The Australian and New Zealand Institute of Insurance and Finance (ANZIIF) has introduced a new short course for responsible managers as Australian financial services licensees (AFSLs) continue to come under scrutiny for how they demonstrate organisational competence under Regulatory Guide 105 (RG 105). The online course, RG105 Responsible Managers, is intended for professionals formally nominated as responsible managers, as well as senior leaders who oversee responsible manager obligations across broking, underwriting, claims, compliance, and operations in Australia and New Zealand.
Under the Australian Securities and Investments Commission’s (ASIC) RG 105 Licensing: Organisational competence, AFSL holders must be able to show they meet the obligation in section 912A(1)(e) of the Corporations Act. In practice, this requirement is linked to the capability and conduct of nominated responsible managers, who are expected to oversee the day-to-day provision of financial services. The course is directed at senior brokers, claims leaders, underwriters, compliance managers, and operational leaders whose responsibilities support the authorisations held under an AFSL and who are involved in key financial services decisions.
Responsible managers are expected to maintain and demonstrate competence on an ongoing basis. The one-hour program is structured to align with that annual expectation and to provide material that can be used by licensees during audits and regulatory reviews. The course uses scenario-based learning, interactive tasks, and applied assessments to set out how RG 105 applies in operational settings. Participants examine how to interpret RG 105 in routine decision-making, demonstrate organisational competence in line with ASIC guidance, and apply a risk-based approach to oversight, escalation, and governance. Course content also addresses current regulatory themes affecting insurers, intermediaries, and related sectors, including design and distribution obligations, scams, technology risk, and unfair contract terms. ANZIIF has indicated the material will be reviewed annually to reflect regulatory change and developments in risk.
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ANZIIF chief executive officer Katrina Shanks said the course has been developed in the context of the role responsible managers play within AFSL governance. “Responsible managers sit at the heart of organisational competence, and expectations have never been higher. This course provides a clear and practical way for responsible managers to meet their annual compliance obligations, while strengthening the quality of decision-making across their organisations. It’s designed to build knowledge and help professionals demonstrate competence in a way that stands up to regulatory scrutiny,” Shanks said.
The program includes an option for Recognition of Current Competency (RCC), allowing experienced responsible managers to have existing skills recognised as part of the process. On completion, participants receive a digital badge and supporting reference materials that can be used in their organisations. According to ANZIIF, RG105 Responsible Managers is the first in a planned series of compliance-focused courses for insurance and financial services professionals in the region.
The course launch comes against a backdrop of continuing regulatory attention on how AFSL holders appoint, change, and remove responsible managers and how those decisions affect organisational competence. ASIC guidance describes responsible managers as the individuals a licensee relies on to meet its organisational competence obligations. Before nominating a new responsible manager, AFSL holders are expected to confirm that the individual is directly responsible for significant day-to-day decisions about the ongoing provision of financial services, is a fit and proper person, and holds qualifications and experience that meet one of the five pathways set out in Section C of RG 105. Licensees are also asked to consider the practical experience of any proposed responsible manager, including whether the individual understands the responsibilities of the role in the context of the particular business, how relevant financial products and services are delivered, and whether they have experience either providing those services or supervising others who do.
ASIC requires AFSL holders to notify the regulator of changes to responsible managers within 10 business days of any change. Notifications are lodged through ASIC’s Regulatory Portal. Through this process, licensees can update the details of an existing responsible manager, appoint a new responsible manager, or notify that a responsible manager has ceased. For each change, ASIC requires the effective date and uses the information both to update its public register and to assess any impact on the licensee’s organisational competence.
When a new responsible manager is added, ASIC expects supporting documentation, including a Statement of Personal Information, a criminal history check that is no more than 12 months old, information about the person’s competence and relevant roles over the previous 10 years, and copies of qualification certificates. Where the individual has lived outside Australia for more than 12 months in the past decade, overseas bankruptcy and police certificates are also required.
For responsible managers with overseas qualifications, licensees may use Australian Education International–National Office of Overseas Skills Recognition (AEI–NOOSR) tools and assessments to show that a foreign qualification is comparable with an Australian qualification that satisfies RG 105 requirements. If a responsible manager who is named as a key person on an AFSL leaves the licensee, the AFSL holder must first notify ASIC of any new responsible manager appointments and then apply to vary the licence to change or remove the key person condition. There is no fee for lodging a change of responsible manager within the 10-business-day timeframe. Late notifications attract a fee of A$98 if submitted up to one month after the deadline and A$411 if lodged more than one month late.
