Royal Commission Recommendations — Progress Update
Key takeaways:
- The Royal Commission into Misconduct in Banking, Superannuation and Financial Services (2019) made 76 recommendations
- Significant progress has been made on banning grandfathered commissions, strengthening the best interests duty, and improving accountability
- Key reforms still in progress include further simplification of SOA requirements and enhanced consumer dispute resolution
- The DBFO reforms represent the next phase of implementing the Commission's vision for a more professional advice industry
How the Hayne Royal Commission recommendations continue to shape financial advice regulation
Background
The Hayne Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry delivered 76 recommendations in February 2019. Several recommendations directly affected financial advice including the ban on grandfathered commissions, the requirement for annual fee renewal, and increased accountability for AFSL licensees.
Implemented Reforms
Key recommendations that have been implemented include the banning of grandfathered conflicted remuneration, the introduction of the reportable situations regime, the extension of the AFCA jurisdiction, and the introduction of the Design and Distribution Obligations. These reforms have fundamentally changed how advice is delivered and documented.
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Ongoing Reforms
The DBFO Act represents the next phase of reform stemming from the Royal Commission findings. Changes to advice documentation, FSG requirements, and ongoing fee arrangements continue to evolve. Advisers should stay informed about these developments as they affect compliance obligations.
Impact on Advice Practices
The post-Royal Commission regulatory environment requires advisers to maintain higher standards of documentation and compliance than ever before. Regular file reviews and robust compliance processes are essential for meeting these heightened expectations.
Reforms Already Implemented
Since the Royal Commission delivered its final report in February 2019, substantial progress has been made on implementing its 76 recommendations. Key reforms fully implemented include: the banning of grandfathered commission arrangements for financial advice (effective 1 January 2022), the strengthening of the best interests duty (s961B) and appropriate advice duty (s961G), the introduction of the Banking Executive Accountability Regime (BEAR) and its successor the Financial Accountability Regime (FAR), and the establishment of AFCA as a one-stop dispute resolution body.
Other major reforms implemented include: the removal of the exemption for general advice from the best interests duty, the requirement for annual fee disclosure statements and renewal notices, the banning of hawking of financial products, and increased ASIC enforcement powers and penalties. The FASEA education standards raised the minimum qualification requirements for financial advisers, contributing to the professionalisation of the industry.
Reforms Still in Progress
Several Royal Commission recommendations are still being implemented through the DBFO reforms and other legislative processes. These include: further simplification of SOA requirements to make advice documents more accessible to consumers, streamlined fee disclosure processes, and enhanced powers for AFCA to handle complex disputes more efficiently.
The government has also been working on recommendations related to the design and distribution obligations (DDO) for financial products, which require product issuers to target products to appropriate consumer segments. While DDO was implemented for most financial products from October 2021, its application to financial advice continues to evolve. The Quality of Advice Review (QAR) and its successor DBFO reforms are directly addressing remaining recommendations about advice accessibility and affordability.
How Reforms Affect Consumers
For consumers, the Royal Commission reforms have delivered meaningful improvements. Fee disclosure statements make it easier to understand what you are paying for advice. The annual renewal requirement means you must explicitly opt in to ongoing advice arrangements rather than paying fees indefinitely. The banning of grandfathered commissions means your adviser cannot receive hidden ongoing payments from product providers.
If you believe an adviser has breached their obligations under the post-Royal Commission framework, you have stronger avenues for recourse. AFCA can handle complaints about financial advice up to $1 million (with a $5.36 million cap for superannuation complaints), and the increased penalties for misconduct provide a stronger deterrent against inappropriate advice. The Financial Advisers Register allows you to check any adviser's qualifications, experience, and disciplinary history before engaging them.
Frequently Asked Questions
Are all Royal Commission recommendations implemented?
Not all. Most recommendations are implemented or in the process of implementation through the DBFO reforms. Some recommendations, particularly those requiring complex legislative changes or international coordination, are still being progressed. Check the Treasury website for the latest implementation status.
How do I know if my adviser is compliant with post-Royal Commission requirements?
Check the Financial Advisers Register for your adviser's current status. Your SOA should clearly disclose fees, scope of advice, and any conflicts of interest. You should receive annual fee disclosure statements and renewal notices. If any of these are missing, raise the issue with your adviser.
What is the Quality of Advice Review and how does it relate to the Royal Commission?
The Quality of Advice Review (QAR) was commissioned by the government in 2021 to identify opportunities to improve the accessibility and affordability of financial advice while maintaining consumer protections. Its recommendations fed into the DBFO reforms, which represent the next phase of advice reform following the Royal Commission.
Has the Royal Commission improved financial advice quality?
Evidence suggests yes. The proportion of advice files found to be compliant has increased, consumer complaints about advice have declined, and industry professionalism has improved through higher education and ethical standards. However, the advice gap (consumers unable to access affordable advice) has widened due to increased compliance costs.
ASIC's Recent Crackdown, By Theme
The numbers. Financial year 2024-25 delivered 19 criminal convictions, 38 new civil proceedings, $104.1 million in penalties and bans or restrictions against 58 individuals or companies. Investigation volume rose roughly 50% on the prior year — evidence, in ASIC's words, of a "more confident and ambitious regulator."
Failed investment schemes. The Shield Master Fund episode dominated: receivers were appointed in 2024-25 amid concerns about inappropriate advice and inadequate disclosure, and the fund was wound up. Four MWL Financial Services advisers were banned for 4–8 years in 2025 for steering clients into it against their best interests.
Dishonest operators. Glenda Rogan copped a 10-year ban in 2025 for funneling $14.8 million of client funds into a cryptocurrency investment scam; Barry King was permanently banned the same year for dishonest conduct, misuse of client funds and providing false documents.
Systemic breaches. Fees-for-no-service failures triggered multiple actions against licensees and advisers — Crown Wealth Group director Andrew Moore was banned for failing to report such conduct — while licensees including Skye Money and Smart Financial Capital paid $31,300 infringement notices for allowing unregistered advisers to operate.
ASIC additionally flags unscrupulous models that target superannuation savings through high-pressure selling and promises of superior returns.
Source material: ASIC Annual Report 2025; ASIC Financial Advice Update, August 2025.
Major Reforms That Shaped Today’s Rules
From FOFA to DBFO, each milestone below altered consumer protections in practical ways. Scan it to place your own advice document in context.
| 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. |
Sourced from ASIC, Treasury DBFO documentation, FAAA and APESB publications.
Verifying Advice in the Post–Royal Commission Era
This page explains the rule; AdviserCheck applies it. Our engine encodes FOFA obligations, the s961B best interests duty, RG 175 content standards and DBFO requirements into structured checks, then runs three independent AI models over your document. What reaches you is a short list of gaps that matter, each tied back to the obligation behind it. Put the rules to work on your own document — the first check is free.
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Try AdviserCheck FreeLast updated: 2026-09-12. This guide is for informational purposes only and does not constitute legal advice.