ACL credit licence application preparation checklist
An Australian Credit Licence is required to engage in credit activities including lending, broking, and leasing. ASIC assesses applicants against the general conduct obligations in s 47 of the National Credit Act. This checklist covers preparation from initial scoping through to lodgement.
This is a 12-step checklist for preparing an Australian Credit Licence (ACL) application under the National Consumer Credit Protection Act 2009 (Cth). It covers fit and proper assessments, compliance systems, and ASIC lodgement.
The checklist
Determine credit activities
Identify which credit activities the applicant will carry on — lending, broking, leasing, or debt collecting — and confirm each requires an ACL.
Review exemptions
Check whether any exemptions or authorisation under another licensee apply, such as credit representative arrangements.
Confirm entity eligibility
Confirm the applicant entity is a body corporate or natural person eligible to hold an ACL and is registered with ASIC.
Assess fit and proper person
Conduct fit and proper person assessments for all directors and senior managers, including criminal history and insolvency checks.
Draft compliance arrangements
Draft internal compliance arrangements covering responsible lending, hardship procedures, and staff training programs.
Prepare financial resources evidence
Prepare evidence of adequate financial resources including audited accounts, cash flow forecasts, and PI insurance details.
Confirm EDR membership
Confirm membership of AFCA for external dispute resolution and document the internal complaints handling procedure.
Prepare staff competence records
Document qualifications and training records for all staff who will engage in credit activities, satisfying ASIC RG 206.
Draft responsible lending procedures
Draft responsible lending assessment procedures covering inquiries, verification, and preliminary and final assessments.
Prepare credit guide
Draft the credit guide that will be provided to consumers, covering fees, complaints, and the credit representative relationship.
Compile supporting documents
Compile all attachments including organisational chart, outsourcing agreements, IT security summary, and sample disclosure documents.
Lodge application with ASIC
Complete and lodge the CL01 application form through ASIC Connect, pay the fee, and note the expected assessment period.
When this checklist applies
Use when a client needs an Australian Credit Licence to engage in credit activities as a lender, broker, lessor, or debt collector.
Common pitfalls
- Incorrectly assuming a credit representative authorisation covers all proposed activities
- Incomplete fit and proper assessments for overseas-based directors
- Responsible lending procedures that do not address hardship variation obligations
- Lodging without confirmed AFCA membership
- Underestimating the level of detail ASIC requires in the compliance framework
Run this checklist on a real matter
Quillio can identify credit activity types from product descriptions, draft responsible lending procedure outlines, and summarise ASIC RG 206 competence requirements.
General guidance for ACL application preparation. ASIC assessment outcomes depend on the applicant's specific circumstances — obtain specialist credit regulation advice.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
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