The introduction of the Conduct of Financial Institutions regime marks one of the most significant shifts in the history of New Zealand’s financial services sector. Although CoFI applies directly to banks, insurers, and non‑bank deposit takers, its influence reaches every adviser, every advice process, and every client interaction. The regime is a response to years of conduct and culture reviews by the Financial Markets Authority and the Reserve Bank of New Zealand, which found that institutions were not consistently putting in place systems to ensure consumers were treated fairly. These findings led to the Financial Markets (Conduct of Institutions) Amendment Act 2022, the legislative foundation of CoFI.
CoFI is not simply another compliance requirement. It represents a philosophical shift in how financial services are expected to operate in Aotearoa. Fairness is no longer an aspiration. It is a regulated obligation. And while institutions carry the licence, advisers carry the experience that clients feel every day. This is where the real implications of CoFI emerge.
A New Standard of Professionalism
CoFI elevates the expectations placed on advisers. It requires institutions to demonstrate that their networks — including advisers and intermediaries — consistently deliver fair outcomes. This means advisers must now operate within clearer frameworks, stronger governance, and more transparent processes.
The days when good advice was defined solely by technical accuracy are behind us. Today, good advice is defined by behaviour, culture, and the systems that support them. Advisers must be able to show not only that their recommendations are suitable, but that their processes are fair, their communication is transparent, and their conduct aligns with the institution’s Fair Conduct Programme.
This shift is reshaping what it means to be a professional adviser in New Zealand. It is raising the bar — and rightly so.
Greater Scrutiny, Clearer Expectations
One of the most immediate implications of CoFI is the increased oversight advisers will experience. Institutions are now required to monitor adviser behaviour more closely, ensure advice processes are consistently applied, and identify conduct risks before they become consumer harms.
For advisers, this means:
- More structured documentation
- More transparent remuneration models
- More consistent client‑first processes
- More evidence of fairness in every step of the advice journey
This is not about policing advisers. It is about ensuring that the entire sector operates with integrity and that clients receive the standard of care they deserve.
The End of Ambiguity
Before CoFI, conduct expectations were often implied rather than explicit. Advisers were expected to “do the right thing,” but the definition of “right” varied between organisations. CoFI removes that ambiguity. It sets a clear, enforceable expectation: consumers must be treated fairly, consistently, and transparently.
This clarity benefits advisers. It provides a framework that supports good practice, reduces uncertainty, and strengthens the trust that underpins the adviser‑client relationship. When expectations are clear, professionalism becomes easier to demonstrate — and easier to recognise.
A Shift Toward Capability and Culture
CoFI is not just a compliance regime. It is a capability regime. Institutions must now invest in training, systems, and support structures that enable advisers to meet conduct expectations. This includes clearer guidance, better tools, and more consistent oversight.
For advisers, this means access to stronger professional development pathways and more structured support. It also means that capability is no longer optional. Advisers who invest in their skills, their processes, and their client experience will thrive in the CoFI era. Those who do not will find it increasingly difficult to meet the expectations of institutions, regulators, and clients.
This is where A‑Perform plays a critical role. Our purpose is to help advisers build the capability, confidence, and consistency required in this new environment. CoFI does not just require compliance. It requires competence. And competence requires investment.
A More Trusted, Transparent Sector
Ultimately, CoFI is about trust. It is about ensuring that every New Zealander who seeks financial advice can rely on the integrity of the system that supports it. The conduct and culture reviews that preceded CoFI did not uncover widespread misconduct, but they did reveal a need for stronger systems, clearer expectations, and more consistent oversight.
CoFI addresses that need. It strengthens the foundations of the sector and positions advisers as trusted professionals operating within a transparent, client‑centred framework.
For advisers, this is an opportunity. It is a chance to differentiate through excellence, to build deeper client trust, and to demonstrate the value of advice in a way that is visible, measurable, and aligned with national expectations.
Looking Ahead
The future of financial advice in Aotearoa will be shaped by those who embrace this new era of fairness, capability, and accountability. CoFI is not a burden. It is a catalyst — one that will elevate the profession and strengthen the trust that New Zealanders place in their advisers.
At A‑Perform, we are committed to helping advisers navigate this transition with clarity and confidence. The opportunities ahead are significant, and together, we can build a sector that is resilient, trusted, and ready for the next decade of change.
