ASIC RG 234 — ASIC Regulatory Guide – RG 234 Advertising financial products and services (including credit)

Page 1 REGULATORY GUIDE 234 Advertising financial products and services (including credit) June 2026 About this guide This guide is for promoters of financial products, financial advice services, credit products and credit services, and publishers of advertising for these products and services. It contains guidance to help promoters comply with their legal obligations not to make false or misleading statements or engage in misleading or deceptive conduct. Page 2 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 2 About ASIC regulatory documents In administering legislation ASIC issues the following types of regulatory documents. Consultation papers: seek feedback from stakeholders on matters ASIC is considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:  explaining when and how ASIC will exercise specific powers under legislation (primarily the Corporations Act)  explaining how ASIC interprets the law  describing the principles underlying ASIC’s approach  giving practical guidance (e.g. describing the steps of a process such as applying for a licence or giving practical examples of how regulated entities may decide to meet their obligations). Information sheets: provide concise guidance on a specific process or compliance issue or an overview of detailed guidance. Reports: describe ASIC compliance or relief activity or the results of a research project. Document history This guide was issued in June 2026 and is based on legislation and regulations as at the date of issue. Previous versions:  Superseded Regulatory Guide 234 Advertising of financial products and advice services (including credit): Good practice guidance, issued November 2012, which updated the guidance to include new information on credit products and services.  Superseded Regulatory Guide 234 Advertising of financial products and advice services: Good practice guidance, issued February 2012. Disclaimer This guide does not constitute legal advice. We encourage you to seek your own professional advice to find out how the applicable laws apply to you, as it is your responsibility to determine your obligations. Examples in this guide are purely for illustration; they are not exhaustive and are not intended to impose or imply particular rules or requirements. Page 3 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 3 Contents A Overview ........................................................................................... 4 Purpose of this guide ......................................................................... 4 Overview of this guide ....................................................................... 5 Our regulatory powers ....................................................................... 6 B When advertising may be misleading ........................................... 7 Returns, features, benefits and risks ................................................. 7 Warnings, disclaimers, qualifications and fine print ......................... 14 Fees and costs ................................................................................ 18 Comparisons .................................................................................... 24 Past performance and forecasts ...................................................... 26 Use of certain terms and phrases .................................................... 33 Target audience ............................................................................... 37 Photographs, diagrams, images and examples .............................. 39 Nature and scope of financial advice and credit assistance............ 41 C Media-specific guidance ............................................................... 43 Mass media...................................................................................... 43 Audio advertisements ...................................................................... 44 Film and video advertisements ........................................................ 45 Internet advertising .......................................................................... 45 Outdoor advertising ......................................................................... 47 D Publishers and media outlets ....................................................... 49 Publisher responsibility .................................................................... 49 Sponsored content ........................................................................... 50 Comparison sites ............................................................................. 50 Appendix 1: Quick reference guide to advertising guidance for promoters ....................................................................................... 51 Complying with legal obligations ..................................................... 51 Assessing advertising ...................................................................... 51 Advertising guidance for promoters ................................................. 53 Appendix 2: Other relevant ASIC guidance ........................................ 57 Product specific guidance ................................................................ 57 Other guidance ................................................................................ 57 Key terms ............................................................................................... 59 Related information ............................................................................... 61 Page 4 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 4 A Overview Key points Consumers are heavily influenced by advertisements for products and services when making financial decisions and seeking financial advice. We have developed guidance to help promoters comply with their legal obligations to not make false or misleading statements or engage in misleading or deceptive conduct. Our guidance applies to any communication intended to advertise financial products, financial advice services, credit products or credit services. While the primary responsibility for advertising material rests with the organisation placing the advertisement, publishers and media outlets may also have some responsibility for content. ASIC has a range of regulatory powers that we can exercise for dealing with false or misleading statements or misleading or deceptive conduct. We may take a greater interest in advertisements that do not meet this guidance when considering whether to make further inquiries or to exercise our regulatory powers, among other things. Purpose of this guide RG 234.1 Consumers are heavily influenced by advertisements for products and services. Advertisements that do not fairly represent the product or its key features and risks, or the nature and scope of the service, can be misleading and create unrealistic expectations that may lead to poor financial decisions. RG 234.2 This regulatory guide sets out guidance to help promoters comply with their legal obligations to not make false or misleading statements or engage in misleading or deceptive conduct. Following our guidance will also help