What the file has to show
Four obligations in Part 7.7A of the Corporations Act 2001 drive the content of an advice file: the best interests duty (s 961B), appropriate advice (s 961G), the warning where information is incomplete or inaccurate (s 961H) and the conflict priority rule (s 961J). ASIC's guidance on these sits in RG 175. The SOA or ROA records the advice. The file note records the conversation that led to it, and that conversation is where most of the s 961B(2) steps take place.
There is also a direct record-keeping rule. ASIC Corporations (Record-Keeping Requirements for Australian Financial Services Licensees when Giving Personal Advice) Instrument 2024/508, which replaced Class Order 14/923 in September 2024, requires licensees to keep records of personal advice for seven years after the advice is given. Authorised representatives must keep those records too and give the licensee access.
| s 961B(2) step | What it asks | Template heading |
|---|---|---|
| (a) | Identify the objectives, financial situation and needs disclosed through the client's instructions | Objectives, Financial situation, Needs |
| (b) | Identify the subject matter of the advice sought, explicit or implicit, and the circumstances relevant to it | Subject matter and scope |
| (c) | Where information looks incomplete or inaccurate, make reasonable inquiries | Inquiries made, Gaps and warnings |
| (d) | Assess whether you have the expertise. If not, decline | Expertise and referrals |
| (e) | If recommending a product is reasonable, investigate products that could meet the objectives and assess them | Options and products investigated |
| (f) | Base all judgements on the client's relevant circumstances | Reasoning linked to this client |
| (g) | Take any other step reasonably regarded as in the client's best interests | Other steps taken |
Each step is covered in the s 961B safe harbour steps explained. The point for a template is simple. If a step has no heading, it depends on the adviser remembering to write it down.
Template 1: discovery meeting
The first meeting evidences steps (a), (b) and (c). Its job is to capture what the client told you and what you asked in return, before any strategy is on the table.
- FILE NOTE - DISCOVERY
- Date / time / channel:
- Client(s) / adviser / others present:
- Financial services guide (FSG): (date given, how)
- Why the client has come: (in their words)
- Objectives: (each one, with timeframe and priority as ranked by the client)
- Financial situation: (income, expenses, assets, liabilities, super, insurance, estate planning in place)
- Needs: (what has to be true for the objectives to be met)
- Personal circumstances: (age, health, dependants, employment, expected changes)
- Risk discussion: (how they talk about risk, past behaviour in a downturn, profiling tool result if used)
- Subject matter and scope: (what they want advice on, what they do not, anything implicit you identified)
- Inquiries made: (follow-up questions where something was incomplete or did not add up, and the answers)
- Gaps and warnings: (information not provided, whether a s 961H warning may be needed)
- Expertise and referrals: (anything outside your competence or authorisation, referred to whom)
- Fees discussed:
- Client questions and understanding:
- Next steps: (who, what, by when)
Filled example: discovery
- Financial services guide
Emailed our financial services guide (FSG) on 30 July 2026. Delphine confirmed she had read it.
- Why the client has come
In her words: 'I am 58, I have three super accounts and no idea if I can stop work at 63.'
- Objectives
In Delphine's order of priority:
- Retire at 63, in five years. This is her priority.
- Retirement income of about $62,000 a year in today's dollars.
- Tidy up her super into 'one account I understand'.
- Help her daughter with a home deposit 'if I can afford it'. Lowest priority, and no amount set.
- Financial situation
- Work: full-time employee, practice manager, on $104,000 a year plus her employer's compulsory super contributions.
- Spending: about $58,000 a year, from Delphine's own budget.
- Home: owned outright, no mortgage, worth about $920,000.
- Super: Fund A $286,000 (current employer, balanced option). Fund B $71,000 (old employer, high growth option). Fund C $19,000 (old employer, default option).
- Cash: $44,000. No investments outside super.
- Insurance: death and total and permanent disability (TPD) cover in Funds A and B. Income protection in Fund A only.
