Annual Fee Consent Compliance for Australian Paraplanners

For paraplanners supporting Australian financial advisers, annual fee renewals have always required careful coordination. Yet following the implementation of the Delivering Better Financial Outcomes (DBFO) reforms in January 2025, the process has changed in an important way. While the reforms simplified documentation by combining requirements into a single framework, they also increased the compliance responsibilities attached to that process.

Rather than removing administrative work, the reforms shifted more accountability into one consolidated annual consent document. As a result, paraplanners now play a more central role in ensuring accuracy, evidence, and regulatory alignment.

Understanding how the revised process works and maintaining a structured compliance workflow has become essential for advice practices navigating Australia’s evolving ongoing fee arrangements.

Understanding the Shift Under DBFO Reforms

Before January 10, 2025, advisers managing ongoing fee arrangements generally issued two separate documents every year.

The first was the Fee Disclosure Statement (FDS), which outlined fees charged and services delivered during the previous 12 months. The second was a written client consent introduced after the Royal Commission reforms of 2021, allowing fees to continue being deducted from client product accounts.

While both documents served different purposes, managing them often created operational complications. Anniversary dates, renewal schedules, opt-in requirements, and signed authorities frequently became misaligned.

The Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024 addressed this issue by consolidating these obligations into a single annual document known as the Ongoing Fee Consent.

Instead of maintaining two separate workflows, practices now operate under a unified process that combines:

• Historical fee disclosures
• Records of services previously delivered
• Client consent for future fee deductions
• Forward-looking fee information for the next service period

Although documentation has become more streamlined, the expectations attached to this single document are significantly higher.

Regulatory guidance continues to place strong emphasis on accurate disclosures, sufficient evidence, and valid client authority.

By 2026, most Australian advice firms had transitioned clients onto this consolidated framework.

What Must Be Included in the Annual Fee Consent?

The updated consent process combines historical reporting and future authorization into one document, meaning every detail matters.

Current regulatory guidance requires inclusion of:

• Name and contact details of the fee recipient
• Services delivered during the previous 12 months
• Fees charged during the previous 12 months
• Services the client will receive over the next year
• Expected fees for the upcoming period
• Fee deduction timing and frequency
• Accounts from which deductions will occur
• Client signature and date, including approved digital execution methods
• Information explaining the client’s right to withdraw consent

One area that regularly creates compliance concerns involves forward-looking fee estimates.

Where fees are based on percentage structures or funds under management (FUM), practices should maintain clear evidence supporting assumptions and calculations. Fee estimates cannot appear arbitrary. Supporting records should explain methodology, projected balances, and assumptions used.

Without that evidence, even accurately prepared documents may face scrutiny.

A Practical Annual Fee Consent Checklist for Paraplanners

Paraplanners frequently serve as the final review layer before documents return to advisers for approval. That review process often prevents issues before they become compliance risks.

A consistent checklist can help reduce errors and create repeatable quality control across client files.

1. Verify Anniversary Date Alignment

Confirm that renewal dates match the original fee arrangement or documented annual review schedule.

Missed anniversary windows create more than administrative issues. Once timing requirements lapse, the authority to deduct fees may also expire.

2. Confirm Service Delivery Evidence

Every service recorded as completed should have supporting evidence.

This may include:

• File notes
• Meeting records
• Review correspondence
• Records of Advice (ROAs)
• Client communications

For example, if an ongoing service agreement promises quarterly reviews, the file should demonstrate that those reviews actually occurred.

A wording issue can often become an evidence issue.

3. Reconcile Fees Against Platform Reports

Fee disclosures should match actual amounts charged.

This requires checking platform reports from systems such as:

• HUB24
• Netwealth
• BT Panorama
• CFS Edge
• Macquarie Wrap

Even small discrepancies can become findings during audits or surveillance reviews. Mid-year rebates or adjustments should also be reflected accurately.

4. Review Forward Fee Calculations

If upcoming fees rely on estimates rather than fixed dollar amounts, supporting calculations should be retained.

Documentation should clearly show:

• Assumed FUM values
• Growth projections
• Applicable fee schedules
• Calculation methodology

Maintaining this evidence creates transparency and strengthens defensibility.

5. Validate Account Holder Authority

Fee deductions require approval from the correct account holder.

Additional attention may be required where:

• Superannuation accounts are involved
• Joint ownership structures exist
• Corporate trustees are included

Execution requirements should be checked carefully.

6. Confirm Signature and Audit Trail Integrity

Whether using wet signatures, DocuSign, or Adobe Sign, execution methods should provide complete audit records.

Executed copies should remain securely stored in the practice CRM with unaltered timestamps.

7. Review Withdrawal Language

Consent documents should clearly explain how clients may withdraw their consent.

Broad wording such as “contact us for changes” may not provide sufficient clarity.

Instructions should be specific and easy for clients to understand.

8. Cross-Check Against Code of Ethics Standard 7

Standard 7 requires fees and benefits to remain fair, reasonable, and representative of value delivered.

During review, paraplanners should assess whether the relationship between fees charged and services provided would withstand closer examination.

This serves as both a compliance and client-value check.

What ASIC Still Focuses On

Although the documentation framework has changed, regulatory focus areas remain consistent.

Historical surveillance activity has concentrated on three key themes:

Accuracy

Fees disclosed should precisely match fees charged.

Differences caused by rounding or overlooked fee rebates are generally viewed as avoidable issues.

Service Delivery

Services described in agreements should genuinely be delivered and supported by evidence.

Promises made to clients must align with actual activity.

Valid Authority

Every fee deducted from a client account requires active and valid consent.

Without proper authority, deductions become a serious compliance issue.

Previous reviews found a significant proportion of files contained disclosure or consent deficiencies. While DBFO simplifies documentation, it places greater scrutiny on the single annual consent process that remains.

Paraplanners increasingly serve as the final checkpoint before documents move forward.

What This Means for Paraplanning Teams

The revised framework may appear administratively simpler, but the underlying work remains detailed.

Instead of managing two separate processes, firms now operate under one annual deadline for each client relationship.

Missing that deadline has direct consequences.

For internal teams, workflows increasingly revolve around coordinated annual review cycles. For firms using outsourced paraplanning support, responsibilities should extend beyond SOA and ROA preparation to include annual consent requirements.

Australia’s ongoing fee arrangement rules leave little room for incomplete processes or assumptions.

Final Thoughts

The Annual Fee Consent and FDS Checklist is no longer a process built around managing two separate documents, but the consolidated framework now carries greater compliance significance than either requirement previously did on its own.

 A missed renewal anniversary, insufficient evidence of delivered services, or discrepancies between disclosed fees and platform reports can jeopardise a licensee’s authority to continue charging client fees. For paraplanning teams such as NCSGX, success lies in maintaining strong process discipline.

 Implementing a consistent and repeatable Annual Fee Consent compliance checklist for every client file helps transform regulatory obligations from a potential compliance risk into an efficient and reliable annual workflow.