RG 234: What ASIC's June 2026 Update Means for Your Financial Services Advertising

For fourteen years, the guide most Australian fund managers, advisers and lenders used to check their advertising was written for a world of newspaper ads and radio spots. On 9 June 2026, ASIC replaced it.

The updated Regulatory Guide 234 keeps the core idea that advertising must not mislead. What has changed is the detail around how people now meet financial products: through social feeds, short video, sponsored content, influencers and increasingly through content drafted with AI tools.

If your marketing team or agency built its checklist on the 2012 version, it is out of date. The new guide is longer, more specific about channels and more direct about who carries responsibility when something goes wrong. It also expects someone in your organisation to own the process, from AI drafts to influencer posts. Here is what matters.

What is RG 234?

RG 234 is ASIC's guidance for anyone promoting financial products, financial advice services, credit products or credit services, and for the publishers who carry those promotions. The updated RG 234 was issued on 9 June 2026 and replaces the version from November 2012.

It is guidance, not a law in its own right. Its purpose is to help promoters comply with their legal obligations not to make false or misleading statements or engage in misleading or deceptive conduct. ASIC also says it may take a greater interest in advertisements that do not meet the guidance when deciding whether to make inquiries or use its regulatory powers. In practice, that makes RG 234 the benchmark your advertising will be measured against.

The guide is written broadly. It applies to any communication whose purpose is to inform consumers about or promote a financial product or service, through any medium, and it names intermediaries such as lead generators among the promoters it covers.

What changed in the June 2026 update?

Three changes stand out for marketing teams.

AI generated content is named directly

The new guide says it applies regardless of the technology used, including artificial intelligence. It notes that the law applies to AI generated advertising in the same way as human generated content, and that the potential for hallucinated or biased content from AI tools may increase the risk of misleading advertising. It also expects advertisements for financial services to give balanced messages about customer tools used in those services, including AI tools.

If your team uses AI to draft ad copy, product descriptions or social posts, the output carries exactly the same legal weight as anything a person wrote. Someone needs to check it before it goes live.

Social and short form formats get specific attention

The guide addresses banners, tiles, posts, reels and short videos on platforms such as Facebook, TikTok, X, YouTube and Instagram. It asks promoters to consider the overall impression created the first time an ad is seen, and to think carefully about whether a channel is appropriate at all if content limits leave too little room for balanced information.

It also says the stronger the headline claim about returns, the more important it is for risk information to sit in the banner ad itself rather than on another page.

Sponsored and influencer content is harder to hide

RG 234 now says advertising should be clearly distinguishable from news and opinion content, particularly in high trust settings like social media where people do not expect paid content. Where a publisher or influencer actively contributes to or promotes a product, ASIC regards them as being in the same position as the promoter.

What does RG 234 say about past performance?

This is one of the most practical sections for fund managers, and it is specific.

An advertisement that includes past performance should draw attention, unambiguously and without reservation, to the fact that past performance is not indicative of future performance. The warning should appear legibly or audibly in the main part of the promotion and close to the performance figures. For online formats, the guide says the consumer should not have to click through to another link to see it.

This single requirement changes a lot of social content. A reel that flashes a return figure for two seconds, with the warning in the caption below the fold, is the kind of format the guide is pushing against.

Performance figures also need context. Selective periods, comparisons that flatter and returns shown without fees all create the unbalanced impression the guide is designed to prevent. If your fact sheet leads with the best twelve month return in the fund's history, expect questions about why that window was chosen.

How should warnings and disclaimers be used?

Carefully, because RG 234 is clear that a disclaimer cannot rescue a misleading headline.

The guide accepts that a headline will not always contain every relevant detail. It says the more a qualification changes the headline claim, the more prominent that qualification should be, and that the headline itself must not be misleading. Warnings in fine print, buried in dense text or shown only briefly may not be enough to correct a misleading headline.

In practice, that means reading the ad the way a first time viewer would. If the only thing they remember is the headline, would they understand the product correctly? If not, the qualification needs to move closer to the claim or the headline needs to change.

The same logic applies to words like "free", "low cost" and "stress free". If there is a cost, a condition or a risk that changes the meaning of the claim, it belongs next to the claim.

Do finfluencers and sponsored posts fall under RG 234?

Yes. RG 234 says social media influencers who discuss or promote financial products and services must ensure promotional material is not misleading and complies with other financial services laws, and points to ASIC's separate guidance on discussing financial products online.

That guidance makes two points licensees need to take seriously. Influencers who provide financial product advice or arrange dealing as part of a business need an AFS licence or authorisation, and licensees who use influencers may be liable for the influencer's misconduct. In 2026, ASIC reminded licensees for the first time since issuing that guidance that responsibility for supervising finfluencers and liability for breaches stay with the licensee when an influencer acts as its authorised representative.

For a fund or adviser running an influencer campaign, the influencer's content is your advertising. Brief it, approve it and keep records of it. Agree in writing what claims the influencer can make, how they will disclose the commercial relationship and who signs off each post before it goes live.

How should you audit your advertising against RG 234?

Start with the channels where the new guidance is most specific, because that is where older checklists fall short.

1. List every live advertisement, including social ads, sponsored posts, influencer content, email campaigns, landing pages and anything produced with AI tools.
2. Check every headline claim about returns, benefits or cost against the balance of risk information in the same placement.
3. Confirm past performance figures carry a prominent warning in the main body of the ad, with no click through needed.
4. Review who your ads are reaching. RG 234 also says statements about who a product suits should be consistent with the product's target market determination.
5. Keep records of each advertisement, including warnings and disclaimers, as the guide recommends.
6. Put an approval step in front of AI generated and influencer content before it publishes, and record who approved each item and when.

If you find problems, fix the highest reach placements first. A paid social campaign running today matters more than a brochure that sits in a drawer.

Want a second view on whether your advertising reflects the updated RG 234? Talk to our team and we will walk through it with you.

Frequently asked questions

Is RG 234 legally binding?

RG 234 is ASIC guidance. The binding obligations sit in the Corporations Act, the ASIC Act and the National Credit Act, and RG 234 explains how ASIC expects promoters to meet them.

Does RG 234 apply to wholesale only products?

The guide is framed around consumers and retail audiences. If wholesale marketing reaches a broader audience through public channels, the misleading conduct prohibitions still apply, so get advice on your specific distribution.

Does RG 234 cover our product disclosure statement?

No. The guide says advertising does not generally include statements in regulated disclosure documents such as a PDS, prospectus or Financial Services Guide.

What about superannuation fund advertising?

RG 234 applies, and ASIC has other product specific guidance that sits alongside it. Check Appendix 2 of the guide for the related documents that apply to your product.

Are publishers responsible for our ads?

Publishers may bear some responsibility, and ASIC expects them to stop running an ad that is subject to a stop order or public warning notice. Primary responsibility still rests with the organisation placing the ad.

References

• Australian Securities and Investments Commission. (2022). Discussing financial products and services online (INFO 269). asic.gov.au

• Australian Securities and Investments Commission. (2026, June 9). RG 234 Advertising financial products and services (including credit). asic.gov.au

• Australian Securities and Investments Commission. (2026). ASIC continues finfluencer crackdown alongside global regulators (26-081MR). asic.gov.au