The short answer
An Australian advice practice spends most of its hours on paperwork that proves good advice: file notes, statements of advice, reviews and the yearly written consent for each ongoing fee arrangement. Platforms such as Iress Xplan, Midwinter, AdviserLogic and Padua hold the client data and produce documents, and most practices should keep one as the record. Custom work pays where those platforms stop: AI drafted file notes and SOA first drafts in your house style, a consent renewal tracker that follows the 60 day and 150 day window, and dashboards that join platform and product data. Builds of this kind sit around $20,000 to $100,000 (AUD, ex GST) as a market range, not a quote.
Key takeaways
- Since 10 January 2025, ongoing fee arrangements no longer need a fee disclosure statement, but a written consent must still be signed each year in a window from 60 days before to 150 days after the reference day.
- Miss the consent window and the arrangement terminates; continuing to charge fees after that attracts civil penalties.
- The DBFO Act received Royal Assent on 9 July 2024 as Tranche 1. ASIC lists the remaining Quality of Advice Review measures as a second tranche, so check its status before you design around it.
- ASIC's REP 798 found AI governance at licensees was lagging adoption. Any AI note taker or SOA drafter needs adviser review and a record of what changed.
- AWLabs holds no AFSL. We build software; your licensee decides what advice and disclosure the law requires.
Where do the hours go in an advice practice?
Most of an adviser’s week goes on documenting advice rather than giving it: file notes after meetings, statements of advice, annual reviews and fee consents. Each document exists to show that the advice met the client’s objectives, financial situation and needs, and that the adviser acted in their best interests.
A typical client relationship generates:
| Stage | Document | Who usually prepares it |
|---|---|---|
| Discovery meeting | File note, fact find | Adviser, then client services |
| Strategy | Modelling, product research | Paraplanner |
| Recommendation | Statement of advice (SOA) | Paraplanner, adviser signs off |
| Implementation | Product applications, authorities | Client services |
| Each year | Review notes, record of advice where relevant, ongoing fee consent | Adviser and client services |
| Any time | Complaint record | Practice manager |
The bottleneck is usually the paraplanner and the turnaround from meeting to SOA. That is where software, and carefully governed AI, can save the most time.
This page is about ASIC licensed advice practices. If you are an APRA regulated bank, insurer or super fund, see our page on AI for financial services instead.
What do Xplan, Midwinter, AdviserLogic and Padua hold?
The advice platform is your record of clients, fact finds, modelling and documents, and in most practices it should stay that way. Iress describes Xplan as covering fact finds for individuals, trusts and businesses, advice workflows from onboarding to reviews, modelling, a client portal and integrations. Midwinter offers CRM, a dynamic fact find, product comparison, scaled advice, advice documents and a client portal, and publishes API documentation. AdviserLogic and Padua are other advice platforms built for the Australian market.
Licensees often choose the platform, or approve a short list. Before you build anything, find out:
- Which API or data export your platform and licence allow.
- Whether your licensee permits third party tools to read or write client data.
- Whether SOA templates are locked by the licensee or editable by the practice.
Those three answers decide whether a custom tool reads from the platform, writes back to it, or sits beside it.
What did the Delivering Better Financial Outcomes reforms change?
Tranche 1 of the DBFO reforms, Schedule 1 of the Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024, received Royal Assent on 9 July 2024 and changed fees, consents, financial services guides and conflicted remuneration. The main paperwork changes, as ASIC summarises them:
| Change | Start |
|---|---|
| FSG information can be published on your website instead of handed over | 10 July 2024 |
| Conflicted remuneration rules clarified | 10 July 2024 |
| Fee disclosure statement removed for ongoing fee arrangements; consent content changed; more flexible anniversary timing | 10 January 2025 for new arrangements, with transition for existing ones |
| Non ongoing fee consent content changed, including advice fees from super | 10 January 2025 |
| Informed consent before accepting certain insurance commissions | 9 July 2025 |
ASIC describes the remaining Quality of Advice Review recommendations as a second tranche of legislation. Treat any future change to the best interests duty or SOA requirements as unconfirmed until it is law, and design templates so they can change without a rebuild.
How should the ongoing fee consent work as a workflow?
Each year a client must sign a written consent within a window that opens 60 days before the reference day and closes 150 days after it; if that doesn’t happen, the arrangement terminates and fees must stop. ASIC’s INFO 286 explains that the reference day can be agreed with the client, provided it is earlier than the anniversary and disclosed before consent. Charging after termination attracts civil penalties.
The consent itself has mandatory content, including the fee recipient’s details, why consent is sought, the maximum period before consent ceases, the services, an estimate of each fee and how it was calculated, the frequency, a statement that the client can terminate at any time, and the date the arrangement ends if consent isn’t given.
A renewal tracker turns that into a daily list:
- Every arrangement with its reference day and window dates.
- Consents sent, opened, signed or outstanding, by adviser.
- Arrangements inside the last 30 days of the window, flagged red.
- Arrangements that lapsed, with a task to turn off fees at the product provider.
- An audit trail of what the client was sent and when they signed.
Most platforms track some of this. Practices with several advisers, or several licensee rule sets, often need it joined into one view.
AI file notes and SOA drafts: what must the adviser check?
AI can turn a recorded meeting into a structured file note and turn a strategy into a first draft SOA, but the adviser stays accountable for every word. ASIC’s guidance on SOAs covers required content, especially disclosure of remuneration, commissions and conflicts. Those are exactly the parts a model can get wrong.
Build the review into the tool, not around it:
- Recording consent captured at the start of the meeting.
- Transcript and draft file note shown side by side, with each point linked to where it was said.
