How long does an AFSL application take? (And how to move faster with a CAR)

How long does an AFSL application take?

According to its service charter, ASIC aims to decide 70% of complete AFSL applications within 150 days, and 90% within 240 days. It beat both in 2024–25, deciding 77% of new AFS licence applications inside 150 days and 91% inside 240.  The constraint isn't ASIC's pace, it's that the clock only starts once ASIC has a complete application.

At a glance:

• The 150 and 240-day timelines are measured from a complete application, not from the day you start preparing
• The preparation beforehand and final steps afterwards sit outside that timeline
• Success isn’t guaranteed. Roughly a third of new AFS licence applications ASIC finalised in 2024–25 didn't result in a licence 
• A corporate authorised representative (CAR) arrangement is a different route to starting a fund

Why ASIC’s timeline and your timeline are different 

ASIC measures from the point it receives a complete AFSL application. Your timeline starts earlier and finishes later.

AFSL preparation involves: working out which services you need to be licensed for, lining up the people who'll run the business, gathering background documents, and building the compliance systems your application describes. ASIC expects those systems in place at the time you apply, because the obligations start the day the licence does. Even working alongside advisers, this stage can run into months.

Once your application is lodged, ASIC might request more information. Applications often take longer if they raise complex or new policy issues, or if you haven't given ASIC everything it needs. 

What happens at each stage of an AFSL application?

Sources: ASIC's licence application FAQs and the ASIC service charter.

What can derail your AFSL application or make it take longer than expected?

There are four main reasons why AFSL applications stall or take longer than fund managers might expect.  

The application gets returned. ASIC didn’t accept 138 applications for lodgement in 2024–25 (comprising 12% of the total number of applications it finalised). This figure covers all AFS and credit licence applications, including variations.

Withdrawals. A further 187 applications were withdrawn in 2024–25 (16% of those finalised, on the same basis). Withdrawing after ASIC has accepted your application means forfeiting the fee.

Questions from ASIC. These take time for you to reply to and gather documentation if needed, and for ASIC to review. Note that if ASIC requests more information via a formal notice and you miss the deadline it sets, your application is treated as withdrawn, with no right of appeal and no fee refund. Extensions are available, but only if you ask before the date passes.

Finding the right people. ASIC assesses whether you can run the business by looking at the people who'll be running it. They each need to meet a combination of qualifications and experience, and ASIC expects you to name at least two Responsible Managers. It also weighs whether they've got enough time available. For a small team, finding the second person is a common source of delay.

Applying for an AFSL doesn’t mean you’ll receive one

ASIC granted 290 new AFS licences in 2024–25 (68% of the applications it finalised). The rest were refused, rejected or withdrawn.

There's a middle ground between the two though. Where an applicant falls short, ASIC might talk through alternatives instead of refusing outright. That might mean limiting you to wholesale clients, narrowing the advice you can give, asking for a different person to run the business, or granting the AFSL with additional conditions attached. 

What conditions on an AFSL mean

Every AFSL comes with conditions. ASIC publishes a standard set that applies to most licences, and there might also be additional conditions on top of those. 

In 2024–25, 42% of approved AFSL applications had at least one additional regulatory outcome – 467 outcomes imposed in total. This covers both new applications and variations.

The extra conditions ASIC adds

Of those 467 additional regulatory outcomes ASIC imposed, 302 were key person conditions. 

This condition names one or two specific people on your licence, on the basis that the business depends on them. ASIC applies it where a licensee leans heavily on the knowledge and skill of one or two of the people running it, giving the example of a small firm with one or two principals. 

If a named person leaves or steps out of the role, you have five business days to notify ASIC in writing, naming a replacement or explaining why there isn't one. Changing the condition means applying to amend the licence, and ASIC assesses that much as it does a new application. Across a 10 to 12 year fund life, that affects how freely you can restructure, take extended leave, hire a partner or step back.

What does an AFSL application cost?

The application fee is typically a few thousand dollars, depending on what you apply for, whether you're an individual or a company, whether you deal with retail or wholesale clients, and whether you lodge online or on paper. 

