A borrower who is about to hand over payslips, bank statements and a credit history may well check the broker first. On a mortgage broker’s website, three details answer that check: the Australian credit licence number, the credit representative number and the name of the licensee the broker works under. Shown in the right places, written the way ASIC shows them, they match what the borrower finds on ASIC’s register.
This guide sets out what each number is, where it goes on a broker’s site, how to write it, and the wording that sits around it, from the comparison rate beside an interest rate to the label on the enquiry button. ASIC’s own pages are linked throughout and are the place to confirm the current requirements.
General information, not legal advice
This guide is about what to show on a website. Check the current requirements with ASIC (1300 300 630), your licensee or your own adviser before you publish.
ACL number, credit representative number and licensee name
Three identifiers turn up on a broker’s paperwork, and they do different jobs. The licence belongs to the licensee, which may be a company the broker works under rather than the broker. The representative number belongs to the person or company the licensee has authorised to act for it.
| Identifier | What it is | Where it goes on the site |
|---|---|---|
| Australian credit licence number | ASIC allocates one to each credit licence when it is granted. If the licensee also holds an Australian financial services licence, the two numbers are the same. | The footer disclosure line beside the licensee's name, the credit guide, and the structured data |
| Credit representative number | ASIC allocates one to a person or company a licensee has authorised to act on its behalf. It stays with the representative if they move to another licensee. | The footer line, the team page beside the broker's name, and the representative's credit guide |
| The licensee's name | The person or company that holds the licence. It may be the aggregator or licensee the broker works under. | Beside the licence number, so the relationship between the broker and the licensee reads plainly |
A licensee authorises a credit representative in writing to carry out specified credit activities on its behalf. A representative that is a company can, with the licensee’s consent, sub-authorise individuals, who then become credit representatives of the licensee in their own right. That is why a broker business can have one representative number for the company and another for each broker in it, and why the team page is the place to show each one.
How to write the numbers
ASIC sets out how a licence number should be written. Its Information Sheet 103 (INFO 103) gives the format as “Australian credit licence 12345” and says the abbreviated form, such as “ACL 12345”, is not sufficient on its own. Where the licence is referred to more than once in a document, ASIC’s view is that the full description used once is enough, with the abbreviation after that.
On a website that works out neatly. The footer line uses the full wording on every page. The team page and the about page can use “ACL” after that, because the full wording is already on the same page. A representative number is written the same way: “credit representative number” in full, then the number.
A footer line, written out
- For a credit representative: the trading name and company, "Credit representative number" and the number, "authorised by" the licensee's name, "Australian credit licence" and its number.
- For a licensee: the company name, "Australian credit licence" and the number.
- For both: a link to the current credit guide, and a link to ASIC's Professional Registers Search.
INFO 103 also says the number does not have to be on other business documents, such as business cards and letterheads, though licensees should still make sure those are not confusing or misleading. A website is where a borrower goes to check, so it is worth showing the numbers there in full.
Where the numbers go on a broker’s website
This is how I set out the numbers on a broker’s site, so a borrower who checks finds them quickly and finds the same thing on every page and on the register.
- One disclosure line in the footerWritten in full, the way INFO 103 shows it, and stating the relationship between the broker and the licensee as it is. The footer is on every page, and it is where people look for the fine print.
- The credit guide one click from the footerAs a dated PDF or a printable page that can be saved. Keep only the current version up, so an old fee table or an old licensee never reaches a borrower.
- Each broker's number on the team pageWhere individual brokers are authorised in their own right, put each one's credit representative number under their name, next to the photo and phone number a client already looks at.
- The comparison rate beside every rateSame size, same contrast and in the same spot as the interest rate, with the warning on the same screen. No hover, tooltip or "see details" link to reveal it.
- Lender logos with a plain labelIf the site shows the lenders the broker can access, label the strip with what the relationship is, such as "Lenders on our panel". Nothing that reads as an endorsement by the lender.
- The same text in the structured dataThe licensee's name and the licence wording in the Organization markup match the footer, so search engines read what the borrower reads.
- Text, at a readable size, from one place in the codeText can be copied into the register search and read by a screen reader. Keeping the numbers in one place in the code means the footer, team page and markup change together.
- Checked before launchEach number checked on ASIC's Professional Registers Search, and the site shown to the licensee before it goes live.