raise standards in advertising more generally. Who our guidance applies to RG 234.3 Our guidance is relevant to: (a) promoters of financial products, financial advice services, credit products, and credit services. The promoter will sometimes be the product issuer or credit provider, but can also be a third party, such as a financial adviser, credit service provider, distributor, intermediary (e.g. lead generators), or agent; and (b) publishers of promotions about these products and services, such as television networks, newspapers, radio stations, social media and digital platforms. Page 5 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 5 What our guidance applies to RG 234.4 Our guidance applies to any communication whose purpose is to inform consumers about or promote financial products, financial advice services, credit products or credit services. Note 1: References to ‘financial advice services’ in this guide mean the provision of financial product advice as defined in the Australian Securities and Investments Commission Act 2001 (ASIC Act): see s12BAB(5) of the ASIC Act. Note 2: This guide uses the term ‘credit products and credit services’ to refer broadly to both credit facilities under the ASIC Act and credit activities under the National Consumer Credit Protection Act 2009 (National Credit Act), which includes the National Credit Code as Schedule 1 to the Act (National Credit Code). References to ‘credit products’ include both credit contracts and leases. RG 234.5 It applies to advertising communicated through any medium in any form, including mass media, audio, film, video, internet (including internet-based applications), social media and outdoor advertising. It also applies regardless of any specific technologies that may be used, including artificial intelligence (AI). See Section C for more details. Note: While the laws relating to financial and credit products and services apply in the same way to AI-generated advertising content as human-generated content, the potential for hallucinated or biased content by AI tools may increase the risk of misleading or deceptive advertising. RG 234.6 Some financial products, due to their risk or nature, require further specific guidance. This guide should be read in conjunction with our other product- specific advertising guidance: see Appendix 2. RG 234.7 Advertising does not generally include statements in a regulated disclosure document, such as a prospectus, Product Disclosure Statement (PDS) or Financial Services Guide (FSG). This guide also does not cover the design of financial or credit products or their distribution. RG 234.8 Separate to the prohibitions on false or misleading statements and conduct, the Corporations Act 2001 (Corporations Act), National Credit Code and ASIC Act prohibit certain other types of conduct related to the promotion of financial products/services and credit. This includes unsolicited selling conduct, deferred sales of add-on insurance, and advertising about certain offers of securities and financial products. This guide does not cover these prohibitions: see Appendix 2 for other relevant ASIC guidance. Overview of this guide RG 234.9 Appendix 1 contains an overview of the advertising guidance for promoters in this guide: (a) Table 1 in Appendix 1 contains an overview of our guidance on when advertising might be misleading, which is applicable to all media, outlined in more detail in Section B; Page 6 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 6 (b) Table 2 in Appendix 1 contains an overview of some media-specific issues relevant to when advertising might be misleading, outlined in more detail in Section C; and (c) Table 3 in Appendix 1 contains a list of provisions relating to false or misleading representations and false or misleading deceptive conduct in the Corporations Act, National Credit Act and the ASIC Act. RG 234.10 Appendix 2 lists other ASIC regulatory guidance that may be relevant to advertising conduct. Industry guidance RG 234.11 Industry guidelines, standards and codes have a useful role to play in ensuring that advertisements are not misleading or deceptive. This is because consumers will generally expect promoters and publishers to comply with accepted industry guidelines. RG 234.12 We encourage industry bodies to develop and enforce guidelines, standards or codes that build on the principles of our guidance and respond to the specific needs of the sector. RG 234.13 Our guidance will also be relevant to sector-wide advertising undertaken by industry associations on behalf of members. Our regulatory powers RG 234.14 ASIC has a range of regulatory powers that we can exercise for dealing with false or misleading statements or misleading or deceptive conduct. Information Sheet 151 ASIC’s approach to enforcement (INFO 151) addresses these regulatory powers, and our general approach to enforcement. RG 234.15 We may take a greater interest in advertisements that do not meet our guidance when considering whether to make further inquiries or to exercise our regulatory powers, amongst other things. Page 7 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 7 B When advertising may be misleading Key points The guidance in this section covers: • returns, features, benefits and risks (see RG 234.17–RG 234.33); • warnings, disclaimers, qualifications and fine print (see RG 234.34– RG 234.41); • fees and costs (see RG 234.44–RG 234.62); • comparisons (see RG 234.63–RG 234.80); • past performance and forecasts (see RG 234.83–RG 234.110); • the use of certain terms and phrases (see RG 234.120–RG 234.132); • the advertisement’s target audience (see RG 234.133–RG 234.144); • photographs, diagrams, images and examples (see RG 234.145– RG 234.150); and • the nature and scope of financial advice and credit assistance (see RG 234.151–RG 234.155). RG 234.16 Advertisements should give balanced information so that consumers can understand the nature of the product or service being advertised. Balance is important for ensuring that the overall effect of an advertisement creates realistic expectations about a product. Returns, features, benefits and risks RG 234.17 Advertisements for financial products and credit products should give a balanced message about the returns, features, benefits and risks associated with the product. Advertisements for financial and credit services should also give balanced messages about features, benefits, risks and limitations of those services and any customer tools used as part of those services, including AI tools. Advertisements should not overstate the potential benefits (e.g. investment returns) or create unrealistic expectations by giving undue prominence to the benefits compared with the risks or limitations. Example 1: Lack of balance about high-risk strategy A credit provider promoted that consumers could pay off a 25-year mortgage in 10 years while maintaining their existing monthly repayment amount. Consumers could only potentially achieve this claim if they undertook a ‘strategy’ which included taking out a second loan to purchase a residential investment property. The ‘strategy’ relied on the value of the investment property appreciating at a high enough