Statement of Advice Requirements: What an SOA Must Contain, and When a Record of Advice Will Do

8 min read · facts checked 25 Oct 2026

As at 25 October 2026, anyone who gives personal advice to a retail client must give a Statement of Advice (SOA) (Corporations Act s 946A), unless an exception applies, such as further advice recorded in a Record of Advice (ROA) or small investments of A$15,000 or less (s 946AA; Corporations Regulations reg 7.7.09A). What an SOA must contain is set out in ss 947A–947E, and ASIC's examples are RG 90 and the attachment to INFO 267.

When an SOA is needed

• The advice is personal advice (it takes into account the client's objectives, financial situation or needs) and the client is a retail client.
• The SOA can be the way the advice is given, or a separate record of advice given another way, such as in a meeting (s 946A(2)).
• General advice does not need an SOA; it carries a general advice warning instead.
• ASIC says fact-finding meetings do not need an SOA if their genuine purpose is gathering information for advice that will be set out in one, and the client is told so at the start (RG 175.91).

What an SOA must contain

• Replacement advice (s 947D): if you recommend disposing of or reducing one product and acquiring another, the SOA must also cover the costs of leaving and joining, any benefits the client may lose, and other significant consequences. If you know there will be costs but cannot find out what they are, say so (s 947D(3)).
• Level of detail: what a retail client would reasonably need to decide whether to act on the advice (s 947B(3)).
• Presentation: clear, concise and effective (s 947B(6)), titled "Statement of Advice" on the cover or at or near the front (s 947A).
• Separate document: an SOA must not be combined with a Financial Services Guide or a PDS (s 947E).

When it must be given

• If the SOA is not the means of giving the advice, give it when, or as soon as practicable after, the advice is given, and in any case before providing any further financial service that arises from the advice (s 946C(1)).
• If the SOA is not given when the advice is given, give the client the remuneration and interests information at that time (s 946C(2)).
• Time-critical cases: if the client expressly wants the further service immediately and an SOA cannot practicably be given first, it is due within 5 business days, or before the cooling-off period starts if one applies (s 946C(3)).

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When a Record of Advice is enough

An ROA can set out the advice in full, or brief particulars of the recommendations and their basis, plus any replacement-product information given (reg 7.7.09(1)); a recording counts. ASIC says the brief form is normally met by a clear record of the advice and either a summary of the client's relevant circumstances or a dated reference to the earlier SOA or ROA, once inquiries confirm nothing has changed (RG 175.95).

ASIC's example SOAs

• RG 90: an example SOA giving scaled advice to a new client. It is on ASIC's exam reading list for the advice construction area.
• Attachment to INFO 267 (November 2024): an annotated example of an SOA for limited advice, linking each part to the Corporations Act, the Regulations and the Code of Ethics.
• Both are examples, not templates: ASIC expects licensees to tailor SOAs to each client.

How the exam tests SOAs

• Spotting what is missing from an SOA described in a scenario, often the s 947D information on a switch.
• Choosing between SOA, ROA and no document for further advice or a small investment.
• Timing: whether a document arrived too late, or a time-critical exception applies.
• Disclosure of benefits and associations, often alongside a conflict question under s 961J or Code Standard 3.
• Whether a provisional relevant provider's SOA was approved in writing by their supervisor (s 921F(4)): see the professional year guide.

Our study notes on scaled advice and advice documents and advice and disclosure go deeper. To practise, try our free sample questions, each with a worked explanation citing the law or standard behind it, and the worked example in the case study guide.