- Estate planning: will made in 2019. No enduring power of attorney.
- Needs
Enough money at 63 to fund $62,000 a year, with the Age Pension from 67 as a backstop. Less investment risk as retirement gets closer. A simple structure.
- Personal circumstances
Single, with one adult daughter who does not depend on her financially. Good health, non-smoker. Secure job and no plans to change it. Expects to keep working full time until 63.
- Attitude to risk
Said she 'felt sick' watching her balance fall in 2020, but did not switch options. Risk profiling tool result: balanced, and Delphine agrees with it. She did not know Fund B is in a high growth option.
- Subject matter and scope
- In scope: combining her super accounts, a contributions strategy, her investment option and a retirement income projection.
- Not raised by Delphine, but needed: the insurance inside the funds she would close has to be checked before any money is moved out of them.
- Out of scope: Centrelink detail beyond an Age Pension estimate, her daughter's position, and estate planning.
- Inquiries made
- Her $58,000 budget looked low against a $104,000 income and only $44,000 in cash after several years. Asked about it. She paid off her mortgage in 2024, and since then about $1,400 a month of surplus has gone to cash. That adds up.
- Asked if she has a defined benefit fund or an overseas pension. She has neither.
- Asked if she expects an inheritance. She does not.
- Gaps and warnings
The amounts of her insurance cover and the premiums are not known yet. Delphine will get her statements. If they arrive, no warning about incomplete information (under s 961H) is needed at this stage.
- Expertise and referrals
Updating her will and making an enduring power of attorney: referred to her solicitor. Not authorised to give tax agent services beyond what the advice itself needs. Delphine has an accountant.
- Fees discussed
Quoted a fixed fee for the statement of advice (SOA). Engagement letter to follow. Explained that ongoing service is optional and will be discussed when the advice is presented.
- Client questions
- Does combining accounts mean losing insurance? Explained that cover in a closed account ends, which is why we check before moving any money.
- Is $62,000 a year realistic? Said the projections will answer that. No view yet.
- Next steps
- Delphine: send her super and insurance statements by 11 August.
- T. Varga: send the engagement letter today, then research and model the options.
- Strategy meeting in the week starting 24 August.
The 'Inquiries made' section is the evidence for step (c). Something looked off, a question was asked and the answer resolved it. If the client had declined to provide the insurance statements, 'Gaps and warnings' is where the s 961H position gets recorded.
Template 2: advice and strategy discussion, mapped to s 961B(2)
Use this for the meeting where you test or present the strategy. Each heading carries its safe harbour step, so a reviewer can walk the file in order.
- FILE NOTE - STRATEGY DISCUSSION
- Date / time / channel / present:
- (a) Objectives, financial situation and needs confirmed: (restate, record any change since discovery)
- (b) Subject matter and scope confirmed: (what this advice covers and what it does not)
- (c) Further inquiries: (anything chased since discovery and the result, any s 961H warning given)
- (d) Expertise: (within competence and authorisation, or what was referred)
- (e) Options and products investigated: (each strategy and product considered, including staying put, with costs, benefits and what was ruled out and why. For any replacement, what the client loses and gains)
- (f) Recommendation and reasoning: (what you recommend and how each part ties to this client's circumstances)
- (g) Other steps taken: (anything further done in the client's interests)
- Why the advice is appropriate (s 961G):
- Conflicts (s 961J): (any interest of yours, your licensee or an associate, and how the client's interests were prioritised. approved product list (APL) limits if relevant)
- Risks and downsides explained:
- Fees and costs explained: (advice fee, product fees before and after)
- Client questions and understanding:
- Client decision / instructions: (in their words)
- Advice document: (SOA or ROA, date to be provided)
- Next steps:
Filled example: strategy discussion
- (a) Objectives, situation and needs confirmed
No change since 4 August. Retire at 63 on $62,000 a year, simplify her super, and help her daughter if she can afford it. Delphine confirmed no change to her job, health or finances.