rate for consumers to sell their investment property and pay off both loans (i.e. the existing home loan and investment loan). Page 8 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 8 ASIC was concerned that the credit provider’s advertising may mislead consumers because the claim relied on the past performance of the property market continuing into the future and was based on a number of assumptions that were not disclosed in the promotional material. Returns, features and benefits RG 234.18 Where an advertisement states or implies that a particular benefit is likely, it should include a statement about the risks associated with obtaining that benefit, or about the product or service generally. Where appropriate, the advertisement should also include a clear explanation of the assumptions made in predicting the benefit. Example 2: Representations about high-risk investment management An Australian financial services (AFS) licensee promoted itself through its website, publications and seminars as a specialised derivatives dealer. It represented that investors could participate in the lucrative options trading marketplace with minimum effort in the knowledge that a professional options trader was assisting them to manage all aspects of their trading. The advertisement claimed that by using the licensee’s time-tested risk management method, consumers could earn superior returns in a high-risk market. ASIC raised concerns that these representations were misleading and deceptive as they overstated the ability of a consumer to obtain the results claimed. We obtained an injunction restraining the licensee from making further advertisements. Example 3: Benefits restricted to certain circumstances A mortgage broker promoted that a particular home loan could help consumers pay off their debt sooner, using an online calculator that demonstrated considerable savings over time. ASIC was concerned that the broker’s promotional material did not inform consumers that they would need to make considerable additional repayments above their monthly repayments to achieve the promoted claims. We obtained orders in the Federal Court against the mortgage broker, which included a declaration that the mortgage broker had contravened the ASIC Act, and orders restraining the broker from continuing to make these representations. Example 4: Lack of balance about benefits and risks ASIC identified several misleading advertisements that made claims suggesting that reverse mortgages did not need to be repaid. The statements in the advertisements included ‘There are no repayments’, ‘… no loan repayments ever’ and ‘No need to make repayments!!’. Although reverse mortgages do not usually require the borrower to make regular repayments during the course of the loan, they must eventually be repaid. We raised these concerns with the promoters of the advertisements. In each Page 9 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 9 case, the promoter took immediate steps to either withdraw or amend its advertising. Note: Use of the term ‘reverse mortgage’ is restricted under the National Credit Act: see RG 234.127. RG 234.19 Claims made about consumer outcomes of products and services must be able to be substantiated or otherwise have a reasonable or evidence-based justification for the claim. Promoters should keep records which can substantiate or justify any claims or representations made in its advertising material. Example 5: Substantiating significant debt management claims A provider of debt management services represented on its website that it had wiped $80 million in debt and saved consumers $30 million in interest. ASIC was concerned that the statements were false or misleading, as the provider was unable to substantiate these figures, nor was there a reasonable or evidence-based justification for these representations. The evidence produced by the provider indicated that the statements were false and misleading. ASIC issued infringement notices to the provider, and the provider also removed the representations from its website. RG 234.20 Claims about features of a product or service should only be made if a consumer can reasonably expect those features to be available to them. An advertisement should not present a one-sided view of a service or product’s key features to overstate the benefits associated with the service or product. Example 6: Overstating the benefits of a credit repair service ASIC took court action against a credit repair firm after it claimed to be able to ‘clean’ a consumer’s credit history by removing negative listings, without investigating whether consumers in fact had any negative listings or if any such listings could be removed. The court found that these were false or misleading representations and ordered the firm and its director to pay pecuniary penalties. ASIC also obtained an undertaking from the firm to refund some consumers. Example 7: No reasonable basis for asserting features claimed ASIC took court action against a company that offered and marketed a non-cash payment facility, which used a crypto-asset token, to a general audience. Among other breaches, the company was found to have made a public statement that acquirers of the product could confidently exchange tokens for other crypto-assets or currencies through independent exchanges. The court found that the only digital currency exchange that accepted the relevant token was an exchange which was not independent of the offeror and did not permit crypto-assets to be exchanged with each other. Page 10 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 10 Accordingly, at the time of the advertisement, such exchanges neither existed nor was there any reasonable basis for believing they would come into existence, and the offeror of the product had engaged in misleading or deceptive conduct. Example 8: Misrepresenting the nature of the product An advertisement suggesting that goods may be leased or rented before the consumer decides whether to purchase those goods would be misleading if the consumer does not have a right or option to purchase the goods. An advertisement would also be misleading if it implied that rental payments would be deducted from the purchase price, but the agreement merely gives the consumer the option to purchase equivalent goods, rather than the actual goods they had been leasing. RG 234.21 If a product or service offers certain benefits that are mutually exclusive (i.e. they cannot be taken up simultaneously), this should be made clear in the advertisement. RG 234.22 An advertisement should not contain an open-ended promise about a benefit if it is likely that circumstances will change so that the promise will become misleading. It is important to remember that an advertisement may create a lasting impression in consumers’ minds. If circumstances change, merely withdrawing the advertisement may not alter the fact that certain expectations have been created, and the advertisement may have an effect that is misleading. RG 234.23 Where an advertisement contains a promise about a benefit that is likely to change if circumstances change, the advertisement should be qualified by a prominent statement that alerts