RG 175 — SOA Content Requirements

What ASIC requires your Statement of Advice to include

What is RG 175?

Regulatory Guide 175 (RG 175) is ASIC's key guidance document on AFS licensing, including detailed requirements for what a Statement of Advice must contain. It is one of the primary regulatory references AdviserCheck uses when analysing SOA compliance.

Key SOA Content Requirements Under RG 175

• Client circumstances — the SOA must reflect the client's personal situation (RG 175.74)
• Basis for advice — clear reasoning linking recommendations to client goals (RG 175.80)
• Clear language — SOAs must be written in clear, understandable language (RG 175.118)
• Fee disclosure — all fees, commissions, and costs must be itemised (RG 175.123)
• Commission disclosure — commissions and other benefits must be disclosed (RG 175.123(f))
• Risk profile — suitability must be documented with risk profile alignment (RG 175.124)
• Remuneration — adviser remuneration must be clearly disclosed (RG 175.125)
• Associations — relationships with product issuers must be disclosed (RG 175.126)
• Conflicts — conflicts of interest must be managed and disclosed (RG 175.127)
• Cooling-off rights — cancellation rights must be disclosed (RG 175.130)

How AdviserCheck Checks RG 175 Compliance

Each SOA uploaded to AdviserCheck is analysed across six layers, with specific checks mapped to RG 175 requirements. The platform's regulation reference library includes descriptions for RG 175.74 through RG 175.138, providing context for every finding in the compliance report.

Overview of RG 175

ASIC's Regulatory Guide 175 (RG 175) is titled "Licensing: Financial product advisers — conduct and disclosure." It provides ASIC's interpretation of the licensing, conduct, and disclosure obligations that apply to financial advisers under the Corporations Act. While not legally binding in itself, RG 175 represents ASIC's view of how the law should be applied, and courts give significant weight to regulatory guides.

RG 175 covers four main areas: the licensing process for financial advisers, organisational competence requirements (responsible managers, training, supervision), the conduct obligations when providing advice (best interests duty, appropriate advice duty), and disclosure requirements (SOA content, fee disclosure, financial services guide). Advisers who follow RG 175 are likely to meet their legal obligations.

SOA Requirements Under RG 175

RG 175 provides detailed guidance on what your SOA should contain. The guide emphasises that the SOA must be clear, concise, and effective — not a legal document full of jargon. Key requirements include: a summary of the advice and how it meets your goals, a clear statement of fees in dollar terms, disclosure of any commissions or benefits, explanation of alternatives considered, and information about your rights including cooling-off and complaints.

RG 175 also provides examples of good practice. For instance, a good SOA will use plain language, present fee information in a clear table, explain why the recommended option was chosen over alternatives, and show how the advice is linked to the client's stated goals. ASIC has published example SOAs (INFO 267) that demonstrate these principles in practice.

Using RG 175 as a Consumer

You can use RG 175 as a checklist to evaluate your SOA. Compare your document against the guide's recommendations: does it include a clear summary? Are fees shown in dollar amounts? Are alternatives discussed? Are risks disclosed? If your SOA falls short in any area, you have grounds to request amendments.

ASIC updates RG 175 periodically to reflect changes in the law and regulatory practice. The most recent update reflects the DBFO reforms (2024-25). Advisers should be working to the current version of the guide. If you want to read the full guide, it is available on ASIC's website at https://asic.gov.au.

Frequently Asked Questions

Is RG 175 legally binding?
No, RG 175 is a regulatory guide that sets out ASIC's interpretation of the law. It is not legally binding in itself, but courts give it significant weight. Following RG 175 is strong evidence that an adviser has met their legal obligations.

Does RG 175 apply to all financial advice?
RG 175 applies to financial product advice provided by AFSL holders to retail clients. It covers both personal advice and general advice, but the requirements differ depending on the type of advice provided.

How often is RG 175 updated?
ASIC updates RG 175 when there are significant changes in the law or regulatory practice. The guide was most recently updated to reflect the DBFO reforms and will be updated again as Tranche 2 reforms are implemented.

Can I use RG 175 to challenge my SOA?
Yes. If your SOA does not meet the standards described in RG 175 — such as missing fee disclosure or lack of personalisation — you can use the guide as the basis for requesting an amended SOA. ASIC's guidance supports your right to a compliant advice document.

A Decade of Advice Regulation

The rules governing financial advice have been rewritten repeatedly since 2012. This timeline shows what changed, and when.

Date	Reform	Impact on Consumers
July 2012	FOFA enacted	Best interests duty (s961B), ban on conflicted remuneration, opt-in for ongoing fees
July 2013	FOFA mandatory	Full compliance required — advisers must act in your best interests
July 2016	Accountants' exemption repealed	Accountants need AFSL to give SMSF advice, increasing consumer protection
2018-2023	Royal Commission + response	FEAR Act (2019) — higher penalties, breach reporting, enforceable director duties
Dec 2022	QAR Final Report	22 recommendations including simplified SOAs, new adviser class, streamlined best interests duty
July 2024	DBFO Tranche 1	FSG website disclosure option, conflicted remuneration clarification
Jan 2025	DBFO changes commence	Fee Disclosure Statements removed, streamlined ongoing fee consents, legal clarity for super advice fee deductions
Mar 2025	DBFO Tranche 2 draft	SOA rationalisation, collective charging for super, super fund targeted prompts. Best interests duty modernisation and new adviser class still in development.

Compiled from ASIC regulatory guidance, Treasury’s DBFO implementation materials, the FAAA DBFO Hub and the APESB QAR review.

Is a Table of Contents Required in a SOA?

No. RG 175 does not mandate a table of contents, but it requires the SOA to be clear, concise and effective. A table of contents is recommended for longer documents to help you navigate fee disclosure, risk and conflicts, but its absence alone is not a compliance breach.