What Cash Flow Advice Can You Legally Offer?

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1. Where are you based? (select 1)

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2. What type of advice are you wanting to give? (select 1)

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Country requirements

Pick a country above to see the usual licence, authorisation, and competence path for that market.

NZ · Financial Advice Provider (FAP) licence

New Zealand

For forecasting and operational cash advice, usually no special financial-advice licence. If you move into regulated advice, the usual path is a Financial Advice Provider (FAP) licence or operating under one.

What you need if you want to advise on loans, insurance, or investments in New Zealand

For pure cash flow forecasting, scenario modelling, and operational cash advice, a Financial Advice Provider (FAP) licence is usually not the issue.
If you want to give regulated financial advice to retail clients on your own account, the business usually needs a Financial Advice Provider (FAP) licence.
If you are an individual adviser, the usual route is to give that advice under a licensed FAP. If a business operates under another FAP, that may be through an authorised body structure.
If you want to use the title “Financial Adviser”, you must be registered on the Financial Service Providers Register (FSPR) and engaged by a licensed FAP, including through an authorised body structure where relevant.
The Code competence standards do not force one certificate in every case, but a common way to evidence them is the New Zealand Certificate in Financial Services (Level 5) or an objectively verifiable equivalent.

There is not a separate New Zealand certificate just to build cash flow forecasts or explain working-capital pressure.

In New Zealand, regulated financial advice to retail clients sits inside the Financial Advice Provider (FAP) regime. The Financial Markets Authority (FMA) says anyone giving regulated financial advice to retail clients on their own account must hold, or operate under, a Financial Advice Provider licence. The Financial Markets Authority (FMA) also says you must be registered and engaged by a licensed FAP to use the term “Financial Adviser”.

That does not make every cash flow conversation regulated. Cash flow forecasting, reporting, scenario modelling, and operational cash insight are not the same thing as recommending a loan, insurance policy, mortgage, investment, or KiwiSaver-style product.

That means a firm can usually explain a shortfall, model late debtor receipts, discuss creditor timing, stock pressure, tax timing, or payroll pressure, and suggest practical next steps such as collections focus, payment timing, cost control, or a need to get specialist help.

The risk starts when the discussion becomes lender-specific, insurer-specific, or investment-specific. “You may need funding if debtor timing does not improve” is different from “you should take an overdraft with Bank X”.

Scope wording matters. Use an engagement letter, meaning the written scope document between you and the client, that states what the service is and is not. Keep forecasting and scenario support separate from advice on loans, insurance, mortgages, and investments. If a client needs lending, insurance, investment, legal, or tax advice, refer that part out.

Professional indemnity insurance matters as well. Cash flow advisory may be treated by insurers as higher-risk advisory work, so firms should tell their broker what they plan to offer and confirm whether cover wording, excesses, or premiums need to change.

Other considerations in New Zealand

Professional indemnity insurance is not a standard FAP licence condition, but the Financial Markets Authority (FMA) says it is still an important decision. Tell your broker exactly what advisory work you plan to do and check whether cover terms, exclusions, excesses, or premium change.
If you move into licensed advice, Financial Markets Authority (FMA) standard licence conditions bring operational requirements such as record keeping, internal complaints process, regulatory returns, outsourcing controls, business continuity / technology systems, and notification of material changes.
If you provide advice only to wholesale clients, the licensing position can change, but duties such as managing conflicts and exercising care, diligence, and skill still apply.
If you operate as an authorised body under another FAP’s licence, that licensed FAP is responsible and accountable for your conduct, so scope, oversight, and referral rules need to be agreed clearly.

Official references for New Zealand

AU · Australian Financial Services Licence (AFSL)

Australia

For forecasting, usually no Australian Financial Services Licence (AFSL) issue. If you move into product advice, the usual path is an AFSL or authorisation under one, and some retail personal advice roles trigger extra individual standards.

What you need if you want to advise on loans, insurance, or investments in Australia

For pure cash flow forecasting, scenario modelling, and operational cash advice, an Australian Financial Services Licence (AFSL) is usually not the issue.
If you want to give financial product advice, the firm usually needs an Australian Financial Services Licence (AFSL) or you need to act under one.
There is not one universal Australian certificate. The exact path depends on the product and whether you are giving general advice or personal advice.
If you personally give personal advice to retail clients on relevant financial products, you usually need to be a relevant provider: authorised by an AFSL holder, registered with the Australian Securities and Investments Commission (ASIC), and subject to the education, exam, and professional-year standards.
General advice can still be regulated, so AFSL authorisation can matter even when the relevant-provider rules do not.

