You want to know whether an offshore paraplanning support person can write your Statements of Advice. They can produce the document. They cannot form the advice inside it and they cannot sign it. Supervision improves the quality of the work; it does not move who is legally responsible for the recommendation.
The other thing worth settling before you plan any of this: the Statement of Advice has not been replaced. If someone has told you it has, they are describing a proposal rather than a law.
The SoA is still the obligation
Under the Corporations Act 2001, a providing entity that gives personal advice to a retail client must give that client a Statement of Advice. Section 946A is the obligation, the Act allows limited exceptions such as a record of advice for further advice where circumstances have not materially changed, and ASIC sets out what it expects in Regulatory Guide 175. That is the framework you are working in on 10 August 2026, and the one your process should be built around.
The reform package that gets discussed as though it had already landed is Delivering Better Financial Outcomes. Tranche 1 is real and in force. The Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024 received assent on 9 July 2024, and ASIC's DBFO page sets out staged commencement dates running through to July 2025, covering ongoing fee arrangements, advice fee deductions and conflicted remuneration.
Tranche 2 proposed replacing the Statement of Advice with a Client Advice Record: a record the licensee keeps on file and gives the client on request, rather than one handed over as a matter of course. It appeared in an exposure draft released on 21 March 2025. It has not been enacted. In July 2026 the Minister for Financial Services, Daniel Mulino, declined to commit to a timetable for the remaining legislation, saying the government's broader response to the Shield and First Guardian collapses would come first. That response was flagged for mid-August 2026, so this may move soon.
So build around the SoA as it stands. There is an upside if you are designing a support role now: whoever maintains your document templates absorbs the change whenever it arrives, and template maintenance sits well with an offshore support officer.
What actually travels
Four things move offshore cleanly. They are also the four that fill a paraplanner's day without using a paraplanner's training.
Research preparation. Product and fund data pulled from your research tools and tabulated in your comparison format. Ratings, fee tables by APIR code, the current PDS and target market determination, insurance definitions set side by side. The comparison gets assembled. The conclusion does not get drawn.
Modelling inputs. Scenarios built in your modelling software to the adviser's written instruction, with your licensee's mandated assumption set applied and every input checked back to the fact find. Producing the output and interpreting it are two different acts, and only one of them travels.
Document assembly. Your licensee's approved template merged with client data, research and modelling. Appendices attached, fee and remuneration disclosure formatted correctly, cross-references checked, and the whole document read for internal consistency. That last step catches the wrong client name in paragraph nine and the figure that does not match the appendix.
Review preparation and scheduling. The rolling calendar of who is due, the client booked into the adviser's diary, and the pack built before the meeting instead of during it. This is usually the fastest visible win, which is why we treat it as a dedicated review coordinator role rather than a corner of someone else's job.
The first three are the core of a paraplanning support officer. The data collection and provider chasing that feeds them usually belongs with a client services officer, and in a smaller practice one person does both.
Where the adviser must sign
Write this table down before anyone starts, in your own words, and give a copy to the person doing the work. Arrangements come unstuck when the line lives in someone's head and nowhere else.
| Step | Support officer | Adviser |
|---|---|---|
| Scope and strategy | Records the agreed scope on the file | Decides the scope and constructs the strategy |
| Research | Pulls and tabulates the comparison | Selects the products and evidences why |
| Modelling | Enters inputs, applies the mandated assumptions | Sets the assumptions and interprets the outputs |
| Advice document | Assembles it from the approved template | Forms the advice, reviews and signs |
| Client questions | Says where the paperwork is up to | Answers anything touching product, strategy or performance |
| Fee consent | Prepares the form, tracks the anniversary | Has the fee conversation with the client |
| Money movement | Prepares the request | Authorises the release |
The best interests duty in section 961B of the Corporations Act 2001 sits with the relevant provider. A support officer can make that duty far easier to demonstrate by evidencing the file properly, filing the research against the file note and keeping the reasoning visible instead of remembered. The duty does not move, and neither does the judgement it requires.
The last row has no exceptions in any profession we staff. Nobody offshore holds bank authority, a payment token or platform release rights. They prepare, your authorised person releases. The same boundary across accounting, legal, broking and healthcare sits in one place: what you legally cannot delegate offshore in Australia.
Your licensee owns the arrangement
This is the part most practices skip, and it is one email. Licensees differ on outsourcing, data location and system access, and some run a formal approval process. Ask before you hire rather than after.
ASIC published its review of offshore outsourcing by financial services advice licensees on 10 October 2025, alongside media release 25-234MR. It examined ten licensees, and the main service being sent offshore was advice support: paraplanning and administration. That is exactly the arrangement you are contemplating.
The finding was that responsibility does not travel with the work. Choosing a provider with due skill and care, monitoring performance, controlling and auditing system access, and either disclosing the use of offshore providers in your Financial Services Guide or obtaining explicit client consent before client information reaches them all remain the licensee's obligations, alongside the general obligations in section 912A of the Corporations Act 2001.
Client data leaving Australia is its own question. A full financial position, and health information collected for insurance underwriting, are sensitive. Cross-border disclosure is governed by Australian Privacy Principle 8 under the Privacy Act 1988, and handling it properly is the licensee's responsibility. In practice the support officer works inside your systems as a named user with scoped access, so the data stays in your environment and every action is attributed. We cover the risks and the controls in is it safe to hire an offshore virtual assistant.
One more thing to check early: your planning and research software licence terms. Whether you can add a named user is a question for your provider, best answered before someone sits waiting for a login.
Write the instruction, not just the task
The failure mode in an advice practice is not a defiant team member. It is a capable one working from a verbal brief, making a reasonable decision, where reasonable and compliant are not quite the same thing.
