Key Sections Every SOA Should Have

Client Details and Advice Scope

Your Statement of Advice should start by clearly identifying you — your name, contact details, and the scope of the advice being provided. It should state what areas the advice covers (e.g., superannuation, insurance, investments) and any limitations. If the scope is unclear, you may not know what you are agreeing to.

Your Goals and Objectives

The SOA should clearly set out your financial goals and objectives as discussed with your adviser. This section should be personalised and specific to you — not generic statements. It forms the basis for determining whether the recommendations are suitable for your situation.

Your Financial Situation

Your adviser should summarise your current financial situation, including income, expenses, assets, liabilities, and risk profile. This shows that proper fact-finding was conducted and that the advice is based on your actual circumstances. If this section is thin or missing, the advice may not be appropriate for you.

The Recommendations

This is the core of the SOA. Each recommendation should clearly state what product or strategy is being recommended, why it was chosen, what alternatives were considered, and how it aligns with your goals. The reasoning should be detailed and specific — not generic boilerplate.

Fee Disclosure

All fees, costs, and commissions must be clearly disclosed in a way that is easy to understand. Look for a fee table or structured breakdown showing upfront costs, ongoing fees, and any exit or switching costs. If the fee information is vague or hard to find, ask for clarification.

Risk Disclosure

The SOA should explain the risks associated with each recommendation, including what could go wrong and how that would affect your financial position. Risk disclosure helps you make an informed decision about whether to proceed.

Essential SOA Sections

A compliant Statement of Advice must include several essential sections. The executive summary provides an overview of the advice recommendations and key information. The client details section records the client's personal information, objectives, financial situation, and risk profile. The basis for advice section explains why the recommendations are appropriate for the client's specific circumstances, linking each recommendation to the client's objectives.

The recommendations section sets out the specific products, strategies, or actions recommended. The fees and costs section discloses all fees payable including advice fees, product fees, ongoing fees, and any indirect costs. The warnings section includes the general advice warning (if applicable), risk warnings, cooling-off rights, and the client's right to complain.

Common Section Errors

The most common errors in SOA sections include: inadequate basis for advice (failing to link recommendations to client circumstances), incomplete fee disclosure (missing indirect costs or ongoing fees), generic rather than personalised content, and insufficient warnings. Many SOAs use boilerplate language that does not adequately address the specific client's situation.

Another common issue is inconsistency between sections. For example, the executive summary may refer to recommendations not fully explained in the recommendations section, or the client's risk profile may be listed as "growth" but the recommended products are "conservative". Each section should be reviewed for internal consistency and alignment with the overall advice narrative.

DBFO Reforms and SOA Structure

The DBFO reforms have introduced more flexibility in SOA structure. The traditional format of a single comprehensive document is being supplemented by more modular approaches, where clients receive focused advice documents for specific decisions. Streamlined SOAs for simple advice do not require all the sections of a full SOA, reducing document length and complexity.

However, regardless of the format, every SOA must still contain all the information required by section 946A of the Corporations Act. The difference is in how that information is presented and how much detail is required. Simple advice may need less detail in the basis for advice section, while complex advice requires comprehensive documentation of the adviser's reasoning.

Frequently Asked Questions

Can an SOA be shorter than 10 pages?
Yes, particularly under the DBFO streamlined SOA provisions. Simple advice documents can be as short as 2-3 pages if they contain all required information. However, complex advice typically requires more comprehensive documentation.

Do all SOAs need an executive summary?
While not legally required, an executive summary is considered best practice and is included in most SOAs. It helps clients quickly understand the key recommendations and make informed decisions.

Should the SOA include product ratings or research?
Including product research and comparison information is recommended to demonstrate compliance with the best interests duty (particularly step 6). The SOA should clearly distinguish between factual product information and the adviser's recommendations.

How should ongoing fees be disclosed in the SOA?
Ongoing fees must be disclosed in dollar amounts (not just percentages) where possible. The SOA should show the total annual cost of the advice and products, including all upfront and ongoing fees. Fee disclosure statements must then be provided annually.

Regulatory Context

Consumers evaluating advice documents benefit from knowing the recent timeline. Since FOFA took effect in 2013, advisers have owed a best interests duty and been barred from conflicted remuneration. The DBFO reforms, phased through 2024-25, removed the Fee Disclosure Statement and simplified ongoing fee consents while clarifying how advice fees can be deducted from super. Further change is queued: the Quality of Advice Review’s proposals for simpler SOAs and a new adviser class were progressing through draft Tranche 2 legislation as of March 2025.