There is no single Australian certificate just for cash flow forecasting. The key question is whether your service becomes financial product advice.

The Australian Securities and Investments Commission (ASIC) says financial product advice includes a recommendation or statement of opinion that is intended to influence, or could reasonably be regarded as intended to influence, a decision about a financial product.

That is why wording matters so much. A statement can move from factual analysis to regulated advice faster than many firms expect.

Identifying a likely funding gap is different from recommending a specific lending facility. Showing a forecast that suggests a cash hole in May is different from telling the client which facility to take.

Australia is also less forgiving of loose language around “general advice”. General advice can still be regulated advice about a loan, insurance policy, or investment. A warning label does not fix bad wording on its own.

The safer lane is to identify the likely issue, model the cash impact, explain the trade-offs, and, if you are not authorised for product advice, refer that part out.

Other considerations in Australia

If you provide financial services to retail clients, compensation arrangements usually mean adequate professional indemnity insurance. ASIC expects that cover to be maintained on an ongoing basis.
Check that the professional indemnity insurance policy actually covers every service you plan to offer. If the scope of your work changes, the insurance position needs to be checked again.
Retail-client advice also brings dispute-resolution obligations: internal dispute resolution plus membership of the Australian Financial Complaints Authority (AFCA).
Licensed advice is not just a licence number. ASIC expects responsible managers, adviser training and competence, compliance and risk management, and adequate financial, technological, and human resources.

Official references for Australia

UK · Financial Conduct Authority (FCA) authorisation

United Kingdom

For forecasting, usually no Financial Conduct Authority (FCA) permission issue. If you move into product advice, the usual route is direct FCA authorisation or becoming an Appointed Representative.

What you need if you want to advise on loans, insurance, or investments in United Kingdom

For pure cash flow forecasting, scenario modelling, and operational cash advice, Financial Conduct Authority (FCA) authorisation is usually not the issue.
If you want to give regulated advice, the usual routes are direct Financial Conduct Authority (FCA) authorisation for the firm or becoming an Appointed Representative of an authorised principal.
There is not one universal UK certificate for all product advice. The permissions depend on what you advise on.
For retail investment advice, advisers must hold an appropriate qualification and an annual Statement of Professional Standing (SPS).
If you only want to make introductions, an Introducer Appointed Representative route is much narrower and does not let you give full product advice.

There is no single UK certificate just to explain cash flow. The key question is whether you stay in business cash guidance or move into a regulated activity.

In the UK, the Financial Conduct Authority (FCA) perimeter covers regulated advice on investments. The perimeter guidance focuses on advice about the merits of buying, selling, holding, or otherwise dealing with a particular investment. Separate FCA guidance also covers insurance and other regulated products.

The same broad pattern still applies. Discussing business cash, debtor timing, payroll load, stock pressure, supplier timing, or whether drawings should pause is different from recommending a loan, insurance policy, mortgage, or investment product.

Recommendations about lenders, insurance cover, and investments are where authorisation issues become more relevant. Saying that a business may need specialist funding advice is not the same as recommending a particular lender or facility.

This page is a practical high-level guide, not a substitute for UK legal advice.

Other considerations in United Kingdom

Where FCA rules require professional indemnity insurance, the FCA says it is your responsibility to take out adequate cover and think about the effect of the policy terms on your business.
FCA guidance says insurers often price professional indemnity insurance cover based on total income, limit and excess, risk profile, and the nature of the business. Expanding into regulated advice can affect premium, exclusions, and capital planning.
If you use an Appointed Representative model instead of direct authorisation, the principal must have a written agreement, assess the Appointed Representative before appointment, notify the FCA at least 30 days before the appointment takes effect, and keep reviewing those activities.
If you only want to make introductions, an introducer appointed representative can only undertake introductions and distribute financial promotions. That scope is much narrower than full advice.

Official references for United Kingdom

Select your country above to bring the relevant requirements into the tool.

Article

A helpful summary

The tool above gives you the quick answer; this section walks through the same boundary step by step.

Start

What are you advising on?

Are you explaining:

cash flow forecasts
payment timing
shortfalls or surpluses
working-capital pressure
scenarios such as late payers, hiring, tax timing, payroll pressure

✅

Usually safe

Cash flow insight / operational advice

Are you saying something like:

“you may need funding”
“you should talk to a lender”
“you should get specialist insurance advice”
“you may need investment advice”

⚠️

Depends on wording

Often safer if you identify the issue and make a neutral introduction, rather than steering the client to a loan, insurer, or investment product

Are you recommending a regulated financial product such as:

a specific loan
a specific lender
a mortgage or overdraft
an insurance policy or insurer
an investment product
a KiwiSaver / super / pension style product where applicable

❌

Likely regulated

Advice on lending, insurance, investments, or pension-style products will likely require extra licensing or authorisation

The short version

Across New Zealand, Australia, and the UK, the same practical rule shows up again and again.

