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Home Opinion

The end of SOAs? Think again: Why better advice won’t be legislated into existence

Since the Quality of Advice Review was handed down in 2022, advisers and consumers have been told that meaningful reform is coming — simpler documentation, lower costs, and more accessible advice.

by Vincent Holland
May 11, 2026
in Opinion
Reading Time: 4 mins read
Image: Supplied, Plutosoft

Image: Supplied, Plutosoft

The Delivering Better Financial Outcomes (DBFO) reforms were meant to deliver exactly that.

So, what do we have to show for it? 

X

To date, only Tranche 1 has made it into law — the least controversial part of the reform package. Fee consent renewals were positioned as a “quick win”. In practice, they became anything but. What was meant to harmonise and simplify fee consent instead introduced new layers of administration and inconsistent approaches. We still haven’t achieved a standardised industry fee consent form. 

Tranche 2 was meant to be the real reform — the part that tackled lengthy advice documentation head‑on. 

What we received was tranche 2(a) – a draft bill that landed in March 2025 and delivered some movement around advice documentation. Twelve months later, it remains just that: a draft.  A further tranche 2(b) flagged to introduce a new class of advisers and address more complex areas of reform, has yet to materialise 

Now, with a new Financial Services Minister and, according to the FSC’s latest policy update (Issue 89), further progress on Tranche 2 again delayed, the pattern is familiar. 

Same document, different name 

At the heart of Tranche 2(a) was the long‑awaited promise of simpler advice documents. The Statement of Advice (SOA) would be replaced with a Client Advice Record (CAR). For some, this sounded like a line in the sand — the beginning of the end for lengthy advice documents. 

But when you look closely, the substance barely changes. 

Based on our own analysis, the Client Advice Record is, in all material respects, substantively the same as the existing requirements for Statements of Advice. The core obligations remain. 

The problem was never that the law required 80‑page documents. 

The real issue has always been what grew around the law: overly cautious licensee interpretations, conservative ASIC guidance, and compliance frameworks designed primarily for regulatory protection rather than client understanding. Tranche 2(a) does not meaningfully address that reality. It largely rebadges existing obligations and hopes behaviour will change as a result. 

History suggests otherwise. 

Efficiency will be technology‑led, not legislated 

If the goal is genuinely more efficient and better-quality advice, the solution does not sit in Parliament House. It sits inside advice practices. 

Efficient advice businesses don’t start by asking how to shorten a document. They start by simplifying data, reducing re‑keying, and connecting advice strategy directly to client conversations. Strategy modelling done live with clients. One point of data entry. Advice documents generated as an output of the advice process — not as a separate, manual task. 

AI will play a role, but it won’t be a silver bullet on its own. Real efficiency comes from end‑to‑end systems that integrate fact‑finding, modelling, strategy and presentation – technology that supports advisers to spend more time advising, not documenting. 

The most profitable and scalable practices already understand this. They are not waiting for legislation to save them. 

Whether or not Tranche 2(a) eventually passes, the future of advice efficiency will not be determined by what a document is called. It will be determined by how effectively advisers can deliver high‑quality advice, at scale, in a way clients understand. 

And that future will be built with technology — not legislation. 

Vincent Holland is Co‑Founder at Plutosoft

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Comments 3

  1. Michell says:
    2 months ago

    Affordabliity and access to advice is an easy fix, when you consider giving advice without a SOA could be delievered in a letter and time in minutes not days. Technology changes alone, won’t save the advice industry….The Adviser of the future will be working for an Industry Super Fund. The former Finance Minister clearly stated the path going forward is where the majority of Australian mum’s and dads will get advice either from a) their super fund or b) their Accountant and buy products from a large insto with deep compensation pockets and admitted just a small percentage of the ultra wealthy may be getting advice from a Private Financial Planner. Treasury in the past indicated they don’t care about job losses in the sector.

    The ALP model is we’re all working as public servants, paying Union fees, contributing to Union Super. The small business Financial Planner does not fit that model. United Global Capital and Shield will be another sucker punch for most advisers when ongoing Advice fees will be banned from Super.

    Reply
  2. Rob says:
    2 months ago

    Courts and ASIC auditors still are after lengthy document called SOA , no matter how efficient you are.
    IMO solution is in making advice a profession with limited liability, get rid regulator’s micro management and get the industry bodies to become more effective in policy making and compliance monitoring.
    Otherwise in a few years ai will take over all of the above jobs’ while we are busy writing 100 page SOA and auditing it.

    Reply
  3. Trevor says:
    2 months ago

    Let’s face it. The ALP isn’t genuine on advice reform, if they were, they’d have done a lot better than they’ve managed so far.

    I’m increasingly of the view that they’re quite happy with how things are going. I suspect that any new reform will only be to advantage certain vested interests (n the name of access to advice) whilst delivering no release from excessive red tape for advisers (in the name of consumer protection.)

    ALP have been in office for four years and continually demonstrate that they don’t care.

    Suggest that this Government will go down as one of the worst in Australian history and the budget they’ll release tomorrow night will set them firmly on the pathway back into opposition.

    Reply

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