Section 916B governs this, and it starts prohibitively: an authorised representative cannot appoint its own authorised representatives.
The carve-out permits a corporate authorised representative to authorise an individual, but only where the licensee has consented in writing. Three limits ride along with it:
- Sub-authorisation can only be given to individuals — you cannot sub-authorise another company.
- A sub-authorised individual cannot authorise anyone further.
- The licensee must keep a copy of its consent for five years. Consent can be given for a named individual or a specified class.
As ASIC puts it in INFO 91, a body corporate that is an authorised representative will generally need to sub-authorise its directors and employees. It’s a step firms routinely overlook until an audit finds it.
Acting for more than one licensee
Permitted, but conditional. Under s 916C, a person can be the authorised representative of two or more licensees only if each licensee has consented to the person also acting for each of the others, or the licensees are related bodies corporate, or the only services provided are claims handling and settling. An authorisation in breach is void, and giving one is an offence. Where a representative does act for several licensees, s 917C allocates responsibility between them, defaulting to joint and several.
And a trap worth knowing: s 916D provides that a financial services licensee cannot be the authorised representative of another licensee (except under s 916E, for a licensee acting under a binder given by an insurer). Section 916D also makes an existing authorisation void if the representative is later granted its own AFS licence. Firms that graduate to their own licence need to plan that changeover deliberately.
Corporate authorised representative vs your own AFSL
The clearest way to see the difference is to ask where each obligation sits.
| Your own AFSL | Corporate authorised representative | |
|---|---|---|
| Holds the licence | Yes | No — acts under the licensee’s |
| s 912A general obligations | Yours | The licensee’s |
| Scope of services | Set by your authorisations | Capped by the licensee’s licence |
| Responsible managers | You nominate them | Met at licensee level |
| Client-facing liability | Yours | Licensee responsible (ss 917B, 917E) |
| ASIC notification burden | Yours | The licensee lodges under s 916F |
| Your own conduct & competency | Yours | Still yours |
Operating as a corporate authorised representative moves the licensing obligations to the licensee. It does not move your conduct.
Training and competency
Which standard applies to your people depends on what they do. Under s 912A(1)(f) the licensee must ensure its representatives are adequately trained and competent — but the specific standard splits:
- Relevant providers — individuals giving personal advice on relevant financial products to retail clients — are governed by the s 921B education and training standards and must appear on the Financial Advisers Register. The definition of relevant provider in s 910A expressly includes an authorised representative of a licensee.
- Everyone else — general advice, personal advice on basic banking products, general and consumer credit insurance, and time-sharing schemes — still falls under RG 146 Licensing: Training of financial product advisers.
RG 146 hasn’t been withdrawn, but it stopped applying to relevant providers from 1 January 2019 under the professional standards reforms. Statements that RG 146 “still applies” or “has been superseded” are both misleading without that qualifier. For a wholesale-only manager, the relevant provider standards will often not be engaged at all — but that turns on your client classification, which is worth confirming rather than assuming.
Where an integrated platform fits
Providence Equity Holdings holds the AFS licence and carries the s 912A obligations, the responsible manager requirement and the ASIC notification burden. You’re onboarded as a corporate authorised representative to run your strategy within an agreed scope, with the compliance framework and supervision that the licensee is answerable for. → Authorised Representative Onboarding
Frequently asked questions
What is a corporate authorised representative?
A corporate authorised representative is a company authorised in writing by an AFS licensee, under s 916A of the Corporations Act 2001, to provide specified financial services on that licensee’s behalf. It doesn’t hold its own licence — it operates within the scope of the licensee’s. Note that “corporate authorised representative” is industry shorthand, not a statutory term: the Act just refers to a body corporate that is an authorised representative. ASIC allocates each authorised representative a number, and the appointment appears on the public Authorised Representative Register.
What is the difference between a corporate authorised representative and an AFSL holder?
