The Broker Times · Compliance Briefing
The Retirement-Age Mortgage Has Moved Down the Age Range
Vanguard’s 2026 How Australia Retires study asked more than 1,800 Australians whether they expect to still owe money on their home when they stop working. The answers split by generation in a direction that changes which files carry the question.
Expect to retire with a mortgage, by generation
How they say they would deal with it
Would keep making repayments in retirement
Would consider using superannuation to clear the debt
May sell the property
Of Boomers surveyed already own outright
Where the line sits between your licence and someone else’s
The three guidance paragraphs that actually apply
“Higher housing costs, bigger debts and cost-of-living pressures are changing what retirement looks like.”
Daniel Shrimski, Managing Director Asia Pacific, Vanguard
The takeaway for your file
The exit-strategy conversation has been treated as a late-career conversation, because that is where lender credit policy tends to trigger it. The survey data points the other way: the cohorts furthest from retirement are the ones expecting to carry the debt there. Asking the timeframe question earlier costs you a line in the fact-find. It is what you do with the super answer that decides whether the file stays inside your licence.
Sources: Vanguard 2026 How Australia Retires as reported by Australian Broker, Savings.com.au and Livewire Markets (26 August 2026) and Broker Daily (28 August 2026); ASIC Regulatory Guide 209 (issued 9 December 2019, last modified 6 March 2025); ASIC Regulatory Guide 273; ASIC Regulatory Guide 36. General information only — not legal or compliance advice.
Compliance · Best Interests Duty
48% of Gen Z Expect to Retire With a Mortgage. The 39% Who’d Use Super to Clear It Are the File-Note Problem
Vanguard’s new retirement study puts a number on something brokers have been hearing in fact-finds for years. The number itself is not the story. The story is that the repayment strategy a third of them name sits on the other side of a licence you probably do not hold.
In this article
- What the Vanguard data actually says
- Why this lands on brokers before it lands on advisers
- The guidance was written for the other end of the age range
- The super answer is where your licence stops
- What BID actually asks of you here
- The term question you are probably not asking
- A four-line file note that does the work
- What to review this week
A client in their late twenties tells you they assume they will still be paying the house off when they stop working, and that super will sort out whatever is left. Nothing about that sentence stops the deal. Nothing about it triggers a lender policy. And for most brokers, nothing about it makes it into the file.
Vanguard’s 2026 How Australia Retires study, reported across the trade and financial press in the last week of August, suggests that sentence is now a majority-adjacent view among the youngest borrowers in the market. It is worth being precise about what the study measured, because the broker implications sit in the detail rather than the headline.
What the Vanguard data actually says
The study surveyed more than 1,800 Australians. On the question of carrying housing debt into retirement, the generational spread reported by the trade and financial press runs like this: 48 per cent of Gen Z respondents expect to retire with a mortgage, against 37 per cent of Millennials, 23 per cent of Gen X and 24 per cent of Baby Boomers. Seventy-one per cent of the Boomers surveyed already own their homes outright.
Among those who expect to retire still owing money, the reported split of what they would do about it is roughly 45 per cent continuing to make repayments, 39 per cent looking to superannuation to clear the balance, and 16 per cent open to selling the property.
A note on the 39 per cent. Coverage of this figure is not consistent. Australian Broker and Savings.com.au reported it as respondents expecting to pay the debt off using superannuation in a single lump sum; Livewire Markets reported it as respondents who would consider using superannuation. That is a meaningful difference between a plan and a possibility, and we have not been able to check either wording against the underlying report. Treat it as a stated inclination, not a settled strategy — which, as it happens, is exactly how it should be treated in a file note.
The other figure worth carrying into client conversations is the expectation gap on income. Australians under 45 in the survey put the household income they will need in retirement at more than $90,000 a year. Australians already aged 65 and over reported needing around $60,000. Younger borrowers are, on these numbers, anchoring to a materially higher retirement cost base than the people currently living it — while also expecting to service a mortgage out of it.
“Higher housing costs, bigger debts and cost-of-living pressures are changing what retirement looks like.”
Daniel Shrimski, Managing Director Asia Pacific, Vanguard
Why this lands on brokers before it lands on advisers
Broker Daily’s coverage of the study reported that only 27 per cent of Australians use an ongoing relationship with a broker or financial adviser for retirement planning. Almost everyone who buys a house, on the other hand, sits down with a broker. For a large share of borrowers, the conversation in your office is the only structured conversation they will have about a thirty-year financial commitment before they sign it.
