Australian Credit Licence (ACL): Licensing & Obligations

Understanding the ACL

An Australian Credit Licence (ACL) authorises you to engage in credit activities, including credit provision, credit assistance (e.g., mortgage broking), and acting as an intermediary, under the National Consumer Credit Protection Act (NCCP). To obtain (or vary) an ACL, entities must demonstrate fit-and-proper people, competent Responsible Managers, adequate financial and human resources, robust compliance arrangements, conflict management, dispute resolution (IDR and AFCA membership), and record-keeping that stands up to ASIC scrutiny.


Why the ACL Matters

Strong licensing foundations determine what you can offer and how quickly you can scale. Poorly scoped authorisations, thin Responsible Manager coverage, or weak policies slow approvals, constrain growth and increase remediation risk. A well-designed ACL aligns your operating model to obligations, supporting cleaner surveillance, fewer complaints, and smoother reviews by ASIC and AFCA.


Key Challenges Facing Firms

  • Scoping authorisations correctly (today’s services vs near-term roadmap).

  • Ensuring Responsible Manager competence covers all authorised activities.

  • Building evidence packs (policies, procedures, monitoring plans, MI) that are application-ready.

  • Embedding IDD/IDR & AFCA processes that actually work at scale.

  • Governing outsourcing/introducers and appointed credit representatives.

  • Managing variations and growth (new products, distribution models, acquisitions) without control gaps.


How OCG Can Help

Oceanic Consulting Group (OCG) helps new and established firms secure, vary and optimise ACLs with practical, defensible submissions and operating controls.
Our services include:

  • Licence scoping & roadmap (authorisations, representatives, outsourcing).

  • Responsible Manager strategy (gap analysis, competence evidence, coaching).

  • Policy & control libraries (conduct, conflicts, complaints/IDR, breach reporting, monitoring).

  • Compliance plans & assurance (sampling, MI/dashboards, issue management).

  • AFCA readiness and customer-outcomes alignment across channels.

  • Variation projects & remediation following growth, audits or ASIC engagement.


FAQs

What is an ACL?
A statutory licence under the NCCP that permits defined credit activities (e.g., credit provision, credit assistance) subject to ongoing obligations.

How long does licensing take?
Timeframes vary with scope and evidence quality. Clear scope, complete policies and competent Responsible Managers significantly reduce delays.

Do we need appointed credit representatives?
Not always. Where you use them, you must maintain effective supervision and controls, with defensible records of oversight.


Strengthen Your ACL Licensing Programme

Work with OCG’s Credit Compliance Specialists

Build a licence that fits your strategy and stands up to scrutiny. Contact OCG to scope authorisations, evidence Responsible Manager competence, and embed policies, monitoring and MI that accelerate approval and support sustainable growth.

Speak with OCG’s Risk Advisory team today

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