The National Insurance Brokers Association has urged the federal government to reconsider its plan to introduce a client advice record regime.

It says document requirements set out in Treasury’s draft bill “may result in little practical change” for brokers that provide personal advice to retail clients.

The government intends to replace statement of advice requirements with the new record-keeping document under plans to overhaul financial advice laws.

Consultation on the document requirement and other proposed changes under the government’s second phase of reforms closed this month.

“Without more substantive changes to the underlying obligations and structure of advice documentation, the reforms risk maintaining the status quo under a different name,” NIBA says in its submission.

“We urge Treasury to consider a more outcomes-based approach that prioritises clarity, relevance and genuine utility for clients, while also recognising the practical realities faced by advisers.”

Explanatory materials for the Treasury Laws Amendment Bill 2025: Delivering Better Financial Outcomes say the client advice record requirements will mean information is presented in a way that helps a customer make an “informed decision” on taking advice.

“These requirements are intended to bring a client-centred focus to the [client advice record] and allow providers to have flexibility in providing it in a way that is responsive to the client’s needs,” the explanatory materials say. “It is meant to be technologically neutral, as a [client advice record] does not need to have the form of a written statement.”

Treasury says the requirements, depending on circumstances, will reduce the compliance burden on advice providers.

A written document may be appropriate when providing comprehensive advice to meet complex client needs, it says.

When relatively simple advice is provided, an audio recording or email will qualify as a client advice record.

But NIBA says the requirements still “closely mirror those of the [statement of advice], meaning that the reforms may result in little practical change. While NIBA notes that small changes have been made to encourage the provision of clear, concise and effective advice, on balance, these changes are unlikely to impact the length or complexity of advice documentation.

The association says while it supports the aim of improving financial advice, it remains concerned that replacing statements of advice with client advice records will not “meaningfully” reduce regulatory burden or enhance the client experience. 

See the submission here.