- (b) Subject matter and scope confirmed
- Covered: combining her super, contributions, investment option, retirement projection, and the insurance inside her super as it affects moving money between funds.
- Not covered: estate planning (she is dealing with her solicitor), and any gift to her daughter beyond checking whether she can afford it.
- (c) Further inquiries
Statements received on 10 August.
- Fund B holds $180,000 of death and TPD cover. The premiums are eating into a $71,000 balance.
- Fund A holds $250,000 of death and TPD cover, plus income protection to age 65.
- Fund C has no cover.
- Asked whether she needs death cover. She has no dependants and no debt, and sees no need for the Fund B cover.
- No warning about incomplete information (s 961H) needed. The information is complete for this scope.
- (d) Expertise
Within the adviser's authorisation (super, retirement and life insurance). Delphine's accountant is to confirm the tax deduction detail for her contributions.
- (e) Options and products investigated
- 1. Do nothing. Three sets of fees. Fund B's investment mix does not match her risk profile. Her insurance cover is doubled up.
- 2. Move Funds B and C into Fund A and keep Fund A's cover. One account, lower total fees, and she keeps her income protection. Fund A is on our approved product list (APL) and she already holds it.
- 3. Move everything into a new platform super product. Wider investment menu, but a higher admin fee than Fund A at her balance. She would need new income protection cover and would have to be underwritten again at 58. Ruled out: Delphine does not need the wider menu and could lose her income protection.
- Contributions: compared salary sacrifice, kept within her yearly limit for before-tax (concessional) contributions, against saving the money in cash.
- Investment option: compared staying in balanced (her current option in Fund A) with moving to a more conservative option from age 61.
- (f) Recommendation and reasoning
- Recommendation: option 2. Move Funds B and C into Fund A. Keep Fund A's death, TPD and income protection cover. Cancel the Fund B cover when the money moves.
- Salary sacrifice $1,000 a month from her existing surplus. This stays within her limit after her employer's compulsory contributions.
- Investment option: stay balanced for now and review moving to lower risk at 61.
- Why: it meets her goal of one simple account without losing cover she needs, cuts fees, and fixes the mismatch between Fund B's high growth option and her balanced risk profile.
- Projection: on the stated assumptions, her balance at 63 supports about $62,000 a year to life expectancy, with the Age Pension from 67. It is tight, and Delphine was told so.
- (g) Other steps taken
- Checked Funds B and C for exit fees and any benefits she would lose by leaving. None found, based on the product disclosure statements and confirmation from the funds.
- Found that her binding death benefit nomination in Fund A has lapsed. Delphine will renew it.
- Why the advice is appropriate (s 961G)
It deals with her stated priority, fits her risk profile, keeps the one insurance she relies on while working, and is simple enough for her to follow.
- Conflicts (s 961J)
Fixed advice fee. No commission and no fee based on her balance. Fund A is not related to our licensee. No conflict identified.
- Risks and downsides explained
- Fund B's death and TPD cover ends when the money moves, and she may not be able to get it again on the same terms.
- Market risk remains. Showed a poor-returns scenario where her income drops to about $55,000 a year, or retirement moves to 64.
- Salary sacrifice locks money in super until she meets a condition of release (one of the legal triggers for getting access to super).
- Fees and costs explained
Fee for the statement of advice as set out in the engagement letter. Showed her total super fees now against after combining, taken from the funds' disclosure documents. Noted the buy/sell spread (a small transaction cost) when leaving Funds B and C.
- Client questions
- Could she still give her daughter $30,000? Showed the effect: her cash buffer would fall to $14,000. Delphine decided to wait and revisit it at her annual review.
- What does 'condition of release' mean? Explained it.
- Delphine summarised the plan back correctly.
- Client's decision
In her words: 'One account, keep the income protection, start the salary sacrifice. I will hold off on the deposit money.' Instructed us to go ahead with the statement of advice.
