RG 234 is ASIC's guide to advertising financial products and services, including credit. The current version, issued in June 2026, replaced the one ASIC published in 2012 and covers brokers and lead generators as well as lenders. Below are the rules that catch broker ads most often, with the sections behind each. General information only, not legal advice.
We write and run ads for brokers as part of our mortgage broker marketing, and every one goes to the broker's licensee before it runs. This guide sets out the rules those ads are drafted against. Confirm anything you plan to publish with your licensee or aggregator, and read RG 234 on ASIC's website.
What is RG 234?
Regulatory Guide 234, Advertising financial products and services (including credit), is ASIC's guidance on how the laws against false, misleading and deceptive advertising apply to financial products, financial advice, credit products and credit services. It is guidance, not law. The obligations sit in the ASIC Act, the Corporations Act and, for credit, the National Consumer Credit Protection Act 2009 and the National Credit Code in its Schedule 1. ASIC says it may take a greater interest in ads that fall short of the guide when deciding whether to make inquiries or use its powers (RG 234.15).
ASIC consulted on the update from 27 November 2025 to 22 January 2026 (CS 37). It says the new version adds guidance drawn from enforcement and regulatory action since 2012, simplifies the text, and brings in the guidance on past performance from RG 53, which ASIC has withdrawn.
Does RG 234 apply to mortgage brokers and lead generators?
Yes. RG 234 applies to anyone promoting financial products or credit, and it names third parties such as credit service providers, intermediaries including lead generators, and agents (RG 234.3). It covers any communication meant to promote those products or services, in any medium and whatever technology produced it, AI tools included (RG 234.4 and 234.5).
Three paragraphs speak to brokers directly. An intermediary promoting a lender's product should check that the features match the lender's current product information, that advertised fees are right, and that features not available to everyone are identified (RG 234.42). A lender cannot rely on a broker to correct a misleading impression its own ad created (RG 234.43). And a credit assistance ad should be clear about the scope of the service the borrower will get (RG 234.155).
If you buy leads, the seller's ads are part of the picture. RG 234 treats a lead generator as a promoter, so ask to see the ads and landing pages behind your leads before your team calls them.
What changed in the June 2026 version?
ASIC describes three changes: new guidance based on enforcement since 2012, simpler text, and RG 53 folded in. Read the new text and several things a 2012 guide could not have mentioned are now spelled out:
- AI-generated ads. The guidance applies whatever technology produced the ad, and ASIC notes that hallucinated or biased AI output can raise the risk of misleading advertising (RG 234.5).
- Short-form video. Stories and reels on Instagram and short clips on TikTok are named, and the Section B guidance applies to them like any other format (RG 234.158).
- Search and in-app ads. Paid search results, promoted listings and in-app ads, including in AI chat tools, are listed as internet advertising (RG 234.170), with a warning about headline claims where space is limited (RG 234.172).
- The actual audience. Who actually sees an ad counts, not only the audience the promoter had in mind, citing ASIC v Latitude Finance Australia (No 2) [2024] FCA 1205 (RG 234.134).
- Finfluencers. People who promote financial products and services online must not mislead, with ASIC's INFO 269 as the companion guidance (RG 234.179).
The test underneath is the familiar one. An ad is judged on the overall impression it creates when an ordinary member of its audience first sees it, and it can be misleading whether or not anyone meant it to be (RG 234.196 and 234.199).
What must a home loan ad include if it shows an interest rate?
A comparison rate, presented the way the National Credit Code requires. If a credit ad states an annual percentage rate, it must also contain the relevant comparison rate (section 160). The table sets out the rest.
| Requirement | Source |
|---|---|
| Include a comparison rate whenever the ad states an annual percentage rate | National Credit Code s160 |
| Calculate it for the prescribed amount and term closest to the typical loan for that product | National Credit Code s161 |
| Name the product, state the amount and term the comparison rate applies to, and say whether it is for a secured or unsecured loan where the prescribed amounts require it | National Credit Code s162 |
| Add the prescribed warning, in its long or short form | National Credit Code s163; National Credit Regulations reg 99 |
| Label it as a comparison rate, and make it no less prominent than any annual percentage rate or repayment amount in the ad | National Credit Code s164 |
| State an annual percentage rate if the ad states any repayment amount, and if fees and charges apply to an advertised rate, say so or state them | National Credit Code s150(3) |
Source: National Credit Code (Schedule 1 to the National Consumer Credit Protection Act 2009, compilation of 1 July 2026) and National Consumer Credit Protection Regulations 2010 (compilation of 5 September 2026), on legislation.gov.au, read on 1 October 2026.
