Credit Guide: Obligations, Content and When to Provide

A clear, compliant credit guide is a small document that carries big regulatory weight. If you work in credit operations, compliance or brokerage, you need the essentials: what a credit guide must include, exactly when to give it, and how to evidence delivery — especially in digital channels. This guide gives practical, auditable steps for creating a compliant credit disclosure document that supports responsible lending and reduces enforcement risk.

What is a credit guide?

A credit guide is a prescribed disclosure document that explains the credit assistance role being offered, identifies the credit licensee and representative, and sets out how you handle fees, commissions, complaints and privacy. Its role in the credit lifecycle is simple but essential: enable informed consent and transparency before a consumer receives credit assistance.

It is a disclosure, not a contract. It explains who you are, how you are paid, and how a consumer can make a complaint. The credit guide forms part of the responsible lending disclosure set that supports broader responsible lending obligations. It also helps evidence that a consumer was informed about the relationship and remuneration before you proceeded with credit assistance, whether the product is a personal loan, vehicle finance or other credit product.

A well-drafted credit guide reduces regulatory risk, supports good customer outcomes and makes audits easier. Keep it short, plain-language and prominently available at first contact and before application.

Why credit guides matter

Credit guides exist to secure transparency and informed decision-making. Regulators expect credit licensees and representatives to give consumers the information necessary to choose and complain, reducing surprises about fees, commissions and conflicts of interest.

The National Consumer Credit Protection Act and ASIC guidance require disclosure aligned with responsible lending principles — to ensure consumers are not given unsuitable credit. ASIC enforces disclosure requirements and treats failures to give required documents as actionable conduct under its enforcement powers.

For consumers, the credit guide is the first practical tool to compare advisers, check licence details and understand how a broker or representative is paid. A clear credit guide increases transparency about remuneration and conflicts of interest, helps consumers understand dispute resolution routes, and supports responsible lending checks that underpin safe credit provision. For compliance teams, it demonstrates a commitment to fair treatment and helps manage remediation risk.

Who must give a credit guide?

You must provide a credit guide where your activities fall within the credit assistance regime. The usual parties are:

Credit licensees are entities holding an Australian credit licence and must ensure consumers receive a credit guide from the licensee or from an authorised representative.

Credit representatives and brokers who act as a mortgage broker or credit representative giving credit assistance must have the consumer receive a credit guide at the relevant times.

Aggregators and groups: When an aggregator relationship exists, the aggregator and the member broker must coordinate — the licensee remains responsible for ensuring the guide is provided even if the representative issues it.

The credit licence holder retains ultimate responsibility for compliance even where authorised representatives distribute guides. If your business only introduces customers without providing credit assistance, different disclosure triggers may apply. Practical tip: map every front-line role (broker, call-centre adviser, online chatbot) to a delivery owner so it is clear who issues the credit guide and records delivery.

When must a credit guide be provided?

Timing is critical. The regulatory expectation is that a credit guide is provided early enough to allow an informed choice but before credit assistance escalates.

At first contact where credit assistance is on offer: If a consumer first contacts you and you begin to discuss options, provide the credit guide at or before that first substantive discussion.

Before any credit assistance is provided: If you provide tailored advice, recommendations or steps to obtain credit, the guide should be given prior to that assistance.

Before the consumer applies: At a minimum, provide it before the consumer signs an application or gives consent to proceed.

At point of face-to-face meetings and telephone calls: If your process starts with a face-to-face meeting, give the guide verbally and follow up with a written copy; for phone calls, email or SMS a link during the call then confirm delivery in writing.

Best practice examples include: if a broker runs a web form that pre-screens a customer, display a conspicuous link to the credit guide on the form and require an acknowledgement before the form submits. For a walk-in client requesting tailored recommendations, hand a paper guide at the outset and keep a signed acknowledgement in the file. Err on the side of early delivery. If you're unsure whether a specific interaction is "credit assistance", provide the guide.

How to give the credit guide

You can deliver a credit guide in multiple formats; the key questions are readability and evidence of delivery.

Paper (in-person): Hand a printed guide and obtain a dated acknowledgement.

Email: Attach a PDF or include a prominent link. Preserve email headers and delivery logs.