the consumer to the fact that circumstances may change. Example 9: Bait advertising A credit card was widely advertised as having a ‘low ongoing rate’ of 9.99% per year, while warning consumers about the short-term nature of offers made by some competitors. ASIC raised concerns with the company promoting the card when, two months later, they introduced a higher interest rate for cash advances, of 13.99% per year. We were concerned that consumers who responded to the earlier advertising may not have had the benefit of the credit card at the advertised price for a sufficient period of time. RG 234.24 If an advertisement offers certain discounts or pricing, the promoter should ensure that it delivers the discounts and/or pricing as advertised. Page 11 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 11 Example 10: Failing to deliver promised insurance discounts ASIC took court action against an insurer that had advertised certain loyalty and no-claim discounts to renewing customers because the insurer had used an algorithm to calculate insurance premiums, which did not pass on the promised discounts. The court found that by failing to deliver the advertised benefits, the insurer had made false or misleading representations and ordered the insurer to pay pecuniary penalties. Greenwashing RG 234.25 Promoters should take care to avoid misrepresenting the extent to which a financial product or investment strategy is environmentally friendly, sustainable or ethical (‘greenwashing’). Greenwashing distorts relevant information that a current or prospective investor might require to make informed investment decisions. Example 11: Conduct inconsistent with greenwashing representations ASIC took action against a trustee of a superannuation fund for (among other things) making misleading claims that investments in certain activities and industries, such as gambling, coal mining and oil tar sands, were fully excluded. Advertisements for the fund used terms such as ‘we do not invest’, ‘no way’ and ‘eliminate’, even though the fund held securities in these activities and industries. The court noted that the use of these terms unequivocally suggested that these investments would be fully excluded and that these statements had not been qualified. Accordingly, the court found these representations were misleading and ordered the trustee to pay a pecuniary penalty. Example 12: Greenwashing claims: misrepresenting the extent to which exclusionary screens apply to investments in an index fund ASIC took action against an investment management company for making misleading claims about the extent to which sustainability-related exclusionary screens were applied to investments in an index fund. The advertisements across multiple mediums claimed that investments in the index fund were ‘researched and screened against’ certain environmental criteria and ‘any investments that breached them were removed’. In practice, 74% of the securities of the index fund by market value had not been researched or screened against the applicable environmental criteria. In addition, only investments in companies (as distinct from other investment vehicles) were screened. For example, bond issuers with significant business activities in certain industries were not always excluded. RG 234.26 The Court found that the investment management company had benefited from this misleading conduct and ordered the company to pay a pecuniary penalty. For further information and examples of potentially misleading or Page 12 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 12 deceptive practices, see Information Sheet 271 How to avoid greenwashing when offering or promoting sustainability-related products (INFO 271). Consistency with disclosure documents RG 234.27 When an advertisement draws attention to specific features of a product, those statements should be consistent with the product’s features and the disclosures in any corresponding disclosure documents (e.g. a PDS, FSG or prospectus) or contracts. Example 13: Credit card contract terms When a credit card contract includes a standard clause allowing the provider to unilaterally raise the interest rate at any time, the promotional campaign for the card should not contain a ‘guarantee’ that the interest rate will stay low. Example 14: Insurance policy limitations An advertisement for insurance used phrases such as ‘guaranteed acceptance’ and ‘no exceptions’, although the policy had significant exceptions. ASIC took action on the basis that an advertisement should not imply that clients will definitely be paid in certain situations if the policy’s terms contain limits on when claims will be paid out. The insurer agreed to pay out all benefits where a claim had been rejected due to the exclusions not mentioned in the advertisement. Example 15: Advertised claims not reflected in PDS An issuer of capital-protected products and structured products produced marketing material claiming that the fund’s units provided investors with a tax deductible interest expense. However, this claim was not substantiated in the PDS, which encouraged potential investors to seek their own independent advice about the deductibility of interest and borrowing expenses. ASIC imposed licence conditions on the product issuer requiring, among other things, the appointment of a legal firm to monitor certain advertising and marketing material to ensure that it was not potentially deceptive or misleading. RG 234.28 To ensure consistency with a disclosure document, promoters should be aware that a statement in the disclosure document may become misleading when it is taken out of context in an advertisement. An advertisement should not include or rely on context or additional material that is not included in the disclosure document. Page 13 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 13 Risks RG 234.29 Information about the risks of a product or service should be clear, and not hidden or difficult to understand, and should be given sufficient prominence to information about returns and benefits. The tone of the advertisement should not undermine the importance of the risks. Example 16: Misleading investors on risk characteristics ASIC took court action against a group of entities who advertised several classes of promissory notes. ASIC was concerned that the advertisements failed to accurately advertise the risk profile of the notes. The advertisements represented that the notes were comparable to bank term deposits, when they were of significantly higher risk, that the notes carried no risk of default, when there was a risk that the principal investment could be lost, and that the principal investment would be repaid in full on maturity, when the entity could extend the time for repayment for an indefinite period. Representations were also made that some of the notes were fully secured when they were not. The court found that the entities had engaged in misleading or deceptive conduct and making false and misleading statements in relation to these representations and ordered the entities to pay penalties. Example 17: Understating potential risks relative to benefits ASIC became aware of an options trader who marketed