ASIC's reading of "no less prominent" is practical (RG 234.58 to 234.59). A comparison rate in smaller type or a faded colour, one that needs a click or a hover to appear, or one placed far from the headline rate is likely to be less prominent. Matching the font size is not enough if the comparison rate blends into the background. The warning itself need not be as prominent as the rate (RG 234.61). In an online banner with no room for the warning, a clear link labelled as the comparison rate warning, placed as near the rate as possible, is the minimum ASIC will accept (RG 234.62).
The short form of the warning begins "WARNING: This comparison rate is true only for the examples given". Use the exact words in regulation 99 rather than a paraphrase.
Promotional rates need two more things. If the ad mentions a discounted or honeymoon rate, state the period it applies for with equal prominence, and name what it reverts to, such as the lender's standard variable rate (RG 234.53 to 234.54). An "up to" discount that only the largest loans receive needs that restriction made prominent (RG 234.34, Example 22).
Do brokers need a credit licence number in their ads?
In printed ads that identify the licensee, yes. Section 52 of the National Credit Act requires a licensee that identifies itself in a prescribed document to include its Australian credit licence number and say that it is one, and regulation 13 of the National Credit Regulations prescribes printed advertisements for credit the Code would apply to (RG 234.41, note 2). The civil penalty can reach 5,000 penalty units. The regulation is written for print, so check whether your licensee's advertising policy asks for the number on websites and digital ads as well, and how credit representatives should show their own number.
Which words and claims should brokers avoid?
Independent, impartial and unbiased; pre-approved and guaranteed; and any claim about lenders you do not actually use. Some of these are restricted by statute, others are examples ASIC has acted on or warns about, and every row below appears in RG 234.
| Word or claim | The problem | Source |
|---|---|---|
| Independent, impartial, unbiased, or a similar term | A licensee offering credit services to consumers cannot use them to describe itself or its service unless it meets strict statutory defences, which rule out receiving commissions and similar benefits from lenders | National Credit Act s160B; RG 234.126 |
| Financial counsellor, financial counselling | Restricted unless your credit activity is exempt as part of a financial counselling service | National Credit Act s160C; RG 234.126 |
| Loans from a wide range of lenders | Misleading if, in practice, you only ever consider one or two lenders | RG 234.155, Example 64 |
| Calling yourself a mortgage broker while affiliated with one lender | A mortgage broker provides credit assistance for contracts offered by more than one credit provider | National Credit Act s15B; RG 234 Example 64 |
| Pre-approved, guaranteed acceptance, no application refused, 100 percent success rate | Responsible lending means not every applicant can be approved, so these imply an assessment that has not happened | RG 234.141; Examples 57 and 58 |
| No credit checks, instant approval, no-doc | Likely to mislead, or to describe practices that breach responsible lending | RG 234.140 |
| Free, secure, guaranteed | Strong words to use only where they are true in their ordinary meaning | RG 234.120 to 234.122 |
| Debt free, for a consolidation loan | Misleading if what the service delivers is a consolidation loan or restructured repayments | RG 234 Example 65 |
| Reverse mortgage | Misleading for a product without the features of a reverse mortgage, such as a no negative equity guarantee | RG 234.127 |
Source: RG 234 (June 2026) and the National Consumer Credit Protection Act 2009 (compilation of 1 July 2026), checked 1 October 2026.
Can a broker ad promise approval?
Not safely. A credit licensee must not suggest a credit contract to a consumer, or help them apply, if the contract would be unsuitable, and judging suitability takes inquiries into the borrower's requirements, objectives and financial situation (RG 234.139 to 234.140, summarising Chapter 3 of the National Credit Act). An ad that implies approval, or an individual assessment that has not happened, cuts across that. Adding "conditions apply" or "find out if you qualify" may not be enough to fix it (RG 234.142). Advertise what you will do, such as compare loans from the lenders you work with, not what a lender will decide.
How does RG 234 apply to Google Ads, Meta and lead forms?
Every rule above applies online, and Section C of the guide adds detail for internet advertising:
- A link does not fix a misleading headline. Sending people to another page, a document or a QR code for the qualification will not correct a misleading claim in the ad (RG 234.36 and 234.173, citing ACCC v TPG Internet [2011] FCA 1254).
