No. In Australia, you do not need to hold an Australian Credit Licence (ACL) to refer clients to a licensed mortgage broker.
Under the National Consumer Credit Protection Act (NCCP Act), the activities that require an ACL or credit representative appointment are credit activities — specifically, providing credit assistance (suggesting, assisting with, or recommending a particular credit product), acting as an intermediary, or engaging in credit activities as a business. Making a referral — introducing a client to a licensed broker without providing any credit advice, assessment, or recommendation — does not constitute a credit activity.
The distinction is clear: the broker holds the licence and is responsible for all credit-related work. The referring professional’s role ends at the introduction.
What you must do (without an ACL):
– Disclose to your client that you are referring them to a third party and that you may receive a fee
– Not provide any credit advice, loan comparisons, or lending recommendations
– Ensure the referral is genuinely in the client’s interest
What the broker must do:
– Conduct a full credit assessment
– Compare options across their lender panel
– Provide compliant credit proposals and credit guide documentation
This division of responsibility is why mortgage referral programs are accessible to accountants, lawyers, real estate agents, financial planners, and other professionals without requiring them to obtain any finance qualification or licence.