- Advice document
Statement of advice to Delphine by 9 September 2026. Nothing is put in place until she has it and has signed an authority to proceed.
- Next steps
- T. Varga: prepare the statement of advice.
- Delphine: renew her binding nomination in Fund A.
- Delphine: talk to payroll about salary sacrifice once she has the statement of advice.
Template 3: annual review, ongoing fee arrangement and consent
The rules here changed, so check your template is current. The Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024 removed the obligation to give a fee disclosure statement (FDS). The revised rules apply from 10 January 2025, with transitional arrangements for ongoing fee arrangements (OFAs) already on foot at that date. What remains is written client consent to renew the OFA each year. ASIC's guidance describes a renewal period of 120 days starting on the anniversary day, and an OFA that terminates 30 days after that period ends if the client has not renewed. ASIC also says consent records must be kept for five years. More background is in ongoing fee arrangements and fee disclosure statements.
The consent form is the legal document. The file note shows the review was delivered, the fee was explained and the client knew what they were agreeing to. It is also your evidence that the service the client paid for was actually provided.
- FILE NOTE - ANNUAL REVIEW
- Date / time / channel / present:
- Ongoing fee arrangement (OFA) anniversary day / consent due by:
- Services provided in the past 12 months: (what was promised under the OFA, what was delivered, dates)
- Changes in circumstances: (work, health, family, income, expenses, goals. Record 'no change' if asked and nothing has changed)
- Objectives revisited:
- Portfolio / strategy review: (performance against objectives, risk profile still right, contributions, insurance, nominations)
- Advice given today: (none, or what, and whether an ROA or SOA is required)
- Ongoing fee explained: (amount or estimate for the next 12 months, how calculated, which account it comes from, services to be provided)
- Right to withdraw or vary consent explained: (yes or no)
- Client response on fee and consent: (in their words. Consent form signed, date, or sent for signature)
- Conflicts:
- Client questions and understanding:
- Next steps: (who, what, by when, next review date)
Filled example: annual review
- Fee arrangement dates
The anniversary of her ongoing fee arrangement (OFA) is 9 September 2027. Asked for her consent to renew today, before the renewal period closes.
- Services delivered in the past 12 months
Everything promised under the fee arrangement was delivered:
- Annual review (today).
- Mid-year check-in call on 24 February 2027 (note on file).
- Moving her super and setting up salary sacrifice, finished in October 2026.
- Phone and email access as needed: 3 contacts, all noted on file.
- Changes in circumstances
Pay rise to $108,000. Health unchanged. Her daughter is now engaged and likely to buy a house within 12 months. No other change.
- Objectives revisited
Retiring at 63 is still the priority. Helping her daughter with a deposit has moved up: Delphine now wants to give $30,000 within 12 months.
- Portfolio and strategy review
- One account in Fund A, balanced option. Balance slightly ahead of the projection.
- Salary sacrifice running at $1,000 a month.
- Risk profile checked again: still balanced.
- Income protection cover in place. Binding nomination renewed in September 2026.
- Cash now $51,000.
- Advice given today
- Re-ran the projection with a $30,000 gift paid from cash. Her cash buffer falls to $21,000. The retirement projection does not change, because the gift comes from cash and not from super.
- No product or strategy change recommended.
- Further advice to be set out in a record of advice (ROA), because her circumstances and the basis of the advice are not significantly different from the statement of advice of September 2026.
- Ongoing fee explained
Fixed fee for the next 12 months, the same as last year, taken monthly from Fund A. Services: annual review, mid-year call, phone and email access as needed, and putting agreed changes in place. Walked through the consent form line by line.
- Right to withdraw or change consent
Explained. Delphine can change or withdraw her consent at any time by telling us in writing.
- Client's response on fee and consent
In her words: 'Happy to keep going, the mid-year call was useful.' Consent form signed in the meeting, dated 25 August 2027. Copies to Delphine and to the fund.
