The regulator reviewed 15 Australian financial services licensees and their representatives, focusing on activity between 1 January 2025 and 1 June 2026. Across that sample, lead generators referred 7,639 new clients to advisers, representing about 35 per cent of all new clients for those licensees. ASIC said around $678 million was switched or invested after those referrals, with about 90.6 per cent coming from superannuation savings.
The concern is not that every referral or marketing arrangement is automatically harmful. Lead generation can range from ordinary advertising to a handover of contact details. The regulatory problem emerges when unlicensed or unqualified people undertake tasks that should sit with an authorised adviser, such as fact-finding, risk profiling, discussing recommendations, presenting statements of advice or encouraging a particular product outcome.
For consumers, the practical lesson is to slow down when a conversation moves from a general offer of information to a recommendation about super, investments or retirement savings. Warning signs include pressure to act quickly, claims that an existing fund is performing poorly without a like-for-like comparison, offers of free super checks tied to sales calls, limited direct contact with a licensed adviser, or vague explanations of fees and product disclosure documents.
The findings also matter for advice businesses, comparison services and referral models. ASIC's message is that licensees remain responsible for supervision, records and conflicts even when a third party generates the initial customer contact. Heavy reliance on manual checks, limited access to call recordings and weak monitoring of recommendation patterns may leave consumers exposed and licensees vulnerable to enforcement action.
Australians considering financial advice should understand who is contacting them, whether the person is licensed or authorised, what role any referral partner plays and how fees may be paid. A legitimate advice process should leave room for questions, written disclosure and informed consent. Marketing may open the door to a conversation, but personal advice about superannuation and investments should come from properly authorised professionals acting under the obligations that apply to them.
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