A Guide to the A5 Business Description in Your AFSL Application (JUNE 2025 UPDATE)

Introduction

Previously, to apply for an Australian Financial Services Licence (AFSL), applicants were required to complete the now-superseded Form FS01 and provide core proof documents to ASIC. This application process is necessary for those seeking authorisation to provide financial services and products in Australia and operate a financial services business. ASIC assesses these applications to ensure applicants meet the requirements for holding an AFSL.

For AFSL applicants under the former system, a key core proof document was the A5 Business Description. This document provided ASIC with an overview of the applicant’s financial services business and was essential for ASIC to understand the operations of the business and assess organisational competence. While the A5 Business Description as a separate document is no longer required for applications made after 16 June 2025, the detailed information it contained must now be provided directly within the new online application on the ASIC Regulatory Portal.

Important Note on the June 2025 AFSL Changes

This article has been updated to reflect that the A5 Business Description is no longer submitted as a separate “core proof” document, following ASIC’s new AFSL application process effective 16 June 2025. This guide is maintained for historical reference, as the detailed business information it describes is now captured directly within the new online application on the ASIC Regulatory Portal.

Purpose and Significance of the A5 Business Description

The “A5 Business Description” was a core proof document that outlined an applicant’s proposed business, detailing the financial services and products offered, income generation methods, and anticipated business growth as part of the AFSL application.

This description directly addressed question A5 in the now-superseded Form FS01, the ‘Application for AFS Licence’. Under that former system, the A5 Business Description was crucial for ASIC’s assessment process as it outlined the types of financial services an applicant intended to offer and how their business would function. Its primary significance lay in demonstrating to ASIC that the applicant had a well-defined business model and was prepared to operate within the regulatory requirements of an AFSL.

While this specific proof document is no longer required for applications submitted after 16 June 2025, the fundamental requirement to provide this detailed information to ASIC remains, with the details now being captured directly within the new online application form.

Key Components of an Effective A5 Business Description

Overview of Your Financial Services Business

To effectively communicate business operations to ASIC under the previous system, the A5 Business Description had to include a comprehensive overview of the financial services business. This overview provided ASIC with a clear understanding of the business model and its intended operations. While this information is no longer submitted as a separate “A5 proof” document, it remains essential and must now be provided within the structured questions of the new online application form.

The overview was required to specify:

• Types of financial services and products offered: A clear outline of the specific financial services to be provided under the AFSL and the types of financial products involved.
• Income generation methods: An explanation of how the business would generate revenue, such as through fee-for-service arrangements, commissions, or buy-sell spreads.
• Client types: A description of the target clientele, indicating whether they would be retail clients, wholesale clients, or a mix of both, and their typical financial goals.
• Business growth strategies: An articulation of plans for business expansion and anticipated growth.
• Financial service and product delivery methods: Details on how services and products would be delivered to clients (e.g., call centre, face-to-face, online).
• Distribution channels: For product issuers, a description of the distribution channels to be used (e.g., authorised representatives, other AFS licensees).
• Multiple business locations: Information on any operations beyond the principal place of business, including how supervision and compliance would be maintained across all sites.
• Outsourced functions: Disclosure of any outsourced financial service-related functions, including who would perform them and from where.

Organisational Chart and Structure

Including a detailed organisational chart was another critical component of the A5 Business Description. This chart visually represented the business’s structure to help ASIC understand its operational framework. While the A5 proof is no longer a requirement, applicants are still expected to provide this information, and an organisational chart can be uploaded as a supporting document in the new ASIC Regulatory Portal.

The organisational chart was required to include:

• Employee numbers: The total number of employees and the number of staff in each functional area.
• Responsible manager positions: The positions held by each nominated responsible manager and their reporting lines.
• Compliance personnel: The position of the person responsible for overseeing compliance with AFSL obligations and their reporting lines.
• Reporting lines: An illustration of the flow of authority and responsibility within the organisation.
• Partnership or Trust details: The names of all partners (for a partnership) or all trustees (for a trust).

Completing Your A5 Business Description Proof

Preparing and Tailoring the Business Description

When preparing the A5 Business Description proof under the old system, it was crucial to tailor the document to accurately reflect specific business operations. Generic information was to be avoided to ensure the description effectively communicated the necessary details to ASIC. The A5 Business Description needed to be specifically designed to showcase the unique aspects of the business and the financial services it intended to provide. This principle remains critical: providing generic or outdated information in the new online application may delay processing, or even lead to your AFSL application being rejected.

To effectively tailor the business description, applicants were advised to include details such as:

• Specific Types of Financial Services and Products: A clear outline of the financial services and products to be offered.
• Business Model: A description of how income would be generated and the strategies for business growth.
• Unique Business Aspects: Highlighting what set the business apart from others in the industry.

By focusing on these business-specific details, applicants could ensure their A5 Business Description was both relevant and compelling for ASIC’s review.

The Former Submission and Lodgement Process via ASIC MOVEit Portal

Submitting the A5 Business Description proof, along with other core proof documents, was previously done through the ASIC MOVEit portal. After an applicant submitted their online application form (the former Form FS01), ASIC would provide instructions on how to use this portal.

This submission process is now obsolete. As of 16 June 2025:

• The ASIC MOVEit portal is no longer used for lodging AFSL application documents.
• The concept of separate “core proof” documents like the A5 Business Description has been removed.
• All required business information is now entered, and any supporting documents are uploaded, directly into the ASIC Regulatory Portal as part of a single, integrated online application.

Conclusion

The A5 Business Description was a critical component of the AFSL application process prior to the 16 June 2025 updates. It served as a foundational core proof document, directly linked to question A5 in the now-superseded Form FS01, that provided ASIC with a comprehensive understanding of an applicant’s financial services business. While this specific document is no longer required, the information it contained remains essential for ASIC to properly assess your business model and the financial services you intend to offer.

Given that a comprehensive and accurate business description is still paramount, careful preparation is essential. Should you require assistance ensuring the business information you provide within the new online application effectively meets ASIC’s requirements, our expert AFSL application lawyers at AFSL House are available to provide tailored guidance and support. Book a free initial consultation with us today to discuss how we can assist you in navigating the complexities of the current AFSL application and help you prepare the robust and compliant business description information now required by the ASIC Regulatory Portal.

Frequently Asked Questions