The Broker Times · Compliance Brief

A Growth Mandate for ASIC and APRA: What Was Proposed, and What Actually Changes on Your Files

Shadow treasurer Tim Wilson used a 20 October speech to float a Singapore-style dual mandate for Australia’s financial regulators. Here is where each broker obligation actually lives — and which ones a regulator mandate could not reach.

20 OctDate of the speech, delivered to the AFIA conference in Sydney and titled “The alternative agenda”
3 ptsAPRA’s serviceability buffer, left unchanged at its 28 May 2026 macroprudential update
NilReferences to brokers, mortgages, the best interests duty or responsible lending in the published speech text
2023Year the UK legislated a comparable secondary growth objective — the precedent Wilson cited himself

Proposal versus position

What was proposed
  • A dual mandate modelled on the Monetary Authority of Singapore, pairing supervision with a duty to help industry grow, compete and innovate
  • A “get to yes” posture, with ASIC, APRA and the RBA focused on enforcing against harm rather than restricting activity up front
  • Proportionate treatment of smaller operators so regulation “doesn’t become a barrier to entry”
  • Possibly heavier penalties where established operators cause harm
What changes on your files today
  • Nothing. This is an opposition proposal, not law, and no instrument has been amended
  • The best interests duty and the conflict priority rule continue to apply in full
  • ASIC’s REP 840 findings, published 13 October 2026, remain the live document shaping file-note expectations
  • APRA’s 3 percentage point buffer still sets the servicing test
Where each obligation actually lives
Obligation Where it sits Who would have to move it
Best interests duty Sections 158LA and 158LE, National Consumer Credit Protection Act 2009 Parliament, by amending the Act
Conflict priority rule Sections 158LB and 158LF of the same Act Parliament, by amending the Act
How the duty is interpreted and reviewed ASIC guidance (RG 273, June 2020) and review activity such as REP 840 ASIC, through guidance and surveillance posture
Serviceability buffer APRA macroprudential settings APRA, at a macroprudential update

The UK ran this experiment first. Britain gave its conduct and prudential regulators a secondary growth and competitiveness objective in 2023. Reviewing it in June 2025, the House of Lords Financial Services Regulation Committee called the objective “a valuable stimulus” but found a “culture of risk aversion” that was “deeply entrenched”, and said existing metrics “do little to track the impact of regulation on growth”. A mandate changed the statute faster than it changed behaviour.

The takeaway for brokers

A growth mandate is aimed at capital formation and market entry, not at the broker channel’s compliance load. The duty that drives your file notes is a statutory one, so it does not move because a regulator’s objectives are rewritten. Treat this as a signal about the direction of regulatory debate — and keep building files to the standard REP 840 describes.

Sources: Tim Wilson MP, “The alternative agenda”, speech to the AFIA Conference, 20 October 2026; The Adviser, 22 October 2026; ASIC RG 273 and REP 840; APRA macroprudential update, 28 May 2026; House of Lords Financial Services Regulation Committee, Growing pains: clarity and culture change required, June 2025. General information only — not compliance advice.

Compliance · Regulatory Outlook

Tim Wilson Floated a Singapore-Style Growth Mandate for ASIC and APRA. The Speech Never Mentions BID — and the UK’s 2023 Version Hit a “Deeply Entrenched” Culture

The shadow treasurer wants Australia’s regulators to carry an explicit duty to help industry grow. For brokers, the useful question is not whether that is a good idea — it is which of your obligations such a mandate could actually reach. On the evidence, not the one that drives your file notes.

The Broker Times22 October 2026Approx. 8 min read

A speech to a finance industry conference does not change a single obligation on a single file. But it does tell you where the regulatory debate is heading — and this one landed a week after ASIC published the most consequential review of broker conduct in years. Reading the two together is more useful than reading either alone.

What the shadow treasurer actually proposed

On 20 October, shadow treasurer Tim Wilson delivered a speech titled “The alternative agenda” to the Australian Finance Industry Association conference in Sydney. Its central proposition was that Australia’s financial regulators are pointed at the wrong target — and that the fix is structural rather than rhetorical.