Website link/download: Host a current guide on your site and provide a unique URL or time-stamped download; record the URL and the timestamp of access.

SMS with link: For short interactions, SMS a link to the guide, then record the timestamp of the SMS dispatch and any click-through logs.

In-app display: Present the guide in-app with a required checkbox or e-signature confirming the consumer has received and had the opportunity to read the guide.

Electronic evidence and auditability are essential. Save email headers, server logs, download logs and any click-through analytics. Use CRM fields to capture delivery method, date/time (UTC and local), recipient details and which version of the guide was sent.

Provide plain-language text, large-font or high-contrast versions, and offer translated summaries if your customer need profile requires it. If you collect an electronic acknowledgement, ensure the flow does not require pre-ticked boxes and that consent is freely given. Use an e-acknowledgement mechanism that captures who acknowledged, when, and which version of the guide was displayed. You do not need to describe technical implementation details in the guide — only that an auditable acknowledgement is retained.

Required content of a credit guide

A credit guide must be concise but comprehensive. Include mandatory elements plus a short remuneration summary and dispute process.

Licence details: Full name of the credit licensee and Australian Credit Licence (ACL) number.

Contact details: Postal address, phone, email and office hours.

Representative details: Name of the representative or broker, and their relationship to the licensee.

Services offered: A brief description of the credit assistance you provide (e.g., home loans, personal loans, vehicle finance).

Remuneration summary: How you are paid (fees, commissions) and an indicative range or example amounts in AUD where possible.

Conflicts of interest: Material relationships with lenders, aggregators or product issuers.

Privacy and handling consumer data: A short statement with a link to full privacy policy.

Dispute resolution: Internal complaint process, expected timeframes and external dispute body details.

How you can be contacted for further information.

Suggested additional disclosures include: examples of typical fees (e.g., broker fee ranges), an example commission percentage, and whether you receive volume payments. A short plain-English note on responsible lending obligations and credit application implications is helpful. Accessibility options and translated summary availability should be offered.

Sample short wording snippets: Licence: "ABC Pty Ltd — Australian Credit Licence 123456". Remuneration: "We may receive a commission from the lender. Typical commissions range from 0.50%–1.50% of the loan amount for home loans. You may also be asked to pay a broker fee of $X–$Y." Complaints: "If you have a complaint, contact us at complaints@abc.com.au. If unresolved within 30 days, you may escalate to the external dispute resolution scheme at [EDR body link]."

Ensure text is plain-language and avoids legalese. Keep the guide to one or two pages where possible.

Combining disclosure documents

Combining documents can reduce document fatigue but increases legal risk. You may combine a credit guide with other disclosures only where doing so does not obscure required information or breach timing rules.

Required content must be clearly presented and separately identifiable. If combining, use headings and an initial contents box that flags the credit guide section. If another document is delivered earlier or later, the combined document must still be provided at the required trigger point. Do not hide remuneration summaries or dispute processes behind long terms and conditions.

Risks when combining include: consumers may miss the credit guide if buried in larger documents — this raises contravention risk. Auditability becomes harder if you cannot prove the consumer received and read the credit guide section.

Best practice: If you combine, extract the credit guide as a clear, standalone section with its own version number and timestamp. Provide an executive summary and require an acknowledgement for the guide portion.

Exemptions and special rules

There are limited circumstances where the strict guide delivery requirements differ.

Introductory-only interactions: If you only introduce a customer to another credit provider and provide no credit assistance or recommendations, the rules may differ. Document the scope of the interaction and, if unclear, provide the guide.

Corporate customers: Some large commercial credit transactions may fall outside consumer credit rules; however, if dealing with individuals or small businesses for consumer-style credit products, the guide is expected.

Third-party intermediaries: If an aggregator or franchisor handles disclosures centrally, document the arrangement and keep evidence that the licensee satisfied its obligations.

Conservative approach: When in doubt, provide the credit guide. This reduces enforcement and remediation risk and supports consumer expectations.

Record-keeping, monitoring and audit trails

Robust records are the backbone of compliance. Your systems should capture delivery events, guide versions and consumer acknowledgements.

