ASIC warns of risks in super lead-gen advice models
More than $678 million was switched or invested through advice models involving lead generators, with about 90% of the money coming from superannuation savings, according to an ASIC review of 15 advice licensees. The findings, based on an examination of 15 advice licensees, highlight risks to consumers and licensees alike when third-party lead generators play a role in the advice process.
The review, titled REP 845 Lead generation advice models: Putting consumers and licensees at risk, found that lead generators were involved in specialist parts of the advice process, including gathering client information, assessing risk profiles and discussing recommendations. The review assessed licensees’ supervision and monitoring of lead generation services in personal financial advice practices from 1 January 2025 to 1 June 2026.
Across the 15 licensees reviewed, lead generators referred 7,639 new clients to financial advisers from January 2025 to June 2026, representing 35% of all new clients. Advice businesses also received $9.8 million in initial fees, with commitments to a further $4.5 million in ongoing fees.
ASIC identified concerns with the way some lead generators operate, including the use of misleading statements, fear-based claims and comparisons that did not compare like-for-like performance, used to encourage consumers to review their super or switch investments. The regulator also found gaps in licensees’ oversight of lead generators, such as limited access to call recordings, reliance on manual supervision, insufficient monitoring of product recommendations and inadequate limits on adviser client volumes. These weaknesses exposed consumers to unacceptable risks, particularly given the scale of business generated through the arrangements.
ASIC Commissioner Alan Kirkland warned that the findings could jeopardize the licenses of firms using or allowing lead generation services. He stated that the regulator’s previous work had exposed how business models involving slick sales tactics to convince people to switch their super can expose Australians to serious financial harm.
“Commercial incentives must not come at the expense of consumers,” Kirkland said. “Licensees must identify and prohibit arrangements that may compromise the quality of advice or expose consumers to harm. They must ensure that only authorised advisers provide personal advice, and that those advisers act in the best interests of their clients.”
ASIC’s Enforcement Actions and Regulatory Push for Legislation
ASIC has expanded its oversight of high-risk superannuation switching models, releasing two lists of involved entities—one in February 2026 with 44 names and another in June with 19 additional firms. The regulator has also pursued enforcement actions against lead generators and financial advisers, including proceedings over alleged misleading representations and advice failings, and five-year bans for two advisers over flawed superannuation advice models involving third-party marketers.