That is not an argument for brokers to start doing retirement planning. It is the opposite. It is an argument for being deliberate about which parts of that conversation belong to you, which parts belong to someone else, and how the handover gets recorded — because the client will not draw that line, and the file is the only place it exists.
The client’s assumption is not the problem. The problem is a file that neither captured the assumption nor showed what you did with it.
The direction of the generational data matters here too. Home ownership among Australians in the run-up to retirement has been drifting down for decades: the Australian Institute of Health and Welfare, drawing on Census data, reports the ownership rate for 50–54-year-olds fell from 80 per cent in 1996 to 72 per cent in 2021. The cohorts behind them start from a later entry point and a larger loan. Expectations about retiring in debt are, on that reading, less a shift in attitude than an arithmetic result.
The guidance was written for the other end of the age range
Most brokers meet the retirement question through lender credit policy: a loan term that finishes past a nominated age triggers a request for evidence of how the borrower will keep meeting repayments. Thresholds, acceptable evidence and how strictly it is applied differ from lender to lender, and the only reliable source on any given file is the current policy document, not what the BDM said last year.
ASIC’s guidance is narrower than most brokers assume. Regulatory Guide 209 — issued 9 December 2019 and still in force, last modified 6 March 2025 — addresses this under reasonably foreseeable reductions in income. RG 209.64 puts it this way: “if a consumer is approaching retirement, and will still be making repayments on the credit product after their expected retirement age, you will need to determine whether this event is likely to change their income”.
Read that carefully. The trigger in the guidance is a consumer approaching retirement. It is a direction to test an income assumption, not a rulebook for exit strategies. And RG 209.51(b) lists among the information you need on requirements and objectives “the timeframe for which the credit product is required” — which applies to every borrower on every file, regardless of age.
Where a client raises selling an asset as the answer, RG 209.80 is the relevant paragraph. It accepts that “assets may also, in some cases, be available to be sold by the consumer to enable them to meet financial obligations under a credit product if needed”, while directing you to establish whether the consumer is actually expecting to use assets that way and whether those assets will be sufficient. Note the two halves: intention and sufficiency. A file that records the intention and says nothing about sufficiency has done half the work.
The practical gap. Lender policy asks the exit-strategy question at one end of the age range. The survey data says the expectation is concentrated at the other. Nothing requires you to run an exit-strategy assessment for a 28-year-old — and this article is not suggesting you should. What it costs you to ask the timeframe question early is one line in the fact-find. What it buys you is a file that shows you understood the client’s actual horizon at the time you recommended a thirty-year term.
The super answer is where your licence stops
This is the part of the conversation that carries genuine exposure, and it has nothing to do with credit.
Superannuation is a financial product. ASIC’s Regulatory Guide 36 sets out that a recommendation or statement of opinion is financial product advice under s766B of the Corporations Act where “it is intended to influence a person or persons in making a decision about a particular financial product or class of financial products… or could reasonably be regarded as being intended to have such an influence”. It becomes personal advice where the provider has considered one or more of the person’s objectives, financial situation and needs — or where a reasonable person might expect them to have done so. RG 36 also restates the licensing position: you need an AFS licence to carry on a financial services business unless an exemption applies. A credit licence is not that licence, and a credit representative authorisation does not extend to it.
Now apply that to a fact-find. Your client, sitting across from you, having just handed you their entire financial position, says they will use their super to clear the mortgage. Consider what different responses look like against that test:
| What you do | How it reads |
|---|---|
| “Noted — I’ll record that as your intention.” | Recording a client’s stated position. Ordinary fact-find conduct. |
| “That’s a common approach. Plenty of clients do that.” | Getting closer to a statement of opinion about a financial product, offered to someone whose circumstances you have just reviewed. |
| “Based on your balance and contributions, that should be enough.” | An opinion about a financial product, formed on their objectives and financial situation. |
| “Let’s structure the loan around clearing it with super at 60.” | A credit recommendation whose foundation is a superannuation strategy you are not authorised to give. |
Nobody sets out to give super advice. It arrives conversationally, in the reassurance reflex — the client sounds anxious, you want to settle them, and the sentence that settles them is the one that endorses their plan. The discipline is to separate the two jobs out loud: you record what they intend, you tell them plainly that you have not assessed whether it works, and you point them to someone who can.
Worth checking before you rely on it: preservation age and condition-of-release rules govern when superannuation can actually be accessed, and the tax treatment of a lump-sum withdrawal used to clear a mortgage is not uniform. Those are questions for a licensed adviser, not for a broker — and not for an assumption embedded in your servicing conversation.
