Australia's corporate regulator has issued a final warning to financial advice firms that use lead generators, saying the practice may put their licences at risk. The warning follows a review that found more than $678 million was switched or invested after referrals from lead-generation services, with about 90 per cent of that money coming from superannuation.

The Australian Securities and Investments Commission (ASIC) published media release 26-270MR and Report 845, titled Lead generation advice models: Putting consumers and licensees at risk, on 9 November 2026. The review examined 15 Australian financial services licensees and their oversight of lead-generation services in personal financial advice between 1 January 2025 and 1 June 2026.

What the review found

Lead generators referred 7,639 new clients to the 15 licensees reviewed, equal to about 35 per cent of all new clients those businesses added in the period. More than $678 million was switched or invested as a result, and about 90.6 per cent of that money came from superannuation savings.

The licensees deducted $9.8 million in upfront fees and a further $4.5 million in annual ongoing fees from the clients referred through lead generation.

ASIC found that some licensees allowed lead generators, who were unlicensed or unqualified, to carry out specialist tasks in the advice process, including fact-finding, assessing a client's risk profile and discussing advice recommendations. Some were also permitted to conduct product research and provide Statements of Advice, the formal documents setting out personal advice.

A clear warning from the regulator

ASIC Commissioner Alan Kirkland said the findings send a clear warning to advice licensees. ASIC said firms that enable, ignore or fail to control such conduct risk action that may affect whether they stay licensed.

ASIC has also written to 15 professional indemnity insurers about the risks of high-volume superannuation switching advice models that use lead generators. Several insurers have confirmed they will consider those risks when underwriting relevant licensees, according to the report.

The regulator said it uses transparency, surveillance, superannuation trustee and insurer engagement, and enforcement to disrupt harmful models. In 2025-26 it removed or restricted 87 people and businesses, up from 58 a year earlier.

Why lead generation is under scrutiny

Lead generation covers marketing designed to create consumer interest and connect people with financial services businesses. ASIC is concerned that some lead-generation services in financial advice and superannuation may expose consumers to a risk of significant losses, particularly where they encourage people to switch superannuation funds unnecessarily.

Data brokers charged between A$0.50 and A$75 per lead, according to the report, and some referral partners received 80 to 100 per cent of the client's upfront advice fee, paid only if the client signed up.

The review follows the collapses of the First Guardian and Shield investment funds, which reports say cost more than 11,000 Australians around $1 billion from their superannuation accounts. ASIC said inclusion in its review is neither a finding of misconduct nor a sign of involvement in Shield or First Guardian.

What happens next

The federal government announced a reform package on 19 August 2026 aimed at strengthening consumer protections in superannuation and financial advice, including measures to curb harmful lead generation. That package is still pending, with ASIC supporting the work with Treasury.

ASIC has also published a list of known entities involved in lead generation, those acting as referral partners, and advice licensees or corporate authorised representatives that have acquired leads since 1 July 2024. An initial list of 44 entities was published in February 2026, with 19 more added in June 2026.

Consumers who are contacted about switching their superannuation can check ASIC's Moneysmart website for information on how lead generation works and what to look out for before acting on an offer.