Retention period: Keep records for at least seven years after the last relevant interaction or as required under applicable law and company policy.

CRM metadata to capture:

• Guide version ID (e.g., "Credit Guide v1.0 — 2025-03-01")
• Delivery method (email/SMS/in-person/website)
• Date/time of delivery (UTC and local)
• Recipient name, DOB and contact details
• Evidence file (email header, download log, screenshot of in-app acknowledgement)
• Responsible staff ID or representative ARN
• Notes on any follow-up required

Practical CRM fields to implement: guide_version, delivery_method, delivery_timestamp, evidence_file_id, rep_id, case_id, acknowledgement_boolean.

Automate monthly reports showing delivery rates, missing acknowledgements and out-of-date guide versions. Implement a version control system with publish/unpublish functionality for public guides. Use random file audits to confirm evidence quality and completeness.

Example audit log entry:

Enforcement and consequences

Failing to give a credit guide can attract ASIC attention and regulatory consequences, particularly when non-disclosure is part of broader misconduct.

ASIC can issue infringement notices, civil penalty proceedings, enforce remediation and pursue banning orders where non-compliance is systemic. Penalties vary with severity: from enforceable undertakings and remediation to fines and licence conditions. Consumer remediation may be required where a failure to disclose materially affected consumer decisions.

ASIC media releases and enforcement outcomes frequently highlight disclosure failures tied to remuneration and conflicts of interest. Public enforcement outcomes commonly require remedial payments and improved disclosure processes.

Practical impact on business: Remediation costs and reputational damage can exceed the short-term savings from skipping disclosures. Poor disclosure controls increase compliance team workload during investigations and audits.

When designing controls, document everything, keep version history, and provide plain-language disclosures.

Compliance checklist and sample template

One-page checklist:

• Licence name and ACL number present
• Representative name & relationship stated
• Contact details included (phone, email, postal)
• Short description of services
• Remuneration summary (fees/commissions)
• Conflicts of interest disclosed
• Privacy statement and link to policy
• Complaint handling steps and EDR contacts
• Delivery method and date recorded in CRM
• Guide version number and publication date recorded

Sample credit guide template (v1.0 — adapt and review with legal):

Credit Guide — [Licensee Name] (Version v1.0 — 2026-01-01)

1. Who we are

[Licensee Name] — Australian Credit Licence 123456

Contact: PO Box 123, City | Phone: 1300 000 000 | Email: info@licensee.com

2. Who you are dealing with

Your adviser: [Name], Representative of [Licensee Name]

3. What we do

We can provide credit assistance for products including personal loans, vehicle finance and home loan referrals.

4. How we are paid

We may receive fees and commissions from lenders. Typical broker commissions are between 0.50%–1.50% of the loan amount. You may also be asked to pay a broker fee. We will provide a tailored disclosure at application.

5. Conflicts of interest

We maintain commercial relationships with a panel of lenders. Material relationships will be disclosed in your Statement of Credit Assistance.

6. Privacy and complaints

We collect personal information to assist you. Full privacy details: [privacy policy link]. If you have a complaint contact: complaints@[licensee].com. If unresolved, contact the external dispute resolution scheme: [EDR link].

7. Further information

Ask us if you want this guide in large print or another language.

This template is for information only — consult your legal or compliance team before relying on it.

FAQ

Further reading

• ASIC — Responsible lending disclosure obligations: https://www.asic.gov.au/regulatory-resources/credit/responsible-lending/responsible-lending-disclosure-obligations-overview-for-credit-licensees-and-representatives/
• ASIC — Enforcement resources and media releases: https://asic.gov.au/about-asic/news-centre/find-a-media-release/
• MoneySmart — Credit guide glossary: https://moneysmart.gov.au/glossary/credit-guide
• National Consumer Credit Protection Act 2009: https://www.legislation.gov.au/Series/C2009A00035

Key takeaways

A concise, plain-language credit guide delivered at the right time and supported by clear audit evidence is a powerful control that protects consumers and reduces regulatory risk. Make the guide easy to find, keep version history, capture acknowledgements, and err on the side of providing the guide early.

This article is general information only and is not legal, tax or financial advice.