The credit guide and the website
A credit guide sets out the broker’s or licensee’s name and contact details, the licence or credit representative number, the fees a borrower may pay, the commissions and other payments the broker is likely to receive, and how to make a complaint, including the details of AFCA, the external dispute resolution scheme. ASIC’s Information Sheet 146 (INFO 146) summarises what goes in it.
The credit guide is given to each client at the point the licensee’s process sets, and ASIC’s guidance covers how it can be given electronically. A copy on the website does a different job: it lets a borrower read how the broker is paid before booking a call. So publish it, link it from the footer, and keep the giving step where your licensee’s process puts it.
A few practical points for the website copy:
- Make it saveable. A PDF or a printable page that can be saved to a file and printed.
- Date it. Put the version date on the guide, so a borrower and the licensee can see which one they read.
- Keep one version live. Replace the file rather than adding a second, and keep the same web address so links in emails still work.
- Match the site. The fees and the commission wording on the “How I’m paid” page say the same as the guide.
Interest rates and the comparison rate
A broker’s site does not need a rate table to work. If rates are part of the pitch, though, a comparison rate goes with them. The National Credit Code requires a credit advertisement that states an annual percentage rate to include the comparison rate, identified as one and no less prominent than the interest rate or any repayment amount on the page, and it sets out how that works for a rate shown on screen. The warning that goes with it has a short form set by the National Credit Regulations:
“WARNING: This comparison rate is true only for the examples given and may not include all fees and charges. Different terms, fees or other loan amounts might result in a different comparison rate.”
ASIC’s Regulatory Guide 234 (RG 234) gives an example that fits web pages exactly: an interest rate published online where the consumer has to click through, or move the cursor over the rate, to see the comparison rate. On the site, that means the comparison rate and the warning sit beside the interest rate on the same screen, at the same size, on desktop and on a phone. A repayment calculator that shows a repayment amount brings the rate rules with it, so treat its results like a rate table and check them before launch.
Wording to use, and wording to leave off
Some words carry their own rules for credit licensees, and RG 234 gives ASIC’s view on others. The table lists the ones a broker’s website is likely to reach for, and what to write instead.
| Wording | Why to be careful | What to write instead |
|---|---|---|
| "Independent", "impartial", "unbiased" | The National Credit Act restricts these words, and terms of similar import, for credit licensees. The conditions include receiving no commission other than amounts rebated in full to clients. | Leave them off unless the licensee confirms in writing that they can be used. Say which lenders the broker compares and how the broker is paid. |
| "Financial counsellor", "financial counselling" | The Act restricts these too, with exceptions tied to financial counselling services. | Describe the service: helping a borrower compare loans and apply. |
| Holding out a licence or authority | The Act stops a person holding out that it holds a licence, or acts for a licensee, when that is not the case. | State the relationship as it is, in the footer and on the about page. |
| "Guaranteed acceptance", "pre-approved" | RG 234 says advertisements should not use these terms, and that claims of "instant" approval, "no-doc" products or "no credit checks" need care, because each application is assessed. | Label the button as what it is: "Book a call" or "Send an enquiry". |
| "100% success rate" | RG 234 gives this claim by a mortgage broking firm as an example ASIC was concerned about, because it suggested credit would be provided to all applicants. | Say what the broker does at each step, and let reviews speak for results. |
| Testimonials | RG 234 says testimonials from individuals should be attributed to them and should be authentic. | Quote real reviews as written, with the reviewer's name, and the client's permission. |
| Lender and ASIC logos | Third-party logos can suggest an association or backing that isn't there, and advertising must not reproduce ASIC's logo without ASIC's express approval. | A labelled lender panel strip, and a plain text link to ASIC's register. |
Your licensee and the website
ASIC’s Information Sheet 126 (INFO 126) says licensees have a continual obligation to monitor and supervise their representatives. If the licensee you are authorised under, which may be your aggregator, has a marketing approval process, it will be in your agreement with it or in its policies.
Ask before the build starts, not the week before launch. Find out what the licensee needs to see (the full site, the copy only, or the footer and credit guide), how long its review takes, and who signs it off. Then the review sits in the timeline, and the site goes live with the licensee’s approval rather than being changed afterwards.
How a client checks a broker on ASIC’s register
ASIC’s Professional Registers Search covers credit licensees and credit representatives, along with other registers. A link to it from the footer saves a borrower looking for it.
- Open the searchIn the Search ASIC registers box on asic.gov.au, choose Professional Registers.
- Search by name or numberAn individual or company name, a licence or registration number, an ACN or an ABN.
