ASIC Counted The Back Office. Four Firms Had One Person In It.

You hire for the work that does not require the licence. Australian businesses asking how to hire offshore staff in Australia almost always start from the hourly rate, which is the wrong end of the problem. Start instead from the function currently carried by one person who has no cover when that person takes leave.

ASIC counted the staff, not the policies

On 13 October 2026 ASIC published Report 840, a review of 13 credit licensees making up eight large mortgage broker aggregator groups. Those groups carry roughly two thirds of all broker representatives in the country, so this is no sample of stragglers.

Buried in the complaints chapter is a sentence that reads like a staffing audit. “Four licensees had only one or two designated complaints handling officers.” And then: “Only two of these licensees had contingencies in place to cover leave or increased workload.”

ASIC also records what happened when the cover was not there. In one case “support staff were unable to properly handle an IDR complaint when the dedicated complaints officer went on leave”. The regulator’s position is plain enough: “Licensees are required to have sufficient staff to deal with complaints in a fair and effective manner.”

Outstaffer sells against exactly this gap, so treat the next part as a disclosure of interest. Our Employer of Record service exists because the second person in a two person function is usually the one nobody can justify hiring locally.

The levy everybody argued about is worth less than the gap

Brokers spent the past fortnight arguing about something else. The Adviser reported on 16 October that Treasury has tabled a Compensation Scheme of Last Resort special levy of $7.79 million on credit intermediaries for 2026-27, against roughly $668,000 the year before, an increase of about elevenfold.

Put the regulator’s own published numbers against that. ASIC’s CSLR page records the earlier special levy as $667,529.41 across 4,137 entities, charged at $5.72 per credit representative. Multiply that rate by about twelve and you land near $67 a representative a year. A forty broker business goes from roughly $229 to roughly $2,680.

That is the number generating submissions. Meanwhile one complaints officer taking three weeks of leave, in a firm ASIC has named as having no contingency, costs more than $2,680 in delayed resolutions, AFCA escalations and principal hours. The expensive problem is the one nobody filed a submission about.

Which work can leave Australia, and which cannot

The licensed act does not move. Credit assistance, the recommendation itself, the best interests duty sitting behind it: that stays with the credit representative, onshore, supervised, and no staffing model changes it.

Almost everything touching it can sit somewhere else. Document collection. Lender portal data entry. File preparation and compliance note assembly. Post settlement servicing. First pass triage of an incoming complaint, logged and routed, before a licensed person makes a decision on it.

What is offshore staffing actually buying here?

A second trained person on a function that currently has one. Not a cheaper version of the person you have. Working out whether the model fits your business comes before working out the rate, because a function with one person in it fails the same way at any price.

Does the supervision obligation change?

No, and this is the honest counter-argument. Adding a remote team adds a supervision layer you then have to actually run, and ASIC’s own finding is that oversight is already thin. “None of the licensees had conducted any assurance process in the two years before our review.” A firm that cannot assure its onshore complaints data will not assure a distributed team either. The obligations that apply when you engage staff outside Australia are the floor, not the plan.

Related reading

• Which roles should go first
• Who checks the work once it is done

Where to start when you hire

List every function in the business. Mark the ones with exactly one trained person. That list is your hiring order, and ASIC has published the evidence that complaints handling belongs near the top of it for a lot of firms.

If you want to put a real number against the second seat rather than argue about a levy, sign up and scope one role and compare it to what a week of that person’s absence already costs you. Which function in your business would stop tomorrow if one person called in sick?