You’ve Mapped the Gaps.
Now Build the Framework.
A structured AI governance advisory engagement for AFSL holders who have completed their initial assessment and are ready to build a sustainable, Board-defensible AI framework — before December 2026.
AI Governance Isn’t a Document. It’s an Operating Practice.
Most AFSL holders approach AI compliance the way they approach a BAS lodgement — as a once-a-year event. But AI systems change continuously. New tools get adopted. Vendors update their models. Staff turnover creates knowledge gaps. Regulators issue new guidance.
A Governance Policy signed in March is not the same as a governance practice in December. The firms that will satisfy ASIC and the OAIC in 2026 and beyond are those that have built AI governance into how they operate — not those who filed a document and moved on.
The “set and forget” risk: ASIC’s focus is not on whether you have a policy. It is on whether your policy reflects reality. An ADM Register that hasn’t been updated since a vendor changed their model is not a defence — it is evidence of a governance gap.
Firms Ready to Move From Compliance to Capability
This engagement is designed for AFSL holders and accounting firms who have already taken their first compliance steps — and now need a structured approach to embedding governance into ongoing operations.
You’ve completed the AI Governance Dossier and need expert support to implement, customise, and embed the framework into your practice.
Your AI Governance Workshop delivered a 90-day roadmap. Now you need ongoing advisory support to execute it — and adapt as your AI stack evolves.
Your firm is actively expanding its AI toolset and needs governance to keep pace — procurement gates, use-case assessments, and bias reviews before each deployment.
You have an ASIC review, licence renewal, or PI insurer governance audit approaching and need your framework to be audit-ready and defensible.
Three Phases From Foundation to Full Governance
Every firm starts at a different point. Our advisory engagement meets you at your current maturity level and builds toward full, self-sustaining AI governance — with clear milestones at each phase.
Inventory, Policy & Disclosure
We establish the structural backbone of your governance framework — a complete ADM Register, your AI Governance & Usage Policy, your Accountability Map, and your client-facing disclosure documents. This phase closes your most critical regulatory exposure.
Oversight, Monitoring & Staff Capability
We build the operational cadences that turn your policy into practice — quarterly Board AI briefings, Logic Drift monitoring protocols, staff training and acceptable use compliance, and a vendor procurement gate for every new AI tool.
Innovation, Attestation & Competitive Advantage
Your governance framework is operational and defensible. We shift focus to strategic AI adoption — prioritising new use cases, measuring ROI, preparing attestation documentation for ASIC and your PI insurer, and turning your compliance posture into a client-facing trust asset.
What a Discovery & Strategy Engagement Delivers
Each engagement is scoped to your firm’s specific situation, tools, and phase. The following represents the core work delivered across a standard engagement.
We map your firm’s AI opportunities against the Quick Wins vs Strategic Bets matrix — identifying where AI delivers the highest value at the lowest governance risk.
A structured review of every in-scope system — including shadow AI tools — against APP 1.7 “meaningful terms” disclosure requirements. We identify gaps before regulators do.
A review across the four pillars — Infrastructure, Data Quality, Security, and Human Oversight — to identify where technical gaps could undermine governance commitments.
We apply the Australian AI Ethics Principles to your client-facing models — checking for proxy discrimination, fairness failures, and explainability gaps before they reach clients.
A prioritised 90-day action plan with clear ownership, milestones, and Board-ready reporting. Not a general framework — a specific plan for your firm’s structure and toolset.
Quarterly check-ins to update your ADM Register, review vendor changes, assess new use cases, and ensure your governance framework stays current as your AI stack evolves.
AI multiplies whatever you already are. If your data is fragmented, AI makes it a faster, more expensive mess. If your oversight is weak, AI scales the risk. Our engagement ensures your foundation is solid before your AI stack grows on top of it.
The Four Pillars We Assess in Every Engagement
AI governance is only as strong as the technical foundation beneath it. Building AI on top of fragmented data or legacy systems isn’t just inefficient — it creates regulatory liability. Our Technical Readiness Assessment evaluates your firm across four dimensions before any governance framework is designed.
Infrastructure
We map every AI and ADM tool in your environment, test traceability of decisions (can you reconstruct a decision made 6 months ago?), and assess whether your systems can sustain real-time automated decision-making.
Data Quality
We trace personal information from the point of collection to the AI engine, run bias and variance testing on your models, and audit data for completeness and timeliness — essential for the APP 1.7 “meaningful explanation” standard.
Security & Resilience
We test for prompt injection and model inversion vulnerabilities, review access controls on your AI models, and cross-walk your security posture against CPS 234, CPS 230, and APP 11 as applicable.
Human Capability
We assess whether your staff can explain an AI outcome to a client, run Board and Responsible Manager upskilling sessions, and establish Human-in-the-Loop protocols for high-impact automated decisions.
Ongoing advisory. Governance that evolves with your stack.
Start a Conversation →Start Your AI Discovery Engagement
Tell us about your firm and where you’re starting from. We’ll respond within one business day to discuss scope and next steps.
AI Discovery & Strategy EnquiryScoped to your firm · Response within 1 business day
↓ Complete your details below and we’ll be in touch to discuss your engagement
AI Governance Is Not a One-Time Project.
The firms that will be ready in December 2026 are the ones that started building their governance practice in 2025 — not the ones who scramble with a policy update in November.
Start a Conversation →Note: This engagement is scoped and priced based on your firm’s specific situation. There is no fixed rate. All enquiries receive a scoping response within one business day. Liberate Consulting provides GRC strategy and training. For specific legal advice regarding your AFSL obligations, please consult qualified legal counsel.