and sold options- trading software. Marketing material included statements such as ‘Options trading is easy’ and ‘Returns of 5–10% per month and 60–120% per year can consistently be achieved’. We accepted an enforceable undertaking under which the company agreed to permanently refrain from using these phrases in connection with options trading. The company also agreed to provide a refund to people who had bought the product after one or more of the statements were made to them. Example 18: Advertising high-risk contracts for difference Contracts for difference (CFDs) are high-risk financial products with the potential to expose investors to large losses. An advertisement for CFDs should not include prominent headline claims such as ‘Build personal wealth with low-risk trading strategies’ and ‘Safely harness the leverage power of CFDs’ because this does not accurately reflect the risks of trading in CFDs. RG 234.30 The safety or security of a product should not be overstated. There are very few products that can claim that they are fully insured or guaranteed. Note: The Australian Government’s Financial Claims Scheme (FCS) protects deposits in authorised deposit-taking institutions (ADIs) such as banks, building societies and credit unions up to a specified limit. It does not apply to investment products offered by an ADI. Page 14 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 14 Example 19: Overstating product safety ASIC was concerned that credit products, including margin loans, were being marketed in print media, online and within a brochure using the line ‘Stress-free strategies to accelerate your wealth—A guide to borrowing to invest in shares’. There are risks involved in gearing to invest in shares that would make it unlikely that any such strategy would be ‘stress-free’. We raised these concerns with the company, which agreed to cease using the term ‘stress-free’. RG 234.31 When a product or service has a high level of risk or special risk factors that would not be apparent to the target audience, an advertisement for that product or service should clearly disclose the nature of these risks. See RG 234.121 for more detailed guidance on similar terms and phrases. RG 234.32 When a product or service poses significant risks that would not ordinarily be expected by a consumer, an advertisement should include a prominent warning about these risks. Example 20: Prominent warning of unexpected risks Trading in CFDs involves the risk of losing substantially more than the initial investment, and CFD investors do not own or have any rights to underlying assets. These are risks that might not be expected by consumers used to trading in securities. Their advertisements should therefore include a sufficiently prominent warning outlining these risks. RG 234.33 When a product, or a feature of a product, is introduced that makes the product significantly different from other similar products, the advertisement should give prominence to the different or innovative features if they would not ordinarily be expected by a consumer. This is particularly important if the product exposes a consumer to unusual risks. Warnings, disclaimers, qualifications and fine print RG 234.34 We recognise that an advertisement will not always include in its headline claim all information about the product that is relevant to the consumer’s decision. However, the more that a qualification is required to balance the information contained in the headline claim, the more prominently placed the qualification should be. The headline claim must not itself be misleading. Page 15 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 15 Example 21: Failure to state the exclusions applicable to advertised insurance benefits ASIC pursued criminal action against an insurer and its marketing/selling agent in relation to advertisements published online by both entities about travel insurance available to consumers. The insurer’s website advertised the maximum benefits payable to consumers but did not always state that sub-limits, terms, conditions or exclusions applied. The court found that the information published online misrepresented the characteristics or level of coverage of its travel insurance and convicted and fined the entities for making false or misleading statements. Example 22: Loan interest rate benefits not available to all When a home loan provider promotes an attractive interest rate discount that is only available to large loans, any interest rate discount restrictions should be prominently displayed. Sometimes interest rate discounts are tiered between amounts borrowed, increasing for larger loans. Home loan providers generally promote the most attractive discount. In such cases, ASIC does not consider the home loan provider can rely on a statement such as ‘up to X%’, to describe the discount if it is only available in limited circumstances, and this is not prominently disclosed. The use of qualifying phrases such as ‘up to’ or ‘from’ should generally be approached with caution, because the overall impression created by an advertisement may still be that the maximum benefit is more widely or readily available than is the case. RG 234.35 If warnings, disclaimers and qualifications are required, they should not be inconsistent with other content in the advertisement, including any headline claims. They should also have sufficient prominence to effectively convey key information to a reasonable member of the audience on first viewing of the advertisement. Information is less likely to be noticed and understood if it is in fine print, contained within a dense block of text, only shown on television or a computer screen for a brief period, or placed where there is distracting content shown simultaneously. RG 234.36 Statements referring the consumer to another website or webpage through a link or QR code, or a document such as a PDS, prospectus or contract, will not be sufficient to correct a misleading or deceptive headline claim: see Australian Competition and Consumer Commission v TPG Internet Pty Ltd [2011] FCA 1254. Note: See RG 234.170–RG 234.179 for further guidance on internet advertising. Page 16 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 16 Example 23: Benefits only available to new customers A bank advertised an account as being free of monthly account-keeping fees for customers depositing at least $2,000 per month. ASIC was concerned that the advertisements created the impression that the initiative to remove monthly service fees applied automatically to existing account holders when this was not the case. We accept that financial services providers do, from time to time, offer special promotions that only apply to new customers. However, it is important that advertising clearly states whether an offer is available to existing customers (and, if so, how to access it). The bank agreed to take a number of steps to ensure that its existing customers had not been misled, including writing to all of them. Example 24: Qualifications and warnings to be included in an advertisement If the headline claim for a superannuation fund that members ‘pay a low administration fee of $104 per annum’ is prominently