Talking about cash flow, timing, shortfalls, collections, supplier pressure, and scenarios is usually one thing.

Recommending a loan, insurance policy, mortgage, investment, or pension product is another.

That distinction matters because advice on those products is regulated.

What is usually fine

Firms can usually:

prepare and explain cash flow forecasts
model scenarios such as late payments, hiring, tax timing, payroll pressure, and cost changes
identify likely shortfalls or surplus cash
discuss debtor pressure, creditor timing, stock pressure, and working-capital actions
suggest practical operational next steps such as improving collections, delaying spend, reviewing drawings, or getting specialist help

This is also the line shown in the uploaded NZ one-pager: cash flow forecasting, reporting, scenario modelling, shortfall analysis, working-capital discussion, and practical next steps usually sit in the safer lane.

The common thread is that you are analysing the business cash position and helping the client decide what operational actions to take.

You are not telling the client which lender, insurance policy, investment, mortgage, or KiwiSaver-style product to choose.

What starts to get risky

Risk increases when someone:

recommends a specific lender, loan, insurance policy, insurer, broker, mortgage, or investment product
frames operational insight as if it were licensed financial advice
uses wording that implies a recommendation rather than analysis
markets the service in a way that sounds like certainty or guaranteed outcomes

The more your language sounds like “take this loan” or “switch to this insurer”, the closer you move to regulated advice.

The safer pattern is to identify the problem, explain the cash impact, and, if you are not licensed or authorised for that advice, say specialist advice is needed. A neutral introduction is different from telling the client which lender, insurer, or product they should choose.

Real examples

Usually fine

“You will likely run short in 3 weeks if the March debtor book lands late.”

Likely regulated

“You should take a business loan from [specific bank].”

Usually safer

“You may need funding if debtor timing does not improve. Talk to a qualified lending specialist.”

Likely regulated

“You should switch insurers.”

Usually fine

“Your wages, tax, and creditor timing suggest pressure in late April. You may need to delay drawings.”

Best practice if you want to offer cash flow advisory

Define the service clearly in the engagement letter, and update it if the scope changes.
Describe it as forecasting, scenario support, and operational cash insight.
Avoid wording that sounds like advice on a loan, insurance policy, mortgage, or investment product.
Document assumptions.
Check professional indemnity insurance cover with your broker before launch or expansion.
When a client needs lending, insurance, investment, legal, or tax advice, stop at the diagnosis. You can say specialist advice is needed and make a neutral introduction, but do not steer the client to a specific provider or product unless that sits inside your licence or authorisation scope.

What “refer out” means here

Referring a client to a specialist is not the same as recommending a loan, insurer, mortgage, or investment product. The safer pattern is to explain the issue, say the client may need specialist advice, and, if helpful, offer a neutral introduction.

Safer: “You may need lending advice. We can introduce you to a lending specialist.”
Riskier: “Use this lender and take this facility.”
Use extra care if you are paid for referrals, only use one provider, help choose the final product, or package the referral as part of the advice service. That is where introductions can start to look like regulated advice or create conflict issues.

Engagement Letter

What this means in practice

An engagement letter is the written scope document between you and the client. There is not one universal public template that fits NZ, Australia, and the UK, but the best-practice approach is simple: say clearly what you will do, what you will not do, and when the client needs someone else.

Include

the service: cash flow forecasting, scenario modelling, and operational cash insight
the outputs: forecast updates, scenarios, meeting notes, and action points
the exclusions: no recommendation on specific loans, lenders, insurance policies, insurers, mortgages, investments, or pension-style products unless separately agreed and appropriately licensed or authorised
the client responsibilities: timely data, assumptions, and decisions provided by the client
the limits of the work: forecasts depend on assumptions and actual outcomes will differ
what happens when the client needs specialist advice: referral or introduction only, unless separately authorised
fees, billing, review points, complaints process, and what happens if the scope changes

Example scope line

“We provide cash flow forecasting, scenario modelling, and operational cash insights. This engagement does not include advice on specific loans, lenders, insurance policies, insurers, mortgages, investment products, KiwiSaver, super, or pension products unless separately agreed in writing and provided by a person appropriately licensed or authorised.”

Useful references

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Disclaimer

This page is general information only. It is not legal, licensing, or insurance advice. Firms should confirm their position with their lawyer, regulator guidance, and insurance broker before launching or expanding a cash flow advisory service.