Fees for no service just landed on the FSCP register.

Fees for no service was the scandal that defined the Royal Commission. Seven years on, it has quietly reached the FSCP Outcomes Register for the first time.

The Panel called it human error.

It issued the written direction anyway.

Licensees and advisers, alike, need to be aware that the FSCP has it sights now set on an new area of adviser issues – ongoing fee arrangmenets.

What Mr C did, and what the Panel did about it

On 8 April 2026, the FSCP issued a written direction to Mr C under s921L(1)(a)(i) of the Corporations Act. The conduct was narrow.

Mr C charged clients ongoing financial advice fees and failed to provide the services those fees were contracted to cover. A single instance. Isolated.

The Panel accepted it was human error, and it accepted that Mr C and the licensee had taken appropriate steps to prevent it happening again. The Panel still issued a written direction.

That is the point to hold onto. Good intent, isolated occurrence, prompt remediation, cooperative licensee. All present. The instrument issued anyway.

Why Standard 2 and Standard 7 both engage here

The summary names two Standards of the Code of Ethics: Standard 2 and Standard 7.

• Standard 2 requires that you act with integrity and in the best interests of each client. Charging for a service not delivered is a direct failure of that. It does not matter whether the failure was deliberate or accidental. The test is objective: did the client receive the service they paid for? In this case, no.

• Standard 7 requires that the client understand and consent to the fees, and that the fees are fair and represent value for the services provided. If no service was provided, the fee cannot represent value. Standard 7 is engaged the moment the fee is charged without the service sitting behind it.

The Values also matter

The Panel called out two Values as well: Trustworthiness and Diligence.

Values sit above the Standards. A breach of a Standard is also, almost always, a breach of one or more Values.

In this case, Trustworthiness was engaged because the client trusted that paying the fee would produce the service. Diligence was engaged because the failure to deliver reflected a lapse in process, not a considered decision.

The Code of Ethics is designed so that Values give context to Standards.

What this means for you

Three practical takeaways for licensees and advisers:

1. Fees for no service is now live on the FSCP register.  The section of the Corps Act in play here is s921E(3), the obligation to comply with the Code.
2. When the situation involves fees, consider Standard 7 before Standard 5. Ask first whether the fee arrangement itself is fair and consented to. Only then move to whether the advice behind the fee was appropriate.
3. Remediation does not undo the breach. The Code is not contingent on whether the harm was reversed.

Fees for no service reached the register quietly. One written direction, one isolated incident, one adviser. But the signal matters. The Panel has now shown that even the narrowest instance, accepted as human error and fully remediated, sits inside the scope of Standards 2 and 7. That is the benchmark being set for the profession.

If you area licensee, cases like this are worth reviewing. They show you how the Code is read in practice.

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