qualified by a statement that ‘other fees and charges apply—refer to our PDS’, consumers will immediately be aware that the administration fee does not represent the only cost. On the other hand, if the headline claim is qualified only by a statement suggesting that consumers ‘refer to our PDS’, consumers will have no reason to suspect that other costs will be incurred. Example 25: Qualification on a different webpage to the advertisement In a review of advertising for general insurance products, ASIC identified some online advertisements for offers and discounts that appeared unqualified but were in fact subject to conditions, such as age restrictions and absence of at-fault claims. These banner advertisements did not include reference to restrictions on the offers and discounts, which were outlined elsewhere on the insurers’ websites as part of the product information. To prevent misleading consumers, internet banner advertising itself should mention the restrictions for an offer. Including a link or reference to a webpage where restrictions can be found is unlikely to correct a misleading impression. We wrote to the insurance industry to outline our concerns. RG 234.37 If warnings, disclaimers or qualifications are included in an advertisement, they should be in a form similar to the main body of the advertisement so that the consumer can understand the warning, disclaimer or qualification. RG 234.38 If the main body of an advertisement for a financial product is in a language other than English, any warnings, disclaimers or qualifications should be in the same language. Page 17 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 17 Example 26: Disclaimers in a different language to the main advertisement A mortgage broker published advertisements aimed at Chinese-speaking home buyers. The benefits of the mortgage product, including its low interest rate, were presented in Chinese but the disclaimers and qualifications were in English. In response to concerns raised by ASIC, the mortgage broker agreed to amend its advertising. RG 234.39 If a qualification is required, it must be published at the same time as the original message. Subsequent qualifying disclosures will not be effective as the misleading impression will already have been created. RG 234.40 Qualifications should not be used to change the meaning of a headline statement. Some headline claims are so strong that any separate qualification will not correct any misleading impression. Example 27: Claims too strong to be adequately qualified An insurer advertised the option to pay an insurance premium on a monthly basis using terminology such as ‘Cut your car insurance into 12 easy monthly payments’. ASIC raised concerns that this could give the impression that the annual premium is simply split into 12 payments, whereas the total of the 12 monthly payments was in fact more than the price the consumer would pay if they opted to pay annually. Even if the advertisement included fine print stating that the sum of 12 monthly premiums is more than the option to pay an annual premium, the strength of the headline claim would be significantly greater than that of the fine print and would convey a dominant message to consumers. We wrote to the insurance industry to outline our concerns about this type of advertising. RG 234.41 Some warnings or notices are required to be included in an advertisement under various provisions of the Corporations Act or other laws rather than because they qualify a headline claim. In these cases, the warning does not necessarily need to be as prominent as the headline claim. Warnings or notices required under legislation may be different to disclaimers that qualify a headline claim. Note 1: The particular provision requiring the warning may set out specific content or format requirements for the warning. See RG 234.61 for guidance on the comparison rate warning required by the National Credit Act. Note 2: A credit licensee must include its credit licence number in any printed advertisement: s52 of the National Credit Act and reg 13 of the National Credit Regulations. RG 234.42 Where an intermediary (e.g. a mortgage broker or financial adviser), promotes products and services issued or provided by a third party, the intermediary should: (a) ensure the product features described match the current product information; Page 18 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 18 (b) ensure advertised fees and costs are accurately reflected in the relevant materials; and (c) identify where certain features are not available to all consumers. RG 234.43 Promoters should not rely on a third party, such as an adviser or broker, to correct a misleading impression created in the advertisement itself. Fees and costs RG 234.44 Where a fee or cost is referred to in an advertisement, it should give a realistic impression of the overall level of fees and costs a consumer is likely to pay— for example, investment, administrative and transaction fees. When a headline claim about a fee or cost is used in an advertisement, any exclusions or qualifications should be contained within the headline claim or be clearly and prominently noted within the advertisement. Example 28: No fees (but only in certain cases) Unless there is clear and adequate qualification, an advertisement should not promote an online savings account as earning high interest ‘with no fees’ when, in practice, the account with no fees is not a stand-alone product but must be linked to another account that does attract fees. Example 29: Omission of important fee information Promoting a savings account as having ‘no annual fee’ when the same account has a monthly fee that is not mentioned in the advertisement that cumulatively amounts to a yearly cost, may mislead consumers about the cost of having that account. Example 30: Exclusions and qualifications Some basic deposit products may allow consumers a certain number of free transactions per month, after which an ‘excess transaction’ fee applies. An advertisement for such a product should not claim that it is ‘fee free’ without qualifying that headline claim with necessary information about the way fees are applied. Example 31: Omission of details about a product’s novel feature ASIC took action against entities that advertised ‘no deposit’ and ‘interest- free’ terms for a 60-month period for purchases of goods from a franchised store. Some of the advertisements merely stated that ‘fees and charges apply’. However, the terms required customers to take out a particular credit card to purchase the goods, which had establishment and monthly service fees attached. Page 19 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 19 The court found that the entities had engaged in misleading conduct and made false or misleading representations. This was because consumers who wished to make a purchase under the advertised terms had to enter into a fundamentally different arrangement than the one promoted, namely a credit contract linked to a credit card, which required them to pay establishment and monthly service fees. RG 234.45 An advertisement should not state that there is only one fee if there are other costs associated