What Was Form FS01 & How Was It Used When Applying for an Australian Financial Services Licence? (UPDATED JUNE 2025)

Introduction to the former Form FS01 for AFSL Applications

Prior to 16 June 2025, commencing an Australian Financial Services Licence (AFSL) application required completing Form FS01 as a fundamental step. This form, officially titled the ‘Application for AFS licence’, was the designated application form created by ASIC for entities seeking to become an Australian financial services (AFS) licensee and provide financial services in Australia.

Form FS01 was a critical component of the AFS Licensing Kit. As an online application form provided by ASIC through its former eLicensing system, Form FS01 streamlined the initial application process. As of 16 June 2025, this form and the eLicensing system have been replaced by a new, integrated online application process conducted through the ASIC Regulatory Portal.

Important Note on the June 2025 AFSL Changes

This article has been updated to clarify that Form FS01 and the eLicensing system are no longer used for AFSL applications, following changes implemented by ASIC on 16 June 2025. The content is preserved for informational purposes to explain a now-superseded process, which has been replaced by a new online application transaction on the ASIC Regulatory Portal.

Form FS01 as an Electronic Application

Form FS01, officially titled the Application for AFS licence, was designed as an electronic form. This meant the application was completed and submitted through ASIC’s former online eLicensing system. Applicants previously accessed Form FS01 by navigating to the ASIC website and locating the eLicensing portal.

The electronic format of Form FS01 was intended to streamline the application process, making it more efficient for applicants and for ASIC. This online application method was the primary way to apply for an AFSL prior to 16 June 2025. As of this date, both Form FS01 and the eLicensing system have been replaced by a new, integrated application transaction on the ASIC Regulatory Portal.

A Step-by-Step Guide to the Structure of the Former Form FS01

Part A: Applicant, Licence Details and Business Overview

Part A of Form FS01 was designed to collect essential details about the applicant, the scope of the licence sought, and a basic overview of the intended business operations. This initial section was crucial for ASIC to understand the nature of the AFSL application and the applicant entity. Accurate completion of this part ensured that the subsequent sections of the form were tailored appropriately.

When completing Part A, it was important to accurately provide the applicant’s details, including:

• The Australian Business Number (ABN) or Australian Company Number (ACN)
• The correct entity type
• Contact details for a designated person within the organisation

Furthermore, applicants had to specify the financial service authorisations they were seeking under the AFSL. A concise description of the business model was also necessary in this section. While Form FS01 is no longer used, all of this information is still required in the new online application on the ASIC Regulatory Portal.

Part B: Demonstrating Capacity to Meet AFS Licensee Requirements

Part B of Form FS01 shifted focus to evaluating the applicant’s capacity to meet the ongoing obligations of an AFS licensee. This section was vital for ASIC’s assessment of whether the applicant possessed the necessary structures and organisational competence to operate within the regulatory framework. It required applicants to demonstrate their understanding and preparedness in key compliance areas.

Applicants were expected to address their organisational competence, outlining how they would maintain the necessary skills and knowledge. Details regarding compliance arrangements and the allocation of adequate financial resources also had to be provided. While the form itself is obsolete, the obligation for applicants to demonstrate their capacity in these areas remains a central part of ASIC’s assessment in the new application process.

To summarise, in the former Part B, applicants were required to:

• Outline their organisational competence, detailing how they would maintain necessary skills and knowledge
• Describe their compliance arrangements to adhere to regulatory requirements
• Demonstrate adequate financial resources to support their operations

Part C: Addressing Complex Services and Products

Part C of Form FS01 was specifically designed to delve deeper into applications involving complex financial services or products. This part was triggered in the form when certain selections were made in Part A, indicating an applicant’s intention to engage in more intricate areas of financial service provision. It served to gather detailed information about these specific, complex authorisations.

If an applicant had selected complex services or products, Part C would present a series of targeted questions. These questions required comprehensive and precise responses to ensure ASIC could gain a thorough understanding of the applicant’s preparedness. While Part C of Form FS01 no longer exists, the new online application on the ASIC Regulatory Portal still uses a similar logic, asking more detailed questions based on the specific, complex authorisations an applicant selects.

Part D: Declarations and Certifications

Part D of Form FS01 was a critical section where declarations and certifications were formally generated. This part consolidated an applicant’s responses from Parts A, B, and C into legally binding statements.

Applicants were required to formally agree to these declarations, signifying their understanding and acceptance of the responsibilities associated with holding an AFSL. A careful review of Part D was paramount, as it legally bound the applicant to the accuracy of all information provided.

