AFSL Responsible Manager RG105

What is a Responsible Manager?

Responsible Managers are the people that a licensee appoints to demonstrate to ASIC that it has the knowledge, skills and experience required to provide the financial services it is authorised to on its Australian Financial Services licence (AFSL). They are responsible for ensuring that how a licensee delivers its financial products and services complies with its general obligations of AFSL holders.

These are detailed in s912A of the Corporations Act, and ASIC offers regulatory guidance in RG 104 Licensing: Meeting the general obligations.

RG 105 Licensing: Organisational Competence contains detailed information about who is eligible to be nominated as a Responsible Manager, and ongoing professional development requirements.

Download our RG105 brochure

A Responsible Manager is a key individual within a business. They can supervise operations in a few ways:

  • Oversee the conduct of authorised representatives who trade financial instruments or provide advice
  • Be a company director appointed as a responsible manager
  • Serve purely as a responsible manager, monitoring licensing compliance and conduct risks.

Checking the credentials of Responsible Managers is one aspect of how ASIC evaluates whether a licensee is ‘competent’ to provide the financial services specified under its AFSL. In the course of assessing licensee compliance with the ‘organisational competence obligation’ in RG 105, ASIC will expect that Responsible Managers:

  • are directly responsible for significant day-to-day decisions about the ongoing provision of financial services;
  • are of good fame and character; and
  • have the requisite knowledge, skills and experience.

How many Responsible Managers a licensee should ideally appoint varies and depends on the nature, scale and complexity of the business. If a licensee is heavily dependent on the competence of one or two Responsible Managers, e.g. in a small organisation with one or two principals, then ASIC will generally impose a ‘key person’ condition on the licence.

Find out more in our Frequently asked questions

Are you applying for an AFS Licence? Refer to ASICs AFS Licensing Kit for your obligations.

For information on relevant legislation and important information surrounding your licensing obligations please refer to ASIC’s Regulatory Index.

Aspiring to become a Responsible Manager?

ASIC expects Responsible Managers to play an active role in fostering a compliance culture in their business and in the financial services industry more broadly.

Our Responsible Manager Fundamentals course is designed for aspiring responsible managers working for an AFS licensee.

Get the lowdown on what the Responsible Manager role entails and the industry regulations licensees must comply with.

Download our RM Fundamentals brochure

Ready to be a Responsible Manager?

Responsible Managers must have the relevant knowledge and experience to be eligible to be nominated.

How can FEP assist with the nomination process?

We can assist with:

What if your Responsible Manager’s Skills component includes years of recent overseas experience?

Those planning to take on the role of a Responsible Manager for an AFS licensee or who need a refresher on Australian regulations can complete our Regulation of Australian Financial Services course.

Download our RG105 brochure

Already a Responsible Manager needing CPD?

Among measures for preserving organisational competence, ASIC requires licensees to maintain and update the knowledge and skills of their Responsible Managers (RG 105.7).

Our online CPD assists Responsible Managers in meeting their CPD obligation with new courses on topical issues released every year.

Our 2021 program will equip and empower the key people in your business to bring to life the frameworks and activities your organisation needs to effectively manage its non-financial risk.

We also offer tailored, in-house Responsible Manager workshops. Contact us at for further information.

Download our program brochure

Want to equip others in your organisation?

Our Compliance Fundamentals course explains how Australian Financial Services licensing works, examines the main regulatory guides, and suggests real-world tools to use in your workplace.

This course is suitable for the following roles, operating in the context of an Australian Financial Services (AFS) licence:

  • Compliance professionals
  • Licensees seeking refresher training on their obligations
  • Professional services consultants advising licensees, including legal practitioners, accountants, and corporate advisers.
Download our Compliance Fundamentals brochure

What is non-financial risk? 

You might have heard a lot of financial regulator talk about non-financial risk lately. Not sure what that means? Check out some highlights from our current programs and CPD topics to help get your organisation’s non-financial risk training sorted.

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