Annual Fee Consent & FDS: Paraplanner Compliance Checklist

Annual Fee Consent and FDS in 2025: A Paraplanner’s Audit-Ready Documentation Checklist

In financial advice, compliance is never a “set and forget” task. Each year brings new updates from regulators, changing expectations from licensees, and a sharper spotlight on record-keeping standards. For 2025, two areas continue to dominate compliance conversations: Annual Fee Consent and the Financial Disclosure Statement (FDS).

For advisers, getting these requirements right is non-negotiable. While behind the scenes, paraplanners play a crucial role in preparing, reviewing, and maintaining the files that make an advice practice audit-ready. Effective paraplanner support reduces compliance risk and ensures advisers meet client obligations accurately and on time.

This article outlines Annual Fee Consent and FDS requirements for 2025, explains the paraplanner’s compliance role, and provides an audit-ready documentation checklist.

Annual Fee Consent and FDS – A 2025 Refresher

What is Annual Fee Consent?

Annual Fee Consent is a legal requirement that ensures clients provide written permission for fees charged under an ongoing fee arrangement (OFA). Advisers cannot deduct fees from a client’s account without this valid consent, and it must be renewed every year.

The requirement for written client consent under an ongoing fee arrangement now stems from amendments introduced by the Delivering Better Financial Outcomes (DBFO) reforms. These are laid out in ASIC’s Info Sheet 286, which specifies that the new OFA consent rules apply to agreements entered on or after 10 January 2025, and also to existing ones from their first anniversary thereafter.

What is a Financial Disclosure Statement (FDS)?

An FDS details the services the client was promised in the previous year, what was actually delivered, and the fees charged. It also outlines the services and fees for the year ahead. For years, this was one of the cornerstones of client fee transparency.

However, from 2022 onward, there has been a removal of Financial Disclosure Statement requirements in some contexts, where consent forms have taken on greater importance. Yet many licensees still expect FDS-style disclosures, and paraplanners must remain vigilant about ASIC ongoing fee arrangement changes and individual licensee policies.

Together, these documents safeguard client interests and protect advisers from compliance breaches.

The Paraplanner’s Role in Compliance

While advisers face clients directly, paraplanners provide the backbone of compliance by ensuring all paperwork meets audit standards. Their responsibilities include:

Drafting and reviewing ongoing fee arrangement documentation.
Checking fee consent forms for accuracy against client agreements.
Ensuring the correct reference day ongoing fee consent is applied.
Identifying gaps in service vs. disclosure (one of the most common audit findings).
Creating a paraplanner audit-ready documentation checklist for every client file.

For auditors, a missing signature, mismatched numbers, or late disclosure can trigger compliance red flags. Paraplanners help prevent these by applying detail-oriented reviews before files reach final submission.

Audit-Ready Documentation Checklist

Here’s a practical checklist paraplanners can use in 2025 to prepare client files for audits.

A. Annual Fee Consent Documentation

Ensure the consent form requirements for OFA are met: services, fees, and period are clearly disclosed.
Confirm the client’s written and dated signature is on file.
Match consent details against client agreements and CRM records.
Record the reference day ongoing fee consent accurately to avoid fee collection lapses.
Track expiry dates and prepare renewal documentation in advance.

B. Financial Disclosure Statement (FDS)

Prepare an accurate summary of fees charged in the past 12 months.
Compare services promised vs. services delivered to highlight any gaps.
Check timing – was the FDS issued within 60 days of the anniversary date?
Keep delivery proof – email acknowledgment, CRM log, or digital receipt.
Cross-reference with adviser notes to confirm service delivery.

C. Supporting Records

Maintain notes in the CRM that align with fee consents and disclosures.
Save all client correspondence (letters, emails, reminders).
Keep adviser sign-off and paraplanner QA notes in the file.
Use consistent file naming and storage protocols for quick retrieval during audits.

Common Pitfalls to Avoid

Even with a structured process, some common issues continue to trip up advice practices:

Outdated templates – using older FDS or consent forms that don’t reflect current ASIC ongoing fee arrangement changes. Even though ASIC has temporarily adopted a “no-action” approach for missing account numbers (covering the period from 10 January to 5 September 2025), this is strictly conditional and expects advisers to renew consent promptly afterward, as reported by Mirage News.
Mismatched data – client fee amounts in the CRM not matching those in the disclosure.
No evidence of delivery – failing to keep proof that clients received their forms.
Late renewals – missing the anniversary deadline for OFA transition compliance, leaving clients without valid consent.

These issues may seem small, but can lead to serious compliance breaches during audits.

Best Practices for Paraplanners in 2025

To stay ahead, paraplanners should move beyond just “filling out forms” and embrace proactive compliance habits:

Use compliance technology – Systems that automatically track renewal dates and send reminders help avoid late consents.
Maintain a centralised register – Keep an internal log of all ongoing fee arrangement documentation for quick review.
Pre-audit file reviews – Before handing over to the adviser, run through a mini-audit using the checklist.
Collaborate closely with advisers – Regular communication ensures that promised services and disclosures are consistent.
Stay informed on regulatory shifts – Since ASIC regularly updates rules, paraplanners must remain alert to any ASIC ongoing fee arrangement changes.

Some businesses are also outsourcing financial services like fee consent management, CRM maintenance, and compliance reviews to specialist providers, ensuring documentation is both accurate and audit-ready without overwhelming in-house staff.

Looking Ahead: Why Audit-Ready Documentation Matters

The compliance environment will continue to evolve. While some requirements, like the removal of Financial Disclosure Statement obligations, have simplified parts of the process, this hasn’t reduced the scrutiny on practices. In fact, audits in 2025 are expected to focus more on whether advisers can demonstrate client consent clearly and consistently.

For paraplanners, this means every detail matters. Having a paraplanner audit-ready documentation checklist is not just about compliance, it’s about protecting the adviser, the licensee, and ultimately the client relationship. When files are clean, accurate, and complete, the advice practice can operate with greater confidence.

Key Takeaways

Annual Fee Consent remains essential, while FDS requirements have been streamlined under ASIC’s 2025 updates.
A clear documentation checklist helps paraplanners stay audit-ready and avoid compliance gaps.
Support from an outsourced paraplanner or internal staff ensures consistency and reduces compliance pressure.

Conclusion

Annual Fee Consent and the Financial Disclosure Statement remain at the heart of fee transparency and client trust in 2025. For advisers, the risks of non-compliance are high. For paraplanners, the opportunity to add value is equally high.

By applying the checklist above, staying across OFA transition compliance, and keeping up with ASIC ongoing fee arrangement changes, paraplanners ensure every client file stands up to audit scrutiny. Whether in-house or through an outsourced paraplanner, the discipline of keeping audit-ready files is what gives advisers confidence, protects clients, and strengthens the professionalism of the entire advice industry.

In the end, compliance is not just about avoiding penalties. It’s about demonstrating professionalism, respecting clients’ rights, and building a sustainable advice practice. And paraplanners are right at the center of making that happen.