Making false or misleading statements was a serious offence under the Corporations Act 2001 (Cth). This principle remains unchanged, and applicants in the new system must still make similar binding declarations and certifications before submitting their online application.

Part E: Core Proof Documents for Your Application

Part E of Form FS01 outlined the essential documents for an AFSL application, which were known as ‘core proof documents’ that had to be submitted alongside the form. These documents served as supporting evidence, providing ASIC with tangible proof to verify the information declared in the form.

This part of the form is now entirely redundant. The application process that commenced on 16 June 2025 has removed the requirement for applicants to provide separate “core proof” documents (such as the A5 Business Description or B1 Organisational Competence proof). The detailed information that these documents used to contain is now collected directly through structured questions and data fields within the new online application on the ASIC Regulatory Portal.

How the Completed Form FS01 and Required Documents Were Submitted

The Former Online Submission Process via ASIC MOVEit Portal

Under the previous system, the primary method to submit supporting documents for Form FS01 was through the ASIC MOVEit portal. After submitting the completed Form FS01 online via the eLicensing system, ASIC would provide instructions on how to securely upload the required “core proof” documents via this portal.

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

• The ASIC MOVEit portal is no longer used for AFSL applications.
• All supporting documents are now uploaded directly into the ASIC Regulatory Portal as part of the new, integrated online application.

The Former Core Proof Documents Checklist

Submitting “core proof documents” was a necessary step in the former AFSL application process. These documents, along with a signed print-out of Form FS01, had to be provided to ASIC for an application to be considered complete. Checklists for these now-superseded documents were available in historical versions of ASIC’s Regulatory Guide 1 and Regulatory Guide 2.

Providing all necessary core proofs at the time of application was critical, as failure to do so could result in ASIC rejecting the application, leaving applicants wondering what to do if your AFSL application was rejected. This concept of separate “core proofs” (like the A5 or B1 proofs) has been removed in the new system. The information is now captured within the online form, and the only remaining proof documents are “People Proofs”.

Application Fees and Payment Methods

An application fee was associated with lodging Form FS01 for an AFSL, and a fee is still required for the new application process. Previously, ASIC’s eLicensing system would:

• Calculate the statutory fee
• Generate a payment remittance advice

This remittance advice was not a tax invoice because statutory fees are GST-exempt. The new ASIC Regulatory Portal performs the same function, calculating the fee for the online transaction.

Payment methods for the application fee generally include:

• BPAY
• Sending a cheque to ASIC

Previously, those intending to pay by cheque were advised to inform ASIC via email. Details about current fees and payment methods are available on the ASIC website.

Post-Submission Under the Former System: Completeness Check and ASIC Assessment

ASIC Completeness Check and Potential Rejection

After an applicant submitted their signed Form FS01 and core proof documents, ASIC would conduct a completeness check. This check, also known as a pre-lodgement check, was to ensure the application was complete and ready for assessment.

If the application was found to be incomplete, ASIC could reject it for lodgement. In the event of rejection, the applicant was required to re-apply for an AFSL. This principle remains the same for the new application process: if an application submitted through the ASIC Regulatory Portal is incomplete, it may be rejected, and a new application will need to be submitted.

The AFS Licence Assessment Process

Once an application passed the completeness check under the old system, ASIC would proceed with a detailed assessment. This part of the process remains fundamentally unchanged today. A licensing analyst from ASIC is assigned to assess the application. The depth of this assessment will depend on ASIC’s analysis of your business and the market in which you propose to operate.

During the assessment process, ASIC may need further information to support your application. If additional information or proof documents are required, ASIC will contact you via email, letter, or telephone. It is important to respond to any requests from ASIC promptly and within any specified timeframes to avoid delays in the application process.

Conclusion

Successfully navigating the former Form FS01 application was crucial for businesses aiming to secure an AFSL and operate within Australia’s financial services sector. Meticulous preparation and accurate completion of each section of Form FS01 were essential steps in demonstrating an organisation’s competence and commitment to meeting the stringent AFSL compliance requirements set by ASIC.

While Form FS01 and the eLicensing system are now historical artefacts of a previous application era, the principles they embodied remain critical. Ensuring all required information is thoroughly and accurately provided in the new online application on the ASIC Regulatory Portal is paramount to a smooth and efficient process.

Contact our experienced AFSL application lawyers at AFSL House today to book your consultation and leverage our unparalleled expertise. With a 100% success rate in AFSL applications, we can help you navigate the complexities of the current AFSL application process on the ASIC Regulatory Portal, ensuring your application is positioned for success.

Frequently Asked Questions About Form FS01