with the product that consumers will incur. Promoters should not assume that clients will understand the distinction between ‘fees’ and ‘costs’. If an advertisement refers to the fees that apply, it will generally need to positively state whether or not other costs apply. Example 32: ‘Free’ claims where fees or costs are payable Some promotions state that transactions are ‘free’ on an account when the account is in fact subject to account-keeping or monthly fees. While it is true that there is no additional charge for a particular transaction, there is nevertheless a cost to use the account. The word ‘free’ conveys a strong impression and should not be used where there is any charge to use the product. Example 33: Distinction between superannuation fees and costs A superannuation fund advertised that its members would pay ‘one low fee’, but did not mention that other items, called ‘costs’ or ‘charges’, would also apply. ASIC raised concerns that these representations may mislead consumers. In response, the superannuation fund made appropriate changes to its promotional material. RG 234.46 Where an advertisement promotes attractive features of a product, the advertisement should also disclose any fees that are payable to receive those features. Example 34: Fees payable to receive benefits Home loan packages may offer consumers savings on fees and other discounts, in some cases across a range of products. A consumer usually has to pay an annual fee to access the benefits of a home loan package. Advertisements for these packages or offers, including the discounted prices that are part of a package, should not promote ‘no’ or ‘low’ fees without adequate disclosure of the annual package fee. Impact of fees and costs on advertised returns RG 234.47 The effect that the fees and costs may have on returns for a financial product should be clearly stated in an advertisement. For example: (a) returns should be net of fees and costs to the greatest extent practicable; Page 20 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 20 (b) where the fee level is variable, the maximum fee should be deducted from the possible returns advertised; (c) where it would be impractical to deduct some fees or costs, the existence of undeducted fees and costs should be prominently disclosed; (d) where practicable, the size of undeducted fees and costs should be disclosed; (e) where a product is offered with multiple fee options, any advertised returns should make clear which fee option they relate to and not only show the option that shows the highest net returns; and (f) where a scenario is given for a specific investment period, entry and exit fees should be deducted. Note: See also Examples 5, 6 and 42 for further examples relating to fees and costs. Example 35: Quoting net returns on fund product A fund’s five-year net returns may be 10% per annum for the entry fee option and 9.6% per annum for the nil-entry fee option. Acceptable alternatives for quoting net returns are: • give returns for both options; • only give returns for the option with the lower net return; or • give returns for the option with the lower net returns and disclose the returns for the other option in a footnote. RG 234.48 Where an advertisement promotes a scenario for a specific investment period, it may be misleading to not deduct entry and exit fees. Example 36: Including entry, exit and other fees in return advertised A fund advertises that if an investor had ‘placed $10,000 in the fund in 2015, it would be worth $740,000 today’. The present-day value advertised should be calculated on the basis that the hypothetical investor had bought the investment at the start date and sold it at the end date. The appropriate methodology would include: • deducting all relevant fees, including entry, annual, exit and performance fees; • calculating returns on an ‘offer to bid’ or ‘entry price to exit price’ basis; and • applying current fees, even if different fees existed over the relevant period. Fees for financial advice services RG 234.49 Where an advertisement makes a claim about the fees or costs associated with a financial advice service, this should be easily understood, and any qualification clearly and prominently noted in the advertisement. An advertisement should not suggest that an advice service is ‘free’ or ‘low cost’ if, in fact, the consumer would Page 21 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 21 pay for the service indirectly through the fees and costs of any financial products they are placed in or through an administration fee incorporating fees or costs associated with a financial advice service. Note: Divisions 4 and 5 of Pt 7.7A of the Corporations Act contain a ban on conflicted remuneration structures, such as commissions and volume-based payments: see Regulatory Guide 246 Conflicted and other banned remuneration (RG 246). Interest rates RG 234.50 Under the National Credit Code, an advertisement for a credit product does not need to include an annual percentage rate but must do so if the advertisement states the amount of any repayment. The advertisement must also include references to any fees and charges: s150 of the National Credit Code. Note: Section 27 of the National Credit Code defines ‘annual percentage rate’ under a credit contract to mean a rate specified in the contract as an annual percentage rate. An annual percentage rate is the interest rate charged to the borrower, excluding expenses such as account opening and account keeping fees. It is the basic cost of credit as a percentage of the total loan amount. RG 234.51 Depending on the nature of a credit product, the cost to a consumer may involve a combination of interest charges and other fees and costs. RG 234.52 Where an advertisement refers to interest rates and/or fees and charges, it is important that the advertisement gives consumers a realistic impression of the overall costs. Example 37: Significant fees in addition to interest charges A provider of a short-term or small amount credit contract should not promote a loan with a low or 0% interest rate in a manner that suggests a low overall cost if a consumer will incur fees or other charges. Example 38: Comparison involving discounted interest rates An industry association promoted the average savings consumers could achieve if they obtained a home loan from one of its members instead of from its competitors. The calculated savings were based on a sample of members and included some lower-rate, non-standard home loan products. Further, the industry association calculated the savings based on a cost comparison made shortly after an official increase in the cash rate, at a time when competitors’ rates had increased in line with the cash rate but shortly before the members used in the sample followed suit. ASIC was concerned that consumers were at risk of being misled about the nature of the savings in the advertisement as the industry association had not clearly and prominently disclosed the types of interest rates used in the comparison, or that it was based on only a sample of members. Further, we considered that the industry association may not have used an appropriate point-in-time selection to calculate