The licence, and the obligations attached to it. An AFS licensee holds the licence in its own right and carries the general obligations in s 912A — providing services “efficiently, honestly and fairly”, managing conflicts, maintaining adequate financial, technological and human resources, supervisory and risk management arrangements, ensuring representatives are adequately trained and competent, and dispute resolution for retail clients. A corporate authorised representative acts on the licensee’s behalf and doesn’t carry those s 912A obligations in its own right. Its authorisation also can’t exceed the scope of the licensee’s licence (s 916A(2)–(3)).
Does a corporate authorised representative need its own AFSL?
No — and importantly, you can’t hold both. Operating as a corporate authorised representative is an alternative to your own licence. Section 916D provides that a financial services licensee cannot be the authorised representative of another licensee, with a narrow exception in s 916E for a licensee acting under a binder given by an insurer. Section 916D also provides that an existing authorisation becomes void if the authorised representative is later granted its own AFS licence — so moving from operating under a licence to holding your own is a transition to plan, not something that runs in parallel.
Can a corporate authorised representative appoint its own representatives?
Only in a limited way, and only with the licensee’s written consent. The starting position in s 916B is that an authorised representative cannot appoint its own authorised representatives. The exception permits a corporate authorised representative to authorise an individual, but only where the licensee has consented in writing. Three limits follow: sub-authorisation can be given only to individuals, not to other companies; a sub-authorised individual can’t authorise anyone further; and the licensee must keep a copy of the consent for five years. This is how a corporate authorised representative covers its own directors and staff.
Who is responsible if a corporate authorised representative does something wrong?
As between the licensee and the client, the licensee is — and this is the provision most often misunderstood. Division 6 of Part 7.6 applies to conduct relating to a financial service on which a client could reasonably be expected to rely, and did rely in good faith. Where an authorised representative acts for a single licensee, s 917B makes that licensee responsible for the representative’s conduct whether or not the conduct was within authority, and s 917E extends this to any loss or damage suffered by the client. Under s 917F the client has the same remedies against the licensee as against the representative, and both are jointly and severally liable. A narrow exception in s 917D applies where conduct was outside authority and that was disclosed to the client beforehand with sufficient clarity and prominence. These provisions govern client-facing liability — they don’t impose criminal responsibility on the licensee, and the licensee may still have indemnity rights against the representative.
Can a corporate authorised representative act for more than one licensee?
Yes, but only on the conditions in s 916C. A person can be the authorised representative of two or more licensees only if each licensee has consented to the person also acting for each of the others, or the licensees are related bodies corporate, or the only services provided are claims handling and settling services. An authorisation given in breach is void, and giving one is an offence. Where a representative does act for several licensees, s 917C allocates responsibility between them, defaulting to joint and several responsibility.
How does a licensee appoint a corporate authorised representative?
By written authorisation, then notification to ASIC. The authorisation is the written notice under s 916A specifying the financial services the representative may provide on the licensee’s behalf. Section 916F then requires a notice to be lodged with ASIC in the prescribed form within 30 business days, including the representative’s name and business address, details of the authorisation and its date, and details of every other licensee for whom the person is an authorised representative. The same 30-business-day window applies to changes in notified details and to revocation. Failure to notify is an offence. ASIC sets out the process in INFO 88.
Related reading: Own AFSL vs authorised representative — how to choose between the two. Choosing an AFSL licensee to operate under — what to look for in the licensee whose conduct risk you’ll share. AFSL responsible managers.
Sources & further reading
This page draws on the Corporations Act 2001 and guidance published by ASIC. The law changes — for the authoritative and current position, see:
- Corporations Act 2001 (Cth) — ss 910A, 912A, 916A–916G and 917A–917F govern authorised representatives
- INFO 91 Who can be an authorised representative of an AFS licensee
- INFO 88 Notifying ASIC of the appointment of an AFS authorised representative
- ASIC Authorised Representative Register — the public record of authorisations
- RG 104 AFS licensing: Meeting the general obligations — the licensee’s s 912A obligations
There is no ASIC regulatory guide dedicated to authorised representatives — the guidance sits in the information sheets above. ASIC guidance is general and doesn’t address your circumstances; confirm how it applies to you with your own adviser.