Record of Advice template, and when you can use one instead of an SoA
A Record of Advice is the shorter document the law allows instead of a Statement of Advice in three situations. This page sets out when each applies and what the record must contain, and the Word template covers all three.
Checked against the sources listed on this page on 3 October 2026. General information, not legal advice: your licensee’s own requirements come first.
When can you give a Record of Advice instead of an SoA?
The starting point is section 946A of the Corporations Act: personal advice to a retail client needs a Statement of Advice. Three exceptions let you keep a record of the advice instead.
| Situation | When it applies | What the client must be given | Where it is in the law |
|---|---|---|---|
| Further advice | You have already given this client an SoA, their relevant circumstances are not significantly different, and the basis of the new advice is not significantly different either. | Your remuneration, interests and associations (and the switching information, if you recommend replacing a product), at the time or as soon as practicable after. The record itself if they ask. | s946B as substituted by reg 7.7.10AE; content in reg 7.7.09 |
| Small investment | The advice is about investing or disposing of no more than $15,000, and is not about a derivative, general insurance, life risk insurance, or a super product or RSA the client does not already hold. | A copy of the record, with your remuneration and conflicts information, when or as soon as practicable after the advice, and before any further related service. | s946AA; threshold in reg 7.7.09A; content in reg 7.7.08C |
| No recommendation to buy or sell | The advice gives no recommendation or opinion on acquiring or disposing of a specific product, or on changing an investment strategy or contribution level for a product the client holds, and no one listed in s946B(7)(b) is paid for the advice itself. | Your remuneration and conflicts information, in the same communication as the advice. The record itself if they ask. | s946B(7) to (9); content in reg 7.7.10AAA |
If the advice fits none of the three, it needs a Statement of Advice. The small investment threshold has its own counting rules in reg 7.7.09A: for super, managed investment schemes and instalment warrants, include what the client has committed to over the next 12 months; add joint holdings together; and if the value cannot be worked out, treat the advice as over the threshold.
Statement of Advice vs Record of Advice
| Statement of Advice | Record of Advice | |
|---|---|---|
| When it is needed | Personal advice to a retail client, unless an exception applies (s946A). | Only where one of the three exceptions above applies. |
| What it must contain | The advice; the basis for it; your name and contact details; remuneration and other benefits; interests and associations; any warning s961H requires; and the switching information where s947D applies (s947B or s947C). | The advice, or brief particulars of the recommendations and their basis; your remuneration and conflicts information; and the switching information where relevant (regs 7.7.09, 7.7.08C and 7.7.10AAA). |
| Form | Titled “Statement of Advice” at or near the front, and worded and presented in a clear, concise and effective manner (s947A, s947B(6)). | For further advice, any form: the regulation’s own example is “a tape recording” (reg 7.7.09(2)). |
| When the client gets it | When, or as soon as practicable after, the advice is given, and before any further related service (s946C). | Small investment advice: a copy, when or as soon as practicable after the advice. Further advice and no-recommendation advice: on request. |
| How long it is kept | 7 years after it is given (reg 7.7.09C). | Further advice: 7 years (reg 7.7.09(3)). A client can ask for a copy for 7 years after the advice (regs 7.7.05 and 7.7.08). |
What a Record of Advice must contain
The template has six parts. Parts 3 to 5 are what the regulations require. Parts 1, 2 and 6 are not set out in the law, but they are what a reviewer looks for first: they show the record was the right document for this advice.
- 1
Who and when: the client, the adviser, the licensee or authorised representative, and the date the advice was given.
Where this comes from: Good practice.
- 2
Which exception applies, and the facts that show it does: the earlier SoA and why circumstances have not significantly changed; the amount and product type for a small investment; or why no product was recommended.
Where this comes from: Good practice. It evidences the conditions in s946B(2), s946AA(1) or s946B(7).
- 3
The advice: either the advice itself, or brief particulars of the recommendations and the basis on which they were made.
Where this comes from: Required: reg 7.7.09(1), reg 7.7.08C(2)(a), reg 7.7.10AAA.
- 4
Remuneration, other benefits, interests and associations that might reasonably be expected to influence the advice.
Where this comes from: Required: the information in s947B(2)(d) and (e), or s947C(2)(e) and (f).
- 5
If you recommend replacing one product with another: brief particulars of the switching information s947D requires, and the statement it requires (or an acknowledgement that it was given).
Where this comes from: Required where it applies: reg 7.7.09(1), reg 7.7.08C(2)(b) and (c).
- 6
How and when the client was given the record, or the disclosure statement that went with the advice.
Where this comes from: Good practice. It evidences the timing rules above.
Will the reforms replace it?
The government’s Delivering Better Financial Outcomes reforms propose replacing the Statement of Advice with a “Client Advice Record”. On 3 October 2026 that exists only in a Treasury exposure draft from March 2025, which proposed a start 12 months after the law receives Royal Assent. The Corporations Act still requires Statements of Advice and allows Records of Advice on the terms above. In August 2026 the Assistant Treasurer described the measure as “streamlined statements of advice”.
One change from the first tranche of those reforms is already law. If the disclosure on your website says clients can ask for a record of advice, you must give one when asked (s943N).
Questions advisers ask
What is the difference between a Statement of Advice and a Record of Advice?
A Statement of Advice is the full document the Corporations Act requires when personal advice is given to a retail client. A Record of Advice is a shorter record the law allows instead in three situations: further advice to a client whose circumstances have not significantly changed since their last SoA, small investment advice of $15,000 or less, and advice that recommends no product to buy or sell.
When is a Statement of Advice required?
Whenever personal advice is given to a retail client (s946A), unless one of three exceptions applies: further advice where the client’s circumstances and the basis of the advice are not significantly different (s946B as substituted by reg 7.7.10AE), small investment advice up to $15,000 (s946AA), or advice that does not recommend acquiring or disposing of a product and earns no benefit for the advice (s946B(7)).
How long must a Record of Advice be kept?
A record of further advice must be kept for 7 years after the advice is given (reg 7.7.09(3)), and a client can ask for a copy of a record of advice for 7 years after the advice (regs 7.7.05 and 7.7.08).
Can a Record of Advice be an audio recording?
For further advice, yes. Reg 7.7.09(2) says the record may be kept in any form, and gives a tape recording as its example.
Is the Record of Advice being replaced by a Client Advice Record?
Not yet. A Client Advice Record appears in a March 2025 Treasury exposure draft under the Delivering Better Financial Outcomes reforms. On 3 October 2026 it was not law, and the Statement of Advice and Record of Advice rules in the Corporations Act still applied.
Does this template replace my licensee’s?
No. If your licensee has a Record of Advice template, use theirs. This one is a starting point for practices that do not, and a checklist for comparing against one that does.