So give the strategy instruction as a written artefact before production starts. What is being recommended, why, what alternatives were considered, which assumptions apply. If that instruction cannot be written, the document should not be started: the missing piece is the adviser's thinking, not the support officer's throughput.
Then make escalation the expected answer, not a sign of weakness. "I think this crosses into advice, can you take it" should be praised the first time it happens, because that is the sentence that keeps the arrangement safe. Practices that quietly reward getting on with it teach the opposite lesson.
Finally, version control. Track drafts so the version the adviser reviewed and signed is unambiguous, and so the file shows the exact document given to the client. That is what a licensee audit will ask for.
Where to start
Start with the overdue reviews rather than the advice documents. The backlog is finite, it addresses your largest compliance exposure first, and it produces client meetings quickly, so you find out early whether the arrangement works.
Research collation comes second, because the adviser checks it against their own judgement anyway and will spot a weak comparison. Document assembly comes third, once the person knows your templates and your clients. Template maintenance comes last, because it needs an understanding of what your licensee requires and why.
In that order, each stage is verifiable before the next one is trusted. In reverse, the first thing you find out is that someone rebuilt your SoA template from a misunderstanding.
What to do next
Three steps, in this order. Email your licensee and ask what their outsourcing policy requires. Write the one-page boundary, using the table above as a starting point, and get your adviser to agree to it. Then work out which of the four task groups is costing you the most adviser and paraplanner time.
If you want to talk through how the role is scoped, our financial planning practice support page sets out the full task list, and you can book a discovery call to work through your own boundary before you hire anyone.
This is general information, not legal or financial advice. Financial advice is regulated and your licensee's requirements will differ, so confirm your own obligations before you change how advice documents are produced.
How we would staff this: production around the adviser's signature
We hire a paraplanning support officer in the Philippines who works inside your planning and research software as their own named user, with scoped access and subject to your licensee's rules. We start them on the overdue review backlog rather than advice documents, because that backlog is finite, it addresses your largest compliance exposure first and it puts client meetings in the diary quickly, and where the review calendar turns out to be a job in itself we scope that as a review coordinator instead. From A$14 per hour plus GST full-time, no placement or exit fees, an initial three-month contract then month to month, and roughly two weeks from brief to first day.
- Clears the overdue review backlog first: who is due, booked into the adviser's diary, and the review pack built before the meeting instead of during it.
- Pulls product and fund data from your research tools and tabulates it in your comparison format: ratings, fee tables by APIR code, the current product disclosure statement and target market determination, insurance definitions side by side. Assembles the comparison; does not draw the conclusion.
- Enters modelling inputs to the adviser's written instruction, applies your licensee's mandated assumption set, and checks every input back to the fact find.
- Assembles the advice document from your licensee's approved template, with client data merged, appendices attached, fee and remuneration disclosure formatted and cross-references checked, then reads the whole document for internal consistency: the wrong client name in paragraph nine, the figure that does not match the appendix.
- Keeps version control and the file evidence trail so the version the adviser reviewed and signed is unambiguous, and maintains your templates as your licensee's requirements change.
- Forming the advice and signing the Statement of Advice: the scope, the strategy, product selection, the assumptions behind the modelling and the interpretation of its outputs. The best interests duty sits with the relevant provider and does not move.
- Any client conversation touching product, strategy, performance or fees, including the fee consent conversation.
- Releasing money. Nobody offshore holds bank authority, a payment token or platform release rights. They prepare the request; your authorised person authorises it.
- The licensee relationship: getting the outsourcing arrangement approved, and either disclosing in your Financial Services Guide that client information may go to an offshore provider or obtaining explicit client consent before it does.
Frequently asked questions
Do I have to tell clients my paraplanning is done offshore?
What is the difference between a paraplanner and a paraplanning support officer?
Can an offshore assistant have a login to my financial planning software?
How much does offshore paraplanning support cost in Australia?
Can an offshore support officer talk to my clients?
What if my licensee won't approve offshore outsourcing?
- Corporations Act 2001 (Cth) ss 912A, 946A, 961B — The Statement of Advice obligation for personal advice to retail clients, the best interests duty sitting with the relevant provider, and the licensee general obligations that outsourcing does not shift
- ASIC, Regulatory Guide 175 AFS licensing: Financial product advisers—Conduct and disclosure — What ASIC expects in a Statement of Advice and how the advice conduct and disclosure obligations are administered
- ASIC, "Review of offshore outsourcing – Financial services advice licensees", 10 October 2025 (companion media release 25-234MR) — That ten advice licensees were reviewed, that the main service sent offshore is advice support including paraplanning and administrative operations, that provider selection, performance monitoring and system access control stay with the licensee, and that the two disclosure routes are Financial Services Guide disclosure or explicit client consent before client information is provided
- Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Act 2024 (Cth), No. 67, 2024 — That DBFO tranche 1 is law, receiving royal assent on 9 July 2024, covering ongoing fee arrangements, advice fee deductions and conflicted remuneration
- Treasury, Delivering Better Financial Outcomes tranche 2 exposure draft legislation, released 21 March 2025 — That the Client Advice Record is a proposal released in exposure draft and not enacted, so the Statement of Advice still applies
- Privacy Act 1988 (Cth), Australian Privacy Principle 8, as explained in OAIC, APP Guidelines Chapter 8 — That cross-border disclosure of client personal and sensitive information is regulated and remains the disclosing entity's responsibility
- Professional Planner, "Mulino uncommitted to DBFO future as Shield, First Guardian policy response looms", 21 July 2026 — That the Minister for Financial Services has not committed to a timetable for the remaining DBFO legislation, with the Shield and First Guardian response coming first
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