Preparation usually costs considerably more – in our experience, expect roughly $10,000–$70,000 in legal, compliance and adviser fees, depending on how much you outsource.

The largest cost isn't a fee at all. If you wait for the licence before raising, a nine-month delay to first close defers management fee income, pushes back the vintage on a 10 to 12 year fund, and means the deals you're looking at now close without you. On a $20m first close at 2%, that's around $300,000 of deferred fee income. Several times the cost of the application itself. That cost is only unavoidable if waiting is your only option, which is where a CAR arrangement comes in.  

What does holding your own AFSL actually involve?

An AFSL isn't a milestone you reach and move past. The obligations start on the day it takes effect, which is why ASIC wants your systems built before it grants one.

As a licensee you're responsible for:

• Providing your financial services efficiently, honestly and fairly
• Maintaining competence to provide the services on your licence, with representatives who are trained and competent
• Managing conflicts of interest
• Complying with your licence conditions and the financial services laws, and taking reasonable steps to ensure your representatives do the same
• Holding adequate financial, technological and human resources
• Maintaining adequate risk management systems

Then there are the mechanical requirements. Your financial position is tested continuously, so you need to be able to pay debts as they fall due and hold more assets than liabilities. Most licensees also keep a rolling forecast covering at least the next three months, though ASIC allows several ways to meet that requirement. Annual accounts and an auditor's report go to ASIC each year, and certain breaches have to be reported within 30 days.

What can you do while you wait for an AFSL?

Offering interests in a fund is a financial service, so you need to be licensed or appointed under someone else's licence before you raise capital. You can test the market by sharing your thesis and having exploratory conversations with prospective LPs, as long as you stop short of making an offer or accepting money.

You can also settle your structure, finalise legal drafting, appoint your auditor, register entities, open fund accounts, start your ESVCLP or VCLP registration, and build the operational side including investor onboarding, AML/CTF obligations, reporting systems and record keeping. You’d need to do all this as an AFS licence holder anyway, so it’s worth getting a head start. 

How much faster is a corporate authorised representative (CAR) arrangement?

In comparison, a CAR arrangement typically takes days to weeks, instead of months. It removes ASIC’s assessment period from your timeline. There's no licence application for ASIC to assess and no 150-240 day decision window. Instead, an existing AFS licensee appoints you in writing, then tells ASIC within 30 business days. It also means you don’t need to spend months preparing an AFSL application. Under a CAR arrangement, the AFS licensee should do their own due diligence to be confident about you operating under their licence. 

Here’s a comparison of the responsibilities under your own AFSL versus a CAR arrangement.

Can you operate as a CAR and apply for your own AFSL at the same time?

Yes, and it's a common sequence for managers who want to deploy a first fund without waiting on an AFSL decision. 

A CAR arrangement does need to be genuine though. You're providing financial services as a representative of the licensee, which means working inside what their licence covers and under their supervision. An arrangement that exists on paper while the manager operates independently isn't a representative one at all.

Which licensing path is right for your fund?

It generally comes down to what the wait costs you. Your own AFSL will likely require months of preparation plus an assessment period of about 150-240 days, and leaves you carrying the obligations. A CAR arrangement removes the assessment period and shifts the licensing burden to someone who already holds it, at the cost of operating inside their framework.

Your own licence is the better answer once that framework starts to bind. If your strategy needs authorisations your licensee doesn't hold, if an LP mandate requires you to be licensed in your own right, or if you want to appoint representatives of your own, a CAR arrangement can't get you there. There's also the dependency: your ability to operate rests on someone else's licence staying in good standing and their risk appetite staying where it is. For managers at that point, the assessment period is a cost worth paying, and the preparation is work you'd be doing anyway. 

For a deeper comparison between AFSL and CAR arrangements, read our full guide. And if you're weighing up the decision for your first fund, feel free to book a time with our team.

This article is general information about AFS licensing in Australia, current as at 15 September 2026. It doesn't take your circumstances into account and isn't legal, tax or financial advice. Regulatory requirements change, and your obligations depend on your specific structure. Please obtain your own advice before acting. To see how Ventari supports fund managers, please get in touch.