savings. We contacted the association, Page 22 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 22 which agreed that future advertisements would clearly disclose the types of rates used and the selective nature of any comparison. RG 234.53 In many cases, credit contracts are structured with an initial promotional period, where a discount interest rate applies and/or other fees are waived, before the interest rate and fees revert to a higher level on an ongoing basis. If an advertisement includes details of this interest rate or fees, it should state, with equal prominence, the period for which the discount applies. RG 234.54 The advertisement should also describe what the interest rate or fees revert to (e.g. identifying ‘the standard variable rate’ by name as the rate that applies after the promotion period ends), but this need not be stated with equal prominence to the discount rate or fees. The degree of prominence required depends on any unusual features of the discount rate or period. For example, we would expect the following reversion rates to be stated more prominently: (a) if the advertisement is for a honeymoon interest rate on a home loan and the reversion rate is something other than the lender’s standard variable rate; or (b) if the advertisement is for a discount interest rate for a balance transfer on a credit card and the reversion rate is the higher cash advance interest rate rather than the standard purchase interest rate. RG 234.55 The advertisement also need not state the current amount of the discount rate or fees, unless the advertisement puts emphasis on savings that would be obtained during the discount period only, but without clarifying that these savings would not continue during the entire period of the loan. Comparison rates RG 234.56 A comparison rate is a tool to help consumers identify the true cost of a loan. It is a rate that includes both the interest rate and fees and charges relating to a loan, reduced to a single percentage figure. An advertisement must contain a comparison rate if it contains an interest rate: s160 of the National Credit Code. Note: An advertisement is not required to include an annual percentage rate but must do so if it states the amount of any repayment: s150 of the National Credit Code. RG 234.57 Part 10 of the National Credit Code establishes the methodology for calculating the comparison rate for a loan. Advertising an incorrectly calculated comparison rate is likely to mislead consumers about the true cost of a loan. Example 39: Incorrect bank calculation of comparison rate A bank advertised a discounted interest rate for a home loan that consumers could only access as part of a home loan package that has an annual fee. The bank failed to include this fee when calculating the advertised comparison rate. Page 23 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 23 ASIC was concerned that the comparison rate understated the true cost of the loan. We took action and the bank agreed to use a correctly calculated comparison rate in its advertising. RG 234.58 An advertised comparison rate must be identified as a comparison rate and the comparison rate must not be less prominent in an advertisement than any interest rate or the amount of any repayment stated in the advertisement: s164 of the National Credit Code. We consider that the following examples would result in the comparison rate being less prominent than the advertised interest rate: (a) a comparison rate is smaller in size or faded in colour when compared with the interest rate; (b) an interest rate is published online, and a consumer is required to click through or additionally do something (such as move their cursor over the interest rate) to view the comparison rate; or (c) the location of the displayed comparison rate in the advertisement is such that it is easy for a consumer to overlook it, or it is not in close proximity to the displayed interest rate (e.g. if a multi-page advertisement displays the comparison rate on one section of the promotional material and omits it from another section where an interest rate is displayed). RG 234.59 Ensuring that the comparison rate is no less prominent than the interest rate does not necessarily mean that they must be presented identically (e.g. both in the same colour and against an identical background). However, if the interest rate is bright and the comparison rate substantially less vivid by comparison or blended into the background because of a lack of colour differentiation, then even if they are shown in the same font size, it is likely that the comparison rate would be considered less prominent. RG 234.60 A comparison rate in an advertisement must be accompanied by a warning about the accuracy of the comparison rate and that the comparison rate is accurate only for the example given in the advertisement: s163 of the National Credit Code and reg 99 of the National Credit Regulations. The warning is intended to make consumers aware that, while a comparison rate can be a useful tool for comparing the cost of different loans, it is important to consider all of a loan’s features and not just focus on the comparison rate. RG 234.61 While the comparison rate warning reminds consumers to look at both the cost and features of a loan, we acknowledge that the rate itself will be of primary interest. Accordingly, the comparison rate warning need not be as prominent as the headline figure in the advertisement. However, the warning must be given in the same form as the comparison rate is given (i.e. in spoken or written form) unless the credit advertisement is on television, the internet or other electronic display medium: reg 99 of the National Credit Regulations. RG 234.62 Where the advertisement is in the form of an online banner advertisement, it may not always be possible to include the warning on the same page as the comparison rate. It will be sufficient that, at a minimum, the advertisement Page 24 REGULATORY GUIDE 234: Advertising financial products and services (including credit) © Australian Securities and Investments Commission June 2026 Page 24 contains a clear link or reference to the warning, and the reference should be as near to the comparison rate as possible. The reference should use clear language to help make the consumer aware that this is important information that they should consider before making a decision about the product (e.g. ‘comparison rate warning’ or ‘important information about the comparison rate’). Note: See RG 234.41 for our guidance on warnings or notices required under the Corporations Act. Comparisons Comparisons between products RG 234.63 When comparing products in an advertisement, the products should have sufficiently similar features to make the comparison relevant and not misleading. Example 40: Comparison of dissimilar products Debentures involve significantly higher risk than bank term deposits. An advertisement for a debenture should not make a statement such as ‘Is your money earning 6.3% per annum in a bank term deposit?’, or to encourage the consumer to ‘Invest with us and receive 9.75% per annum instead’, as this would not be an appropriate comparison. These two products have