- Conflicts
None. Fixed fee, no commission.
- Client questions
- Will the gift affect her Age Pension later? Explained that the gifting rules apply at the time she claims. She is 8 years from Age Pension age, so we will revisit it closer to the time.
- Should she move to a conservative option yet? Agreed to stick with the plan to review at 61. No change.
- Next steps
- T. Varga: issue the record of advice by 1 September.
- T. Varga: send the signed consent to Fund A this week.
- Mid-year call booked for February 2028.
- Next annual review in August 2028.
Checklist: before you save any advice file note
- Objectives are in the client's words, with a timeframe and a priority.
- At least one follow-up question is recorded, with the answer.
- Scope says what is out as well as what is in.
- Alternatives are named, including doing nothing, with the reason each was ruled out.
- The reasoning refers to this client's circumstances. Generic product benefits do not count.
- Conflicts are addressed even when the answer is 'none'.
- Downsides and what the client gives up are recorded.
- The client's decision is in their own words.
- The note is dated and written the same day.
You can test a note against these points with the free best interests duty file note checklist, or check the whole file with the file note audit readiness checker. More template variations, including insurance and SMSF conversations, are in the file note template library. For worked BID scenarios, see best interests duty examples for advisers.
Using these templates with CallNote
CallNote turns a meeting transcript that already exists into a file note under your headings in about two minutes. It never records calls, never joins a meeting as a bot and never stores call audio. You paste the transcript, upload a .vtt or .txt export from Teams, Zoom or Meet, forward it by email, or receive it automatically from Dialpad or Aircall. After an in-person meeting you can dictate a voice memo instead.
If your practice already has a note format your licensee is happy with, paste one of your own past notes and CallNote builds a template from it that matches your headings and your shorthand. There is a system financial advice template as well. You review and correct the draft, then publish it: the note is sealed with a SHA-256 checksum, amendments are append-only and every action is in the audit log. Export to PDF or copy the text across. We do not have native integrations with Xplan or AdviserLogic, so the route there is copy and paste, PDF, or Zapier where the system supports it. Data is hosted in Sydney and is not used to train AI.
Common questions
Is there a required file note format for financial advisers in Australia?
No. The Corporations Act and ASIC do not prescribe a format. ASIC Instrument 2024/508 requires licensees to keep records of personal advice for seven years, and s 961B, 961G, 961H and 961J set the duties the records need to evidence. Most AFSLs set their own file note standard, so check your licensee's policy first.
What should a financial adviser file note include?
Date, attendees and channel, the client's objectives, financial situation and needs, the scope of advice, the inquiries you made, options and products considered, your recommendation and reasoning, conflicts, risks explained, fees, the client's questions, their decision in their own words, and next steps. Mapping the headings to the s 961B(2) safe harbour steps makes the note easier to review.
How do I show the safe harbour steps in a file note?
Give each step its own heading. Steps (a) and (b) are the objectives, situation, needs and scope. Step (c) is the follow-up questions you asked. Step (d) is expertise and referrals. Step (e) is the options and products you investigated. Step (f) is reasoning tied to the client. Step (g) is anything further you did in their interests.
Do I still need a fee disclosure statement at the annual review?
The obligation to give an FDS was removed by the Delivering Better Financial Outcomes reforms, with the revised rules applying from 10 January 2025 and transitional arrangements for OFAs already in place at that date. Annual written consent to renew the ongoing fee arrangement is still required. Check ASIC's current guidance and your licensee's process.
How long must advisers keep file notes?
Records of personal advice must be kept for seven years after the day the advice was provided, under ASIC Instrument 2024/508. ASIC's guidance on ongoing fee arrangements says consent records must be kept for five years. Many licensees simply apply seven years or longer to the whole client file.
Can I build a template from one of my existing file notes?
Yes. In CallNote you paste one of your own past notes and it builds a template that matches your headings and shorthand. Each new transcript is then written up in that format for you to review, correct and lodge.