Wilson’s diagnosis starts with incentives. Regulators, he argued, behave the way their mandates reward them for behaving:

“The incentive for regulators is to impose more complex regulation and costs on businesses.”

Tim Wilson MP, AFIA Conference, 20 October 2026

From there he drew a distinction that does real work in the speech: the difference between minimising risk and managing it. “Currently, regulators are tasked with minimising risk, and in some places compel it,” he said, describing the post-royal-commission settings as focused on minimisation rather than management.

The proposed remedy is a second mandate. “I am interested in adopting the Monetary Authority of Singapore’s dual mandate,” Wilson said — a model that pairs strict prudential and conduct supervision with an explicit obligation to develop the sector. Under that approach, ASIC and APRA would carry duties to help industry grow, compete and innovate alongside their existing functions. He noted that Britain legislated a comparable change in 2023, requiring its regulators to weigh competitiveness and growth and to report to Parliament on it.

Three further elements matter for anyone running a small licensed business:

  • A “get to yes” posture. Wilson said he wants ASIC, APRA and the Reserve Bank to focus on enforcement — framed not as more aggressive supervision for its own sake, but as acting against conduct that causes harm rather than defaulting to restricting activity in advance.
  • Proportionality for smaller operators. He called for “a focus on proportionate impacts for smaller operators” so that “regulation doesn’t become a barrier to entry”.
  • A trade-off on penalties. The quid pro quo he floated was “heavier penalties for breaches when harm is caused by established operators”.

He also made an argument about where risk has gone. “The consequence of the Hayne Royal Commission has not removed risk, it has just relocated it,” Wilson said, pointing to the way “higher risk or lower security businesses gravitate to private credit and non-bank lenders”. Brokers who have spent the past two years placing squeezed-but-bankable clients outside the majors will recognise the pattern being described, whatever they make of the policy conclusion.

What the speech does not say

Here is the part worth sitting with. The published text of the speech does not mention mortgage brokers. It does not mention the best interests duty. It does not mention responsible lending, home loans, or APRA’s serviceability buffer. Its credit references run to small business capital access, private credit and non-bank lenders.

That is not a criticism of the speech — it was addressed to a broad finance industry audience, and no speech covers everything. But it should calibrate expectations. When a senior political figure promises a regulatory reset, it is natural for a broker carrying a BID compliance load to hear it as relief coming. On the available text, the proposal is aimed at capital formation, market entry and the prudential perimeter, not at the conduct obligations that govern credit assistance.

The distinction that matters

Reporting of the speech in The Adviser on 22 October placed it alongside housing spokesman Andrew Bragg’s long-running challenge to APRA’s serviceability buffer. That context is the outlet’s, not the speech’s — the buffer does not appear in Wilson’s published remarks. Keep the two separate when you assess what has actually been committed to.

Why a regulator’s mandate cannot move the best interests duty

This is the structural point, and it is the reason a mandate debate and your file notes are further apart than they first appear.

The best interests duty is not an ASIC policy. It is a statutory obligation. ASIC’s guidance, Regulatory Guide 273: Mortgage brokers: Best interests duty, published in June 2020, explains that the duty requires a mortgage broker to act in the best interests of the consumer when providing credit assistance, and identifies its home as sections 158LA and 158LE of the National Consumer Credit Protection Act 2009. The companion conflict priority rule — requiring a broker to prioritise the consumer’s interests where a conflict arises — sits in sections 158LB and 158LF of the same Act.

Rewriting what ASIC and APRA are told to optimise for does not amend those sections. Changing the duty, narrowing it, or carving out parts of it would require Parliament to amend the Act. A statement of expectations cannot do it, and nor can a new objective bolted onto a regulator’s charter.

