Annual review template: renewing an ongoing fee arrangement and recording the review
The law does not require an annual review meeting. It requires something that usually happens at one: if a client pays an ongoing fee, their written consent has to be renewed every year or the arrangement ends. This template records the consent, the review and what comes next.
Checked against the sources listed on this page on 7 October 2026. General information, not legal advice: your licensee’s own requirements come first.
Is the client on an ongoing fee arrangement?
An ongoing fee arrangement is one where a client who received personal advice as a retail client agrees to pay a fee, however described, over a period of more than 12 months (s962A(1) and (2)). Three kinds of arrangement are not: paying a fixed, specified fee for past advice by instalments over a fixed period, with no amount tied to the funds invested and no opt-out (s962A(3)); one where the only fee is an insurance premium (s962A(4)); and product fees such as a fund’s own administration fee (s962A(5) and reg 7.7A.10).
What the consent must contain
Before asking for consent, the fee recipient must give the client, in writing, each of the following (s962G(2)). The consent must then be in writing, be for the arrangement to be entered into or renewed and for the disclosed fees to be charged, be signed and dated by the client, and be held by the fee recipient (s962G(1)). If the Minister has approved a form for the consent, it must be given in that form (s962Y).
- (a)
The name and contact details of the fee recipient.
Where this comes from: s962G(2)(a).
- (b)
Why the consent is being sought.
Where this comes from: s962G(2)(b).
- (c)
The maximum period until the consent stops having effect.
Where this comes from: s962G(2)(c).
- (d)
The services the client will be entitled to receive in that period.
Where this comes from: s962G(2)(d).
- (e)
Each ongoing fee for the period: the amount, or if it cannot be worked out yet, a reasonable estimate and how the estimate was made.
Where this comes from: s962G(2)(e).
- (f)
How often the fees are charged.
Where this comes from: s962G(2)(f).
- (g)
That the client can end the arrangement at any time.
Where this comes from: s962G(2)(g).
- (h)
That if consent is not given, the arrangement ends and no further advice is given or fee charged under it.
Where this comes from: s962G(2)(h).
- (i)
The date the arrangement will end if consent is not given.
Where this comes from: s962G(2)(i).
- (j)
Anything else the regulations prescribe.
Where this comes from: s962G(2)(j).
When the consent must be renewed
Each consent has a reference day: the day the consent specifies, if it specifies one, or otherwise the anniversary of the day the arrangement was entered into (or, after the first renewal, the anniversary of the previous reference day), whichever is earlier (s962H(2)). A new consent can be given from 60 days before that day until 150 days after it. If none is given in that window, the consent stops having effect 150 days after the reference day (s962H(1)).
Without a current consent the arrangement terminates (s962F). The fee recipient must not then charge a fee that purports to be an ongoing fee under it (s962Z), and any obligation to keep providing services that depended on the fee ends with it (s962ZA). The client can also end the arrangement at any time by written notice (s962J).
If the fee is deducted from the client’s account
Deducting the fee from a product account needs its own written consent from the account holder, with the s962G(2) disclosures, the account holder’s name and account number, each amount or a reasonable estimate, a signature and a date (ss962R, 962S and 962T). Every holder of a joint account must consent. The account holder can withdraw or vary that consent at any time in writing, and you must confirm receipt within 10 business days (s962U). The deduction consent stops having effect 150 days after the anniversary of the day the arrangement was entered into, when the arrangement ends, or when a new deduction consent is given (s962V).
Records to keep
The fee recipient must keep records that show its compliance can be readily ascertained (s962X). Regulation 7.7A.11AA lists them, including each consent and the matters disclosed before it, any notice from the client electing to renew, not to renew or to terminate, each deduction consent and each withdrawal or variation, and the date and basis on which the arrangement terminated.
After the review: SoA or Record of Advice?
If the review leads to new advice, the client may not need a full Statement of Advice. A Record of Advice is allowed for further advice where you have already given the client an SoA setting out their relevant circumstances, those circumstances are not significantly different now, and the basis of the new advice is not significantly different either (s946B(2) as substituted by reg 7.7.10AE). The client must be given the remuneration, interests and any switching information at the time or as soon as practicable after (s946B(3)), and the record must be kept for 7 years (reg 7.7.09(3)). If the client’s circumstances have changed significantly, the new advice needs a Statement of Advice.
Questions advisers ask
Is an annual review meeting a legal requirement?
No. What the law requires for a client on an ongoing fee arrangement is a renewed written consent each year (s962F to s962H). The review meeting is how most practices deliver the services the client is paying for and collect the consent.
When does an ongoing fee consent expire?
A new consent can be given from 60 days before the consent’s reference day until 150 days after it. If none is given, the consent stops having effect 150 days after the reference day, and the arrangement terminates (s962H and s962F). The reference day is the day the consent specifies or the anniversary date, whichever is earlier.
What must be disclosed before asking for ongoing fee consent?
The ten matters in s962G(2): who the fee recipient is, why consent is sought, how long it lasts, the services, each fee or a reasonable estimate, how often fees are charged, that the client can end the arrangement at any time, that it ends if consent is not given, the date it would end, and anything the regulations add.
Do I need a separate consent to deduct fees from the client’s super or platform account?
Yes. Deductions from an account need a written consent from each account holder that meets s962T, separate from the consent to the arrangement itself (ss962R and 962S).
Can I use a Record of Advice after the annual review?
Yes, if the client’s relevant circumstances and the basis of the advice are not significantly different from those in their last SoA (s946B(2) as substituted by reg 7.7.10AE). Otherwise the new advice needs a Statement of Advice.