Every self-managed super fund needs an Investment strategy, and trustees often turn to their Accountant for help with it. That help is entirely legitimate, up to a point. But the line between assisting with a strategy document and giving financial product advice is a regulated one, and an accountant without an Australian financial services licence must stay on the right side of it. Understanding which documents and services an accountant can provide without a licence protects both the Trustee and the accountant, and it clears up a genuinely confusing area. This article draws the boundary in practical terms.

Why the licence question arises

The old accountants' exemption, which once let recognised accountants advise on establishing an SMSF, was removed in 2016. Since then, advice about acquiring or disposing of an interest in an SMSF, and financial product advice more broadly, generally requires an AFS licence or authorisation, including a limited licence tailored to SMSF services.

That change reshaped what accountants can do. Much of their traditional work, tax, compliance and administration, is unaffected, but anything that amounts to recommending a financial product or an investment strategy now sits behind the licensing line. The investment strategy document is right at the edge of that boundary, which is why it causes confusion.

The distinction is not about the document's title but about whether the accountant is reflecting the trustees' decisions or making recommendations of their own.

Documenting the trustees' own decisions

An accountant can help trustees articulate and record the investment decisions the trustees themselves have made. If the trustees have decided how they want the fund invested, the accountant can help put that into a properly structured investment strategy document, using appropriate terminology and making sure the required matters are addressed.

This is drafting and articulation, not advice. The trustees Supply the substance, the choices about asset allocation and risk, and the accountant helps express it clearly and compliantly. Provided the accountant is not steering those choices, this support does not require a licence and is a valuable service.

Providing factual information

An accountant can also provide factual information about what an investment strategy must address. They can explain that the law requires the trustees to consider matters such as the risk and return of investments, diversification, liquidity, the ability to meet liabilities, and whether to hold insurance for members. Explaining these requirements is factual, not advisory.

Similarly, an accountant can provide general information and tax advice, including the tax implications of particular decisions, so long as it does not tip over into recommending a financial product. Factual information and properly confined tax advice are squarely within an accountant's remit.

Comparing strategy to actual investments

A useful and permissible service is checking whether the fund's documented strategy matches its actual investments. An accountant can compare the two and point out where they diverge, for example where a strategy says one thing but the portfolio does another, prompting the trustees to either adjust their investments or revisit the document.

This is compliance-focused and factual: it identifies a mismatch without recommending what the trustees should hold instead. Flagging that the strategy and the portfolio have drifted apart is different from advising how to bring them back together through particular investments.

Where the licence becomes necessary

The licence line is crossed when the accountant recommends what the fund's strategy should be, advises the trustees to make particular investments, or suggests they modify their investments or strategy in a specific direction. Recommending an asset allocation, a product, or a change of course is financial product advice that generally requires a licence.

So a template the accountant fills in to reflect the trustees' choices is fine; a document in which the accountant decides the allocations and recommends them to passive trustees is not. The same document can be either, depending on whose decisions it records. That is the heart of the confusion, and the key to resolving it.

Getting the roles right

In practice, the cleanest approach is explicit about roles. The trustees make and own the investment decisions; the accountant documents them, supplies factual information and tax advice, and checks the strategy against the portfolio; and where the trustees want a recommendation on the strategy or specific investments, a licensed financial adviser provides it.

That division keeps everyone within their authority and gives the trustees a strategy that is both compliant and genuinely theirs. Trustees who understand it can ask their accountant for the right kind of help without inadvertently asking them to step outside their licence. This article is general information, not legal, tax or financial advice about any particular fund.

An accountant unsure of where a request falls will often, and rightly, decline to give a recommendation and point the trustee to a licensed adviser; that caution is a sign of a well-run practice, not an unhelpful one.

It helps to see why the rules are drawn this way rather than resenting them as red tape. Financial product advice carries obligations, to act in the client's best interests, to hold professional Indemnity cover and to meet Training standards, that exist to protect consumers making significant decisions about their retirement savings. The licensing line is the mechanism that ensures whoever recommends an investment strategy or a product is accountable under that framework. An accountant documenting the trustees' own choices is doing something genuinely different from an adviser recommending a course of action, and the law treats them differently for good reason.

For trustees, the practical benefit of understanding this is a smoother relationship with their accountant. Knowing what to ask for, help articulating and documenting decisions the trustees have made, rather than a recommendation on what to invest in, means the trustee gets useful help without putting the accountant in an awkward position. And when the trustee does want a genuine recommendation, they know to seek a licensed adviser, which is the right source for that advice anyway.

Practical takeaway

Without an AFS licence, an accountant can document the investment decisions the trustees have made, provide factual information about what a strategy must address, give confined tax advice, and check whether the strategy matches the fund's actual investments. What requires a licence is recommending the strategy itself, particular investments, or a specific change of course. The same document can be compliant or not depending on whose decisions it records, so keep the roles clear and use a licensed adviser for genuine recommendations.