What BID actually asks of you here
The best interests duty does not require you to solve a client’s retirement. It does require you to have considered the right things. Regulatory Guide 273 lists among the relevant factors “the consumer’s needs and objectives (including the term of the loan, the amount to be borrowed and the outcome the consumer would like to achieve)” at RG 273.48(b), “the consumer’s personal circumstances and financial situation, to the extent that they could affect the suitability of different products” at RG 273.48(c), and “reasonably foreseeable changes to the consumer’s personal circumstances and financial situation” at RG 273.48(d).
RG 273 also puts weight on cost: RG 273.51 notes that “the cost of a credit product can significantly affect the outcome the consumer achieves, as well as their other objectives”, and RG 273.54 warns that “a failure to consider cost and investigate the lowest cost options available to the consumer may suggest non-compliance”.
Loan term is a cost lever, and it is the one most often set by default rather than by decision. Where a client’s stated objective is to not still be paying this off at 67, a thirty-year term selected without discussion is a term that works against the objective sitting in your own fact-find. That is not a hypothetical audit risk — it is an inconsistency any reviewer can see on the face of the file.
The term question you are probably not asking
Three practical points follow, and none of them require new systems.
1. The term resets, and nobody mentions it
A borrower who refinances at 38 into a fresh thirty-year term has moved their debt-free date from 63 to 68 in a transaction sold as a saving. The monthly saving is real. The extension is also real, and it is frequently the larger number over the life of the loan. Clients rarely raise it. Raising it yourself is both a BID-consistent act and, in commercial terms, the sort of thing that gets remembered at the next refinance.
2. Top-ups compound the same effect
Each top-up written to the standard term does the same thing again. Where the client’s objective involves a finish date, the alternative — matching the remaining term or holding repayments constant — is worth putting in front of them and recording, whether or not they take it.
3. Ask once, early, in plain words
“What age would you like this paid off by?” is a single question. It produces an objective in the client’s own words, which is precisely the raw material RG 273.48(b) is asking about, and it gives the term recommendation something to sit against.
A four-line file note that does the work
Where a client raises retirement debt or superannuation, four lines in the notes cover the ground. Adapt the wording to your licensee’s template rather than lifting it verbatim.
- What they said, in their words. “Client stated they expect to still have a mortgage at retirement and would look to use superannuation to clear the balance.” Their statement, attributed to them.
- The timeframe objective. “Client’s stated preference is to have the loan repaid by age [x]. Term of [y] years discussed against this.” This is the RG 273.48(b) and RG 209.51(b) point in one line.
- The boundary, stated. “Advised that as a credit representative I have not assessed and cannot advise on the use of superannuation, and that this should be discussed with a licensed financial adviser. Client acknowledged.”
- What the assessment rests on. “Serviceability assessed on current verified income. No reliance placed on superannuation access or asset sale in this assessment.” This is the line that matters most, because it shows the credit recommendation stands independently of the strategy you did not give.
Key takeaways
- Vanguard’s 2026 study reports 48 per cent of Gen Z and 37 per cent of Millennials expect to retire with a mortgage — higher than Gen X (23 per cent) or Boomers (24 per cent).
- Of those expecting to carry the debt, around 39 per cent point to superannuation as the way it gets cleared. Coverage differs on whether that is a firm plan or something they would consider.
- RG 209.64 directs you to test the income assumption where a consumer is approaching retirement. It does not create an exit-strategy obligation for younger borrowers — the operative constraint there is lender credit policy, which varies.
- Recording a client’s superannuation intention is ordinary fact-find conduct. Confirming it will work, or building the loan structure on it, moves toward financial product advice as described in RG 36, which a credit licence does not authorise.
- Loan term is a cost lever under RG 273.51 and RG 273.54, and it resets on every refinance and top-up. Asking what age the client wants the loan gone by is a one-question fix.
What to review this week
- Pull the last ten files where the borrower was over 45 at settlement. Does any note record a stated finish-date objective, or only the term the lender defaulted to?
- Check your fact-find template. Is there a field for the client’s target repayment age? If not, adding one is a ten-minute change with a direct line to RG 273.48(b).
- Confirm the current exit-strategy thresholds and accepted evidence for your top five lenders from their policy documents. Written down, dated, in one place.
- Agree the wording your business uses when a client raises superannuation, so that every broker and support staff member says the same thing and records it the same way.
