ASIC Lead Generation Review: 35% of Clients at 15 Licensees

November 10, 2026. The Australian Securities and Investments Commission (ASIC) published Report 845 on November 9, with a media release headlined as a "final warning to licensees" that "using lead generators may put your licence at risk." ASIC reviewed 15 financial advice licensees, and Commissioner Alan Kirkland said that across them "lead generators referred 7,639 new clients to financial advisers from January 2025 to June 2026, representing 35% of all new clients," with "more than $678 million being switched or invested, with approximately 90% coming from superannuation savings." For any agency that generates or calls leads for a regulated client, the findings read like an audit list: who discussed advice, what the scripts said, and whether recordings were kept.

What ASIC found

1. Lead generators in the advice process. ASIC found that some licensees "allowed lead generators to undertake specialist tasks such as fact-finding, assessment of clients' risk profiles and discussing advice recommendations."
2. Potentially misleading and fear-based pitches. Some lead generators used "potentially misleading statements, fear-based claims and non-like-for-like performance comparisons to encourage consumers to review their superannuation or switch investments."
3. Gaps in recordings and scripts. The report says "Not all licensees included in our review kept or retained call recordings or provided call scripts during the relevant period." ASIC drew its examples from call scripts and recordings it obtained.
4. Weak controls at some licensees. ASIC found "inadequate controls by some licensees, including limited access to lead generator call recordings, heavy reliance on manual supervision, insufficient monitoring of product recommendation patterns and inadequate limits on adviser client volumes."
5. Fees earned. Advice businesses received A$9.8 million in initial fees, "with commitments to a further $4.5 million in ongoing fees."

What comes next

Kirkland said ASIC welcomes the Government's proposed reforms but "will continue to take enforcement action under current laws where we find evidence of serious consumer harm." ASIC notes the Government announced those reforms on August 19, 2026, "including measures to curb harmful lead generation practices." ASIC published an initial list of 44 entities in February 2026 and added 19 in June 2026, a list it describes as "known entities involved in lead generation." Its cases include proceedings against Clark Family "over allegations it misled consumers by promoting financial product comparisons while selling their enquiries to the highest-bidding broker." Super Review reported the A$678 million figure on November 9.

What lead generation agencies should check

ASIC's warning is aimed at licensees, and several of its findings concern what lead generators said and did. We suggest four checks for any agency running campaigns for a regulated client:

1. Record and keep every call and script. Missing or hard-to-reach recordings were among the control gaps ASIC found.
2. Keep advice with the adviser. Kirkland said: "Licensees must ensure that only authorised advisers provide personal advice." Fact-finding, risk profiling and recommendations were the tasks ASIC flagged.
3. Drop the bait. ASIC lists free superannuation "health checks", prizes such as gift cards, and offers to find and consolidate "lost super" for free, among warning signs for consumers.
4. Check the calling rules. Our cold calling laws in Australia guide covers the Do Not Call Register and calling hours.

This is general information, not legal or financial advice. We sell B2B lead generation and build AI calling systems that log recordings, transcripts and opt-outs, so we have a stake in how lead generation rules develop. For the US version of this problem, see the FTC's warning letters to health plan lead generators and our insurance lead generation cost guide.