What a mandate could plausibly influence is posture: how ASIC prioritises surveillance, how it frames guidance, how proportionately it treats a two-person brokerage against a major licensee, and how quickly it reaches for enforcement rather than engagement. That is not nothing — posture is what most brokers actually experience of a regulator. But it is a different thing from the duty itself, and it is worth being precise about which one is in play.

The live document is still REP 840

ASIC published Mortgage brokers: Review of best interests duty and complaints — REP 840 — on 13 October 2026. That report, not a conference speech, is what will shape how your recorded reasons, cost comparisons and complaint handling are assessed over the next year.

If you were going to spend an hour this month on regulatory reading, spend it there. General information only — confirm how the findings apply to your own process with your licensee or compliance adviser.

The lever that could reach your files sits with APRA

Of the obligations that shape a broker’s working day, the serviceability buffer is the one most exposed to a change in regulatory philosophy — because it is a macroprudential setting rather than a statutory duty, and APRA can adjust it.

It has not. At its macroprudential update on 28 May 2026, APRA left the buffer at 3 percentage points, describing it as helping ensure that recent new borrowers can continue to service their loans. APRA Chair John Lonsdale said existing settings remained appropriate for now, adding that “the risk landscape is volatile and could evolve rapidly”. The release said lending standards were sound and did not mention brokers.

So the practical sequence for anyone hoping a philosophical shift translates into borrowing capacity is long: a change of government, then legislation creating a mandate, then APRA exercising judgement differently under it, then a macroprudential update. Each step is uncertain. None of it is a reason to tell a client in October 2026 that their capacity is about to improve, and a forecast of that kind has no place in a credit recommendation.

Both sides are already using the same language

It would be a mistake to read the speech as a clean partisan dividing line, because the government has already moved in a recognisably similar direction.

On 16 July 2026, Treasurer Jim Chalmers issued new Statements of Expectations for APRA and ASIC under the title “New Statements of Expectations for APRA and ASIC to focus more on growth”. The release said that “in both Statements there’s now a bigger emphasis on promoting growth”, that the government expects “the regulators to support growth and productivity through proportionate, risk-based regulation”, and referred to “reducing the regulatory burden on businesses”.

Read side by side, the vocabulary is close enough that the real difference is instrumental rather than directional. Chalmers has used statements of expectations, which set out the government’s expectations but do not alter a regulator’s statutory objectives. Wilson is canvassing a legislated dual mandate, which would. Whether that difference produces different regulator behaviour is precisely the question the UK has been testing.

The UK legislated this in 2023. The culture did not follow.

Britain gave its conduct and prudential regulators a secondary international competitiveness and growth objective in 2023 — the precedent Wilson cited. In June 2025, the House of Lords Financial Services Regulation Committee reported on how it had gone, in a report titled Growing pains: clarity and culture change required. The title is the finding.

The committee’s assessment was mixed in a specific and instructive way. It accepted the objective had been “a valuable stimulus for the regulators to increase their focus” on growth and competitiveness, and credited it with exposing long-standing barriers. But it described a “culture of risk aversion” that was “deeply entrenched and, if left unchanged, risks further undermining levels of trust” between regulators and industry, and concluded that “cultural change must be led from the top”. On measurement, it found that existing metrics “do little to track the impact of regulation on growth” and that regulators did not understand the cumulative burden of their own rules. On the link to the wider economy, it said “more research is needed”.

Notably, the committee did not frame growth and consumer protection as a straight trade-off, arguing that reform could proceed “whilst also maintaining high standards of financial stability and consumer protection”.

Why that precedent matters here

The UK experience suggests a legislated mandate changes the statute considerably faster than it changes the disposition of the person reviewing your file. For brokers, that is the forecast worth holding: even on the most favourable path, a mandate is a multi-year cultural project, not a compliance discount.

What to review this week

None of this requires you to change a process. It does make this a sensible moment to check that the processes you have are anchored to the instruments that actually bind, rather than to the regulatory mood.