- Check with your licensee whether your file-note template already covers the advice boundary, and whether they want particular wording used.
The strategic read
None of this is urgent in the way a policy change or a rate move is urgent. No deadline attaches to it and no lender is about to require anything new. That is exactly why it is worth ten minutes now: the exposure it creates is slow, it accumulates quietly across a book, and it surfaces years later in a complaint about a conversation nobody wrote down.
The Vanguard numbers are a survey of expectations, not a forecast of outcomes. Plenty of the Gen Z respondents who expect to retire in debt will not. But the expectation is already in the room, and it is arriving in fact-finds with a proposed solution attached — one that sits on the far side of a licensing boundary. Brokers who get the habit right now, while it is a two-minute conversation and four lines of notes, will not have to retrofit it across a decade of files later.
Broker FAQ
Generally no — lender exit-strategy requirements are credit policy and are typically triggered by the loan term finishing past a nominated age, not by a borrower’s stated expectations. RG 209.64 frames the income question around consumers approaching retirement. The point of this article is not that a new obligation exists for younger borrowers, but that the timeframe question in RG 209.51(b) applies to every file, and asking it early is cheap. Check the specific thresholds with each lender on your panel.
Recording what a client tells you, attributed to them as their stated intention, is ordinary fact-find practice. The distinction to hold is between recording an intention and endorsing or assessing it. It is also worth noting explicitly that your serviceability assessment does not rely on it. Your licensee may have a preferred form of words — use theirs.
ASIC’s RG 36 describes financial product advice as a recommendation or statement of opinion intended to influence, or that could reasonably be regarded as intended to influence, a person’s decision about a financial product. It becomes personal advice where you have considered the person’s objectives, financial situation or needs, or where a reasonable person would expect you to have done so. Providing it generally requires an AFS licence or authorisation. This is general information rather than a legal opinion — if you are unsure where a particular conversation sits, raise it with your licensee before you have it again.
No. A shorter term raises the minimum repayment and can reduce buffer and flexibility, which may cut against the client’s circumstances under RG 273.48(c). The BID point is that the term should be a considered recommendation weighed against the client’s stated objectives and the cost of the product, and that the reasoning should be visible in the file — not that shorter is always better.
It comes from Vanguard’s 2026 How Australia Retires study of more than 1,800 Australians, and reached us through trade and financial press coverage published on 26 and 28 August 2026. Those outlets differ on whether respondents expect to use super or would consider it, and we were not able to verify the wording against the underlying report. Use it as a signal about how common the assumption is, not as a precise measure.
Breaking news for modern brokers
Lender policy, regulator activity and market data, read for what it changes on your files.
Sources. Vanguard 2026 How Australia Retires (survey of more than 1,800 Australians), as reported by Australian Broker, Savings.com.au and Livewire Markets on 26 August 2026 and Broker Daily on 28 August 2026. ASIC Regulatory Guide 209 Credit licensing: Responsible lending conduct, issued 9 December 2019, last modified 6 March 2025 (RG 209.51(b), RG 209.64, RG 209.80). ASIC Regulatory Guide 273 Mortgage brokers: Best interests duty (RG 273.48, RG 273.51, RG 273.54). ASIC Regulatory Guide 36 Licensing: Financial product advice and dealing. Australian Institute of Health and Welfare, Home ownership and housing tenure (Census-based, page last updated 16 October 2025).
Interactive · Broker Tool
The Retirement-Debt Conversation: Three Checks Before Your Next Fact-Find
Work through what to say when a client raises superannuation, what a term actually does to their finish age, and what belongs in the file. Nothing you enter leaves your browser.
Pick the line closest to what your client said. The tool shows where the response sits against ASIC’s guidance and suggests wording for the file. General information only — use your licensee’s approved wording.
Choose a statement above to see the read.
A refinance into a fresh term moves the debt-free date as well as the repayment. This is arithmetic on the numbers you enter — no rates, no assumptions, nothing stored.
Five items for any file where retirement debt or superannuation came up in conversation. Tick as you go — the count is for your own use and is not saved.
General information for Australian mortgage brokers, not legal or compliance advice. Confirm your own obligations and file-note wording with your licensee or aggregator compliance team.
Disclaimer: This article is for general information and professional development purposes only. It does not constitute legal, compliance, or financial advice. Brokers should consult their aggregator’s compliance team and, where required, seek independent legal advice regarding their obligations under the National Consumer Credit Protection Act 2009 and ASIC’s responsible lending guidelines.
