If you’re considering an Australian mortgage broker virtual assistant, the real question is not “Can I hire one?” It’s “Can I hire one without creating a compliance mess?”
Good news. Virtual assistants can be compliant. Many broker businesses use remote support safely.
But there’s a line. Cross it, and you can accidentally create licensing risk, privacy risk, cyber risk, and best interests risk. The trick is knowing where the line is, then building controls that keep you on the safe side.
Compliance is not a vibe. It’s evidence.
In practice, a compliant VA setup means you can show, on request, that:
Mortgage brokers also sit inside a tighter framework than most people realise.
The best interests duty applies when providing credit assistance, and ASIC explains what it expects when it assesses compliance.
Separately, credit licensees have general conduct obligations under section 47 of the National Credit Act. That includes doing things efficiently, honestly, and fairly.
So the VA question becomes simple:
Is your VA model helping you meet these obligations, or quietly making them harder to meet?
This is not a niche operating model anymore. Broker businesses are scaling.
The Mortgage & Finance Association of Australia reports broker market share hit 76.8% of all new residential home loans in the March 2025 quarter.
When an industry becomes that central, scrutiny tends to rise too.
So a VA setup should not be “cheap admin support.” It should be a controlled operating model.
Here’s the single most important rule to get right.
A VA can do lots of valuable work. But if your VA starts doing work that looks like credit assistance, you can drift into licensing and supervision risk very fast.
ASIC’s broker guidance is built around what happens when you provide credit assistance and what best interests means in that context.
These tasks are usually easier to structure safely because they do not require the VA to decide, recommend, or influence the credit outcome:
These activities often require tighter controls, and in some cases you may decide they are not suitable for an offshore VA at all:
If a regulator or dispute ever asks, “Who shaped the recommendation?” you want a clean answer.
The broker did. The VA supported the process.
A VA model is compliant when three pillars hold.
ASIC’s best interests duty guidance is not just theory. It points to what ASIC looks for in practice.
A VA can support that duty. Or undermine it.
Your controls should show:
Section 47 of the National Credit Act includes an obligation to do things efficiently, honestly, and fairly.
ASIC’s RG 205 explains how ASIC thinks about compliance with general conduct obligations, and it focuses heavily on whether your measures and systems are effective.
A VA model needs to fit into that.
That means documented:
If your VA is offshore, privacy becomes a board level issue.
The OAIC explains APP 8 cross border disclosure and when an entity can be accountable for what an overseas recipient does.
If your business is covered by the Privacy Act, you also need to understand the Notifiable Data Breaches scheme, which requires notification in certain serious harm scenarios.
The practical point is simple:
Offshore does not reduce your responsibility. It increases your controls requirement.
This is the checklist that stops most problems before they start.
Be blunt. Write what they do and what they never do.
Include:
Use three buckets:
Then build controls around amber. Remove red.
A good supervision model has receipts.
Examples:
ASIC guidance exists because supervision and outcomes matter, not just intent.
If personal information is disclosed to an overseas recipient, APP 8 becomes relevant, and OAIC guidance explains what “disclosure” can look like.
Practical controls that help:
If you are covered by the Privacy Act, the OAIC sets out when you may need to notify under the Notifiable Data Breaches scheme.
So have:
AFS and credit licensees may need to report certain reportable situations to ASIC. ASIC summarises the regime and reporting expectation.
Your VA model should not become a blind spot.
This is where good businesses get caught out.
If you fix these, you are already ahead of most of the market.
Use this table to choose the model that matches your risk appetite.
| Model | What it looks like | Typical compliance strengths | Typical compliance gaps | Best for |
|---|---|---|---|---|
| Direct hire VA (offshore) | You recruit and manage the VA | Cost efficient, high control over workflow | Harder privacy enforcement, device and access risk | Mature brokers with strong internal controls |
| BPO managed VA | Provider supplies VA and management | Better process discipline, SOPs, supervision support | You must verify controls, avoid “black box” ops | Scaling teams needing process structure |
| Hybrid (onshore admin + offshore processing) | Client contact stays onshore | Reduces client interaction risk | Handover points can create errors | Brokers who want a safer ramp up |
| Contractor VA (mixed tasks) | Flexible, multiple duties | Quick start | Scope creep into red tasks, weaker supervision | Only if you have tight task boundaries |
| “Full service” offshore processing | Provider runs file end to end | Fast throughput | Highest risk of losing effective control | Only with strong governance and strict role limits |
The goal is not “lowest cost.” It’s “lowest regret.”
Here’s a practical way to structure work so the VA drives speed, while you keep compliance tight.
Notice what’s happening.
The VA increases throughput. The broker retains the judgement.
That alignment matters under best interests duty expectations.
This is the minimum standard many broker businesses adopt.
OAIC guidance on cross border disclosure is worth reading carefully if your VA sits outside Australia.
And your breach plan should align with the OAIC’s Notifiable Data Breaches framework if you are covered.
Yes, they can be. The key is task design and controls. Keep VAs in support tasks, not credit recommendations. Maintain supervision evidence. Manage privacy for offshore disclosure under APP 8.
If they only do admin support, usually no. If they provide “credit assistance” activities, licensing and authorisation issues can arise. Design the role so the broker remains the decision maker.
Scheduling, CRM updates, checklist prep, document chasing, lodgement support, and status tracking are common. Draft tasks can work if the broker reviews and approves. Avoid tasks that influence recommendations or client decisions.
Use least privilege access, secure portals, MFA, device rules, and monitoring. If you disclose personal information to an overseas recipient, APP 8 may apply and accountability can follow. Have a breach response plan aligned with OAIC guidance.
If your organisation is covered by the Privacy Act, you may need to notify affected individuals and the OAIC when serious harm is likely. This is the Notifiable Data Breaches scheme. You should have a clear incident process and evidence capture.