A 30-minute audit

  1. Confirm your BID record keeps standing on its own. Your recorded reasons should explain why the recommended product suited this client’s circumstances and objectives — not why it was cheapest, and not by reference to what a regulator is currently emphasising.
  2. Re-read your conflict disclosures against the priority rule. Where ownership, panel composition or remuneration could create a conflict, check the file shows how the client’s interests were given priority.
  3. Map your process to REP 840’s findings, not to headlines about it. Work from the report or your licensee’s summary of it, and note any gap between what it describes and what your files currently show.
  4. Check your complaints and internal dispute resolution trail. Complaint handling in the broker channel has been under explicit review this month; make sure what you log matches what your licensee reports.
  5. Strip capacity forecasting out of client conversations. If anyone in your business is telling clients the buffer is likely to fall, stop it. APRA has held at 3 percentage points and flagged a volatile risk landscape.
  6. Raise the questions with your licensee, not the internet. If a specific obligation is unclear for your business model, that is a conversation with your aggregator’s compliance team or an independent legal adviser.

What to watch next

  • Whether a dual mandate appears in draft legislation. A speech is a position; an exposure draft with amendments to regulators’ statutory objectives is a policy. Until then, treat it as direction, not timetable.
  • Whether proportionality is defined. “Proportionate impacts for smaller operators” could mean scaled reporting, tiered guidance or simply a softer tone. For a small brokerage, the definition is the whole substance.
  • APRA’s next macroprudential update. This remains the only realistic near-term route to a change in assessed borrowing capacity.
  • Any movement on Part 3-5A of the Credit Act. If the best interests obligations themselves are ever revisited, it will show up as proposed amendments to the Act — and that is the development that would genuinely change your files.
  • The cost side of the ledger. Brokers are absorbing rising sector costs independently of all this; The Adviser reported on 16 October that aggregators had criticised an elevenfold jump in brokers’ CSLR special levy. A growth mandate does not address a levy set under a separate scheme.

The bottom line

The most valuable thing a broker can do with a speech like this is resist both available over-reactions. It is not a compliance reprieve: the duty that shapes your files is in the Credit Act, the review that will test them was published on 13 October, and the buffer that caps your clients’ capacity was held in May. Nor is it noise — when the opposition and the government are both using the language of proportionate, growth-conscious regulation, the medium-term direction of travel is reasonably clear, even if the vehicle is not.

The brokers who come out of the next 18 months well will be the ones whose files are built to the standard that currently applies, and who are therefore free to benefit from any loosening rather than scrambling to catch up if none arrives. Build for the rules on the books. Watch the rest.

Key takeaways

  • Shadow treasurer Tim Wilson used a 20 October AFIA conference speech to float a Monetary Authority of Singapore–style dual mandate for ASIC and APRA, with a “get to yes” posture, proportionality for smaller operators, and possibly heavier penalties where established operators cause harm.
  • The published speech text does not mention brokers, mortgages, the best interests duty, responsible lending or the serviceability buffer.
  • The best interests duty sits in sections 158LA and 158LE of the National Consumer Credit Protection Act 2009, with the conflict priority rule in sections 158LB and 158LF. Changing a regulator’s mandate would not amend those sections; Parliament would have to.
  • APRA held the serviceability buffer at 3 percentage points on 28 May 2026, with Chair John Lonsdale noting a volatile risk landscape. Capacity forecasting has no place in a client recommendation.
  • The government has used similar language already: Treasurer Jim Chalmers’ 16 July 2026 Statements of Expectations emphasised growth and “proportionate, risk-based regulation”.
  • When a House of Lords committee reviewed the UK’s 2023 equivalent in June 2025, it called the objective a valuable stimulus but found a “deeply entrenched” culture of risk aversion and metrics that “do little to track the impact of regulation on growth”.
  • Nothing changes on your files today. ASIC’s REP 840, published 13 October 2026, remains the document to work from.

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General information about where each obligation is located in the regulatory framework. It is not legal or compliance advice and does not describe everything an instrument requires. Confirm how any obligation applies to your business with your licensee’s compliance team or an independent legal adviser.

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.