Free Resource · AFSL AI Compliance

The 10-Point AI Compliance Self-Check for AFSL Holders

Know where your firm stands before ASIC and the OAIC ask you to prove it. This free checklist identifies your exposure across the four obligations that matter most before December 2026.

  • Scope & Mapping — do your systems trigger APP 1.7 obligations?
  • Privacy Policy — does yours meet the "Meaningful Terms standard"?
  • Governance & Accountability — are your s912A obligations covered?
  • Human Oversight — do you have HITL controls that hold up to scrutiny?
  • Scoring guide — where you stand and what to do next

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Privacy Act APP 1.7 mandatory ADM disclosure obligations apply from 1 December 2026. Civil penalty exposure applies after this date — this checklist helps you understand your firm's position right now.

What's Inside

The Four Pillars Your Firm Is Assessed Against

The checklist evaluates your firm across the same four pillars used in the full AI Readiness Scorecard — giving you an honest picture of where your compliance gaps are before you engage with regulators or PI insurers.

01

Scope & Mapping

Do your AI systems "substantially and directly" influence decisions about individuals? This is the trigger threshold for your Privacy Act APP 1.7 obligations.

02

Transparency & Disclosure

Does your Privacy Policy explain your AI use in "Meaningful Terms"? OAIC expects plain-English disclosure of how decisions are made and what data is used.

03

Governance & Accountability

Are your internal AI policies aligned with ASIC s912A? Efficient, honest and fair service delivery requires documented supervision of automated systems.

04

Human Agency & Oversight

Do you have Human-in-the-Loop (HITL) controls and an explainability framework? Can your firm demonstrate how AI decisions can be reviewed and reversed?

How to Interpret Your Score

What Your Result Means for Your Firm

The checklist uses a 10-point scoring system. Each range maps directly to a risk level — and a recommended next step.

0–4
Critical Breach Risk

Your firm has significant unaddressed exposure. Immediate action is required before your next client interaction involving AI-assisted advice or decisioning.

5–7
Significant Compliance Gap

You have a foundation but material gaps remain. Your firm needs a structured remediation plan before the December 2026 deadline — not just intent to act.

8–10
Can You Prove It?

Your posture is strong — but can you document it? ASIC and OAIC expect evidence, not assurances. Your focus is on attestation, not remediation.

Checklist Done? Get the Full Picture.

The $97 AI Readiness Scorecard goes deeper — 20 questions, scored across all four pillars, with an Executive Readiness Report delivered immediately. Board-ready, ASIC-aligned, and built specifically for AFSL holders.

Get Your Executive Readiness Report — $97 →

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