Do fees and commissions have to be shown in dollars in an SoA?
Yes, in most cases. Sections 947B(2)(h) and 947C(2)(i) require the amounts of remuneration, commission and other benefits that could influence the advice, and of the adviser's other interests, to be stated in dollars, and s 947D(2)(d) does the same for switching costs. A percentage or a calculation method is allowed only under an ASIC determination, usually with worked dollar examples.
Checked against the sources listed on this page on 11 October 2026. General information, not legal advice: your licensee’s own requirements come first.
What the law says
An SoA must include information about any remuneration, including commission, or other benefits that the adviser, the licensee and the other people listed are to receive and that "might reasonably be expected to be or have been capable of influencing the providing entity in providing the advice" (s 947B(2)(d) for a licensee, s 947C(2)(e) for an authorised representative). It must also disclose other interests, and associations with product issuers, that could have the same effect (s 947B(2)(e) and s 947C(2)(f)).
For that information, s 947B(2)(h) and s 947C(2)(i) say that, unless in accordance with the regulations, any amounts are to be stated in dollars. The rule covers the remuneration and benefits, and the other interests in s 947B(2)(e)(i) and s 947C(2)(f)(i). Regulation 7.7.10A modifies the same paragraphs so that the information must be stated as amounts in dollars unless the regulations and a determination by ASIC allow otherwise.
The exception is narrow. ASIC can determine, for a compelling reason, that stating an amount in dollars is not possible, would impose an unreasonable burden, or would not be in the interests of clients (reg 7.7.11(2) and reg 7.7.11B for a licensee, reg 7.7.12(2) and reg 7.7.13 for an authorised representative). Only then may the SoA describe the amount as a percentage of a specified matter or, failing that, describe how it is calculated, and either way it includes worked dollar examples unless that is inappropriate. A determination must be in writing and published in the Gazette. RG 175.118 points to Regulatory Guide 182 for more on the dollar disclosure rules and ASIC relief.
The same rule applies to switching advice. The charges for leaving the old product, the charges for the new one and the benefits the client may lose are stated in dollars (s 947D(2)(d)), with the same narrow exception (reg 7.7.13A and reg 7.7.13B).
Payments for referring the client are disclosed too: remuneration, including commission, and other benefits a person has received or is to receive for referring the client (reg 7.7.11(1) for a licensee, reg 7.7.12(1) for an authorised representative).
ASIC's guidance on what to include and how to present it:
- Upfront, trailing and "soft" dollar commissions are all included (RG 175.109).
- The information should be in one place in the SoA, presented so the client can understand it (RG 175.119).
- Ranges, rates, comparisons, simple tables and formulas should normally be included, and "It is insufficient to merely state in the SOA that remuneration, a commission or other benefit will or may be received and that clients can ask for further details to be provided" (RG 175.121).
- Where a commission must be disclosed, the SoA should generally include a clear statement of how it is calculated (RG 175.122).
ASIC's view is that the SoA should normally include all the remuneration, commission and other benefits for the advice, except where, for example, the payment does not depend in any way on whether the client follows the advice (such as an hourly fee the client pays regardless) or the benefit is rebated in full to the client (RG 175.112).
What it looks like in an SoA
An example of a fees section, with brackets for what each SoA fills in. The wording is illustrative, not a prescribed form.
| Fee or benefit | Amount | Who pays | Who receives it |
|---|---|---|---|
| Advice preparation fee | [amount in dollars] | You | [licensee name] |
| Implementation fee | [amount in dollars] | You | [licensee name] |
| Ongoing advice fee | [amount in dollars] a year, deducted [monthly] from [account] | You | [licensee name], of which [adviser or practice] receives [amount in dollars] |
| Insurance commission | [amount in dollars] in the first year and [amount in dollars] a year after that, on a premium of [amount in dollars] | [insurer name] | [licensee name], of which [adviser or practice] receives [amount in dollars] |
| Referral payment | [amount in dollars] | [licensee or practice] | [referrer name] |
Each commission row also says how it is calculated, for example "[percentage] of the annual premium", alongside the dollar amount rather than in place of it.
Common mistakes
- A percentage with no dollar amount. "Ongoing fee of [a percentage] of your balance" on its own does not meet s 947B(2)(h) or s 947C(2)(i). Work out the amount from the balance in the SoA.
- Commission described, not quantified. Saying a commission "may be received" and that the client can ask for details is what ASIC calls insufficient (RG 175.121).
- Fees scattered through the document. ASIC expects the remuneration information in one place (RG 175.119).
- A referral payment left out. It is required by reg 7.7.11(1) or reg 7.7.12(1), even where the client pays nothing extra for it.
- Switching costs without dollars. Exit and entry charges in a switch are dollar amounts under s 947D(2)(d), the same as fees.
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