- Filter to the right registerChoose credit licensees or credit representatives. A person or company can appear on more than one register, so check the result is on the one you meant.
- Read the free entryName, licence or registration number, address, start date, status and any conditions.
- For a licensee, look at its representativesA licensee's entry lets you search its representatives by name and export the list as a PDF.
- Note when it was updatedASIC processes changes to the registers once a day, and the search shows when it was last updated.
When a number or authorisation changes
A credit representative number stays with the representative. INFO 126 says the licensee gives ASIC the representative’s existing number, if there is one, when it notifies a new appointment. When a broker moves to a new licensee, the licensee’s name and licence number on the site change, and the representative number does not.
When a representative’s details change or an authorisation ends, the licensee notifies ASIC and the register is updated. Change the footer, the credit guide and the team page in the same week, so the site and the register agree. With the numbers kept in one place in the site’s code, that is a single edit.
Sources
ASIC’s guidance and the legislation it refers to, each linked. Confirm the current version with ASIC before you publish.
National Consumer Credit Protection Act 2009
Licence and representative numbers, credit guides, restricted words and the National Credit Code.
National Consumer Credit Protection Regulations 2010
The comparison rate warning.
Regulatory Guide 234 Advertising financial products and services (including credit)
Prominence of the comparison rate, wording, testimonials and logos.
INFO 103 FAQs: Getting a credit licence
How the licence number is written.
INFO 146 Responsible lending disclosure obligations
What a credit guide contains and how it is given.
INFO 126 Credit representatives
Supervising representatives, and appointments.
The public register of credit licensees and representatives.
ASIC's phone number and online enquiry form.
Where Kovus fits
A Kovus site for a broker is built so the details ASIC and your licensee expect are easy to show: one disclosure line in the footer, each broker’s number on the team page, the credit guide one click away, and all of it kept in one place in the code so a change of licensee is a single edit. Each number is checked on the Professional Registers Search before launch, and you and your licensee approve the final wording. Website builds cost A$500 to A$1,000, with premium builds from A$1,000.
What else a broker’s site needs, from loan pages to the booking form, is on the websites for mortgage brokers page, and the other professional fields are on professional services.
Frequently asked questions
Where should a mortgage broker show the ACL number on a website?
In a disclosure line in the footer, so it is on every page, written in full as ASIC shows it: the licensee's name, then Australian credit licence and the number. A broker who is a credit representative puts their own name and credit representative number first, then the licensee's name and licence number. The same details go on the team page beside each broker, in the credit guide and in the site's structured data.
What is the difference between an ACL number and a credit representative number?
ASIC allocates an Australian credit licence number to each credit licence when it is granted. If the licensee also holds an Australian financial services licence, the two numbers are the same. ASIC allocates a credit representative number to a person or company a licensee has authorised to act on its behalf. A licensee's number goes in its credit guide, and a representative's number goes in the representative's own credit guide.
Can I write ACL 123456 instead of Australian credit licence 123456?
ASIC's Information Sheet 103 shows the format as Australian credit licence followed by the number, and says the abbreviated form, such as ACL 12345, is not sufficient by itself. Where the licence is mentioned more than once, ASIC's view is that the full description can be used once and the abbreviation after that. On a website, the footer line is the natural place for the full wording.
Should the credit guide be on my website?
A copy on the website lets a borrower read it before the first call, and it shows the representative number, the licensee and the dispute resolution details in one place. Publish it as a dated PDF or a printable page, keep only the current version up, and link it from the footer. Giving each client the guide is a separate step your licensee sets out, so the website copy sits alongside that, not in place of it.
How do I check a mortgage broker's credit representative number?
Use ASIC's Professional Registers Search, reached from the Search ASIC registers box on asic.gov.au. You can search by name, licence or registration number, ACN or ABN, and filter the results to the credit licensees or credit representatives register. The free entry shows the name, number, address, start date, status and any conditions.
Should a broker's website call the broker independent?
Leave it off unless your licensee confirms in writing that you can use it. The National Credit Act restricts words such as independent, impartial and unbiased for credit licensees, with conditions that include how the broker is paid. Describe what you do instead: the lenders you compare and how you are paid.
Does my licensee need to see the website before it goes live?
Ask before the build starts. ASIC says licensees have a continuing obligation to monitor and supervise their representatives, and if your licensee or aggregator has a marketing approval process, it will be in your agreement or its policies. Building the review into the timeline means the site launches with the licensee's sign-off rather than being changed afterwards.