- Draft SOA generated in the licensee’s template, with figures pulled from the platform rather than from the transcript.
- Required sections checked for presence, such as fees, commissions, conflicts and the basis of advice.
- Adviser edits tracked, approval recorded, final document filed in the platform.
ASIC’s REP 798, released in October 2024, reviewed 23 AFS and credit licensees and found governance arrangements lagging AI use. Expect your licensee to ask which model processed client data, where it was hosted and how errors are caught. Our AI governance service and our guide to AI hallucinations cover the controls.
Do client portals and data collection still need building?
Often not from scratch: Xplan and Midwinter both offer client portals, so start there. Custom work makes sense when you want one place for documents from several sources, such as fact find updates, super statements, tax returns and signed consents, with reminders and progress the client can see. Our customer portal guide covers design and security choices.
What do complaint records need to show?
AFS licensees must have internal dispute resolution that meets ASIC’s RG 271 and must be members of AFCA. RG 271, issued in September 2021, sets out how firms record and respond to complaints and the timeframes for doing so, and most firms also report IDR data to ASIC. A complaints register linked to the client file, with dates and outcomes, gives your licensee what it needs and shows patterns early.
Can you see the whole practice in one dashboard?
Usually only with some joining work, because revenue, client activity and product data sit in different systems. The platform knows clients and reviews, the product providers know balances and fees deducted, the accounting system knows what was actually received, and the consent tracker knows which arrangements are at risk.
A practice dashboard that joins those sources answers questions principals ask every month:
- Which advisers have reviews overdue, and by how many clients?
- Which ongoing fees were deducted for arrangements that have lapsed?
- How long does an SOA take from meeting to signature, by paraplanner?
- Which clients have had no contact in 12 months?
The second question matters most. Fees charged after an arrangement terminates are a remediation problem, and a nightly check that compares lapsed arrangements with provider fee data catches it early. This is data analytics work rather than AI, and it often pays for itself first.
What do typical builds cost?
These are indicative AUD market ranges, ex GST, not quotes. Expeed publishes $15,000 to $40,000 for simple internal tools and $40,000 to $150,000 for mid complexity systems.
| Build | Includes | Indicative range |
|---|---|---|
| Ongoing fee consent tracker over platform data | Window calculations, e-signature, reminders, lapse tasks, audit trail | $20,000 to $50,000 |
| AI file note and SOA first draft generator | Transcription, house templates, section checks, adviser review, hosting | $40,000 to $100,000 |
| Client data collection portal | Document requests, uploads, reminders, platform sync | $25,000 to $60,000 |
The AI build costs more because of evaluation: testing drafts against real past SOAs, with paraplanners scoring them, before anyone relies on it.
How AWLabs approaches advice practice builds
We start with a Development Consult to hear where the paperwork backs up. If a build is worth doing, a paid Discovery Audit checks your platform’s API, your licensee’s rules on third party tools and your templates, then you receive a fixed price Schedule of Work with three options: The Minimum, The Recommended and The Complete. Senior engineers lead every build, with updates every Tuesday and Friday, Sydney time.
AWLabs has not yet delivered a project for an advice practice, and we hold no AFSL. This page is general information, not legal or financial advice. Your licensee and compliance advisers decide what your obligations require. See our wider finance and fintech work.
Frequently asked questions
What is the best financial planning software in Australia?
There isn't one answer. Iress Xplan is common in larger practices and licensees, Midwinter offers advice software with a published API, and AdviserLogic and Padua are other Australian options. Your licensee often sets or limits the choice. Pick on how well it fits your advice process and how open its data is, because that decides what you can build around it later.
Can AI write a statement of advice?
It can produce a first draft from the fact find, the meeting transcript and your strategy notes, in your template. It cannot decide what is in the client's best interests. The adviser must check every recommendation, figure and disclosure before the SOA goes out, and the practice should keep the draft, the edits and the approval.
Is it legal to record client meetings for AI notes?
Recording laws differ between states and between phone, video and in person meetings, so get advice for the states you work in. As a practical rule, tell clients you are recording, explain why and how the recording is stored, and get their agreement on record at the start of every meeting.
What changed for fee disclosure statements?
Schedule 1, Part 2 of the DBFO Act removed the fee disclosure statement for ongoing fee arrangements from 10 January 2025, with transition rules for existing arrangements. The annual written consent remains, with mandatory content such as the services, an estimate of each fee and a statement that the client can terminate at any time.
How do complaints and AFCA fit into the software?
AFS licensees must have internal dispute resolution that meets ASIC's RG 271 and must be AFCA members. A complaints register linked to the client file, with dates for acknowledgement and response, makes those timeframes visible and gives your licensee the data it reports.
Have you built software for financial advice practices?
No. AWLabs has not delivered a project for a financial advice practice or licensee, so we won't claim sector experience. We bring AI, integration and workflow engineering, and we work to your licensee's compliance requirements.
This page is general information about Australian law and regulation, current at the date shown. It is not legal advice. Get advice from a qualified lawyer about your circumstances.
Sources
- Delivering Better Financial Outcomes (DBFO) package, ASIC
- FAQs: Ongoing fee arrangements and consents (INFO 286), ASIC
- Fees, ASIC
- Statement of Advice, ASIC
- Acting in the client's best interests, ASIC
- REP 798 Beware the gap: Governance arrangements in the face of AI innovation, ASIC
- Dispute resolution, ASIC
- RG 271 Internal dispute resolution, ASIC
- Xplan financial advice software, Iress
- Midwinter financial planning software, Midwinter
- Custom software development cost in Australia 2026, Expeed Software