- Take more care on social platforms. People who see your ad on Facebook or Instagram have less reason to leave what they are doing to read conditions, so the balance has to be in the ad itself (RG 234.174).
- A small format is not an excuse. If a tile, banner or search ad cannot carry the qualification a claim needs, reconsider the format (RG 234.175).
- Search ads need care with headline claims, because space is limited and the listing's appearance is not fully in your control (RG 234.172).
- Disclaimers in the same language. If the ad is in a language other than English, the warnings and disclaimers should be too. ASIC's example is a broker whose Chinese-language ads carried English disclaimers (RG 234.38, Example 26).
- Keep records of every ad, including its disclaimers and warnings (RG 234.177).
- Comments count. A testimonial or comment someone else posts on your Facebook page becomes your responsibility once you know about it and decide to leave it up (RG 234.187).
The platforms add rules of their own. Google has required financial services advertisers to be verified before their ads show in Australia since 30 August 2022, which means showing it that you are licensed or authorised by ASIC, or exempt. Meta requires ads for loans to be targeted to people 18 and over.
What about reviews, awards and lender logos?
Testimonials must be authentic and attributed to the person who gave them (RG 234.130). If you advertise an award, name who granted it, explain it, show how current it is, and make it clear if the grantor is related to you (RG 234.80). Take care with third-party logos, lenders' logos included: ASIC warns that a reputable logo can create an impression of safety or institutional backing that does not exist (RG 234.128). Never reproduce the ASIC logo without ASIC's approval (RG 234.129).
A pre-publication checklist for broker ads
- Does the headline claim stand on its own, without relying on the fine print? (RG 234.34)
- If the ad shows a rate, is there a comparison rate for the right amount and term, labelled, with the warning, and at least as prominent as the rate? (National Credit Code s160 to s164)
- If it shows a repayment, is the annual percentage rate there too? (s150)
- If the rate is a discount, is the period equally prominent, and is the reversion rate named? (RG 234.53 to 234.54)
- Do product features and fees match the lender's current information? (RG 234.42)
- Does it use independent, impartial, unbiased, pre-approved, guaranteed, instant, no credit check or debt free? Remove them unless you are sure they are true and permitted. (s160B; RG 234.140 to 234.141)
- Does "a wide range of lenders" match the lenders you actually use? (RG 234.155)
- On printed ads, is the credit licence number there in the form your licensee requires? (s52; reg 13)
- Are disclaimers in the language of the ad, readable on a phone, and on screen long enough to read? (RG 234.35, 234.38 and 234.167)
- For bought leads, have you seen the ads and landing pages that produced them?
- Has your licensee or aggregator signed it off, and is a dated copy filed? (RG 234.177)
Who is responsible, and what are the penalties?
The business placing the ad carries the main responsibility, and publishers can share it, particularly when they help create the content (RG 234.183 to 234.186). The table shows the main credit provisions and the maximum penalties the legislation sets, in penalty units.
| Provision | What it prohibits | Maximum penalty as written |
|---|---|---|
| National Credit Code s154 | A false or misleading representation material to entering a credit contract | Civil penalty of 5,000 penalty units; an offence of 50 penalty units |
| National Credit Code s150 | Publishing a credit ad that does not meet the advertising and comparison rate rules | Criminal penalty of 100 penalty units |
| National Credit Act s160B | Using independent, impartial, unbiased or a similar term | Civil penalty of 5,000 penalty units |
| National Credit Act s52 | Leaving the credit licence number off a prescribed document | Civil penalty of 5,000 penalty units |
| National Credit Act s160D | Giving false or materially misleading information in a credit activity, knowingly or recklessly | Civil penalty of 5,000 penalty units; an offence carrying up to 5 years imprisonment |
Source: National Consumer Credit Protection Act 2009 and National Credit Code, compilation of 1 July 2026, on legislation.gov.au, read on 1 October 2026. The dollar value of a penalty unit changes, so check the current figure.
Before anything runs
RG 234 is guidance and this article is general information, not legal advice. Put anything new through your licensee's or aggregator's compliance process, and check the current text of the guide and the legislation before you rely on any of it.
For ads built around these rules from the first draft and judged on loans that settle, see how we run mortgage broker marketing, how we cost mortgage leads per settled loan, and our marketing for finance brokers who write business and consumer loans. Or book a free 30-minute profit audit and bring a quarter of your leads by source.
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