Life insurance commissions (DBFO Act): How to ensure your disclosure and informed consent process meets ASIC requirement for 10 July 2025?

From 10 July 2025, if you receive insurance commission from life insurance products and provide personal advice to a client, you must adhere to the following disclosure requirements:

  • obtain the client’s prior informed consent to receive the commission
  • keep a record of the written consent or a written record of any verbal consent, and
  • give the client a copy of the written consent.
  • name of the insurer
  • rate of the commission
  • frequency with which you will receive the commissions
  • nature of the services that you will provide to the client in relation to the relevant product (if any)
  • statement that it is a requirement of the law that the client’s consent must be obtained before the payment of an insurance commission, and
  • statement that the client’s consent, once provided, is irrevocable.

The information sheet (INFO 292), states the following requirements:

  • Clients are not considered to have provided informed consent if the information is not clearly identifiable.
  • If the rate of renewal commission is higher than the rate previously disclosed to the client, or you propose to increase the frequency, you will need to obtain new consent from the client.
  • If you want to vary the existing insurance that was issued to the client or issue new insurance to an existing client, including if requested from the client, you will need to meet the informed consent requirement again for the new or varied insurance.
  • There is no explicit provision to give the insurer a copy of the client’s consent, however, they may ask for a copy as part of their compliance or risk mitigation.

For more information, see: