Different regulators, different consent law, different market structure. What a broker operating in both markets has to change, and what carries across unchanged.
Figures in this article describe the wider market and are drawn from the third-party sources listed at the end. They are not Lead Foundry results, and nothing here is a projection of what any individual broker will achieve.
A broker licensed on both sides of the Tasman can run one sales process and one CRM. What cannot be shared is the compliance layer, because the two markets regulate the same activity through different instruments.
This is the practical diff. It covers who regulates you, what consent you need before contact, and what the underlying market looks like in each country.
Neither country regulates the purchase of leads directly. Both regulate what you do next, and that is where the divergence starts.
| Area | New Zealand | Australia |
|---|---|---|
| Primary regulator | Financial Markets Authority | ASIC |
| Licence to give advice | Financial Advice Provider licence, or operating under one | Australian Credit Licence, or credit representative status |
| Conduct standard | Code of Professional Conduct for Financial Advice Services | Best interests duty, ASIC RG 273 |
| Public register to check a counterparty | Financial Service Providers Register | ASIC registers and credit licensee lookup |
| Misleading conduct | Fair Trading Act 1986, Commerce Commission | Australian Consumer Law, ACCC |
| Complaints scheme | An approved dispute resolution scheme such as IFSO | AFCA |
The FMA data gives a sense of the New Zealand market shape: just over 3,000 financial advice businesses, made up of 1,807 Financial Advice Providers and 1,200 Authorised Bodies, engaging 10,743 financial advisers and 12,287 nominated representatives. 82% of financial advice providers have fewer than ten advisers.
This is the single largest operational difference, and it runs the opposite way to what most brokers expect. Australia has more explicit machinery around unsolicited contact, so an Australian broker has more boxes to tick before dialling.
Electronic messages are governed by the Unsolicited Electronic Messages Act 2007, which requires consent, accurate sender identification, and a functional unsubscribe on commercial electronic messages sent to New Zealand addresses. There is no national do-not-call register for voice calls, so a phone call to a consumer who submitted an enquiry is on ordinary footing.
The privacy obligation is IPP 3A of the Privacy Act 2020, which applies when you collect information about someone from a source other than that person. Buying an enquiry is exactly that, so the obligation to make the consumer aware falls on you as well as on the supplier.
The Spam Act 2003 governs commercial electronic messages. Separately, the Do Not Call Register Act 2006 means a telemarketing call to a listed number requires the recipient's consent. ACMA has published its expectations for what consent records must contain: the method used to give consent, the terms of that consent, and the date and time it was obtained, and ACMA can compel production of those records on complaint.
APP 5 requires notification at collection and APP 7 restricts direct marketing using third-party data unless the APP 5 notification covered direct marketing as a purpose. The OAIC guidelines name third-party lead generation explicitly as caught data.
What this means when you buy: An Australian broker needs the supplier to hand over consent evidence in a form that would survive an ACMA request, covering method, terms, and timestamp. A New Zealand broker needs the supplier to have disclosed the onward supply on the form so the IPP 3A obligation is already satisfied at the source. Ask for the specific artefact, not a reassurance.
Australia is a far more broker-mediated mortgage market. MFAA data puts broker share of new residential home loans at 81.0% for the March 2026 quarter, the highest since records began, up from 55.3% in the March 2018 quarter. Leading aggregators settled A$124.88 billion in the March 2026 quarter alone.
| March 2018 quarter | 55.3% |
|---|---|
| March 2026 quarter | 81.0% |
A 25.7 percentage point rise across eight years. Australia is now one of only a small group of markets, alongside the UK and the Netherlands, where brokers write more than 80% of mortgage lending.
That share difference changes what a purchased enquiry means. An Australian consumer submitting a mortgage enquiry is very likely already expecting to deal with a broker. The equivalent New Zealand consumer is more likely to be weighing a broker against going direct to their bank, which puts more of the first conversation into explaining the channel itself.
On the insurance side, the New Zealand picture is a large underinsurance gap rather than a channel contest. FSC research found only 41% of New Zealand respondents hold life insurance and 11% hold income protection, with around 70% of New Zealanders underinsured.
Most of the operational work. The response-time research is not market-specific, and neither is the contact-strategy research. Speed to first call, a six-attempt cadence, exclusive supply, and verification at submission all behave the same way in Auckland and in Sydney.
Where Lead Foundry sits, in plain terms: Lead Foundry currently supplies life insurance enquiries in New Zealand. Mortgage supply opens when LoanWatch launches. This is a comparison of the two markets rather than an offer in either, and the Australian half is written from the published regulatory guidance rather than from our own supply.
| Before you buy | New Zealand | Australia |
|---|---|---|
| Verify the supplier exists | NZBN register and the FSPR | ABN lookup and ASIC registers |
| Confirm your own authority to advise | FAP licence or authorised body status | ACL or credit representative status |
| Get the consent artefact | Form disclosure supporting IPP 3A | Consent record with method, terms and timestamp |
| Confirm electronic message compliance | UEMA consent, sender ID, unsubscribe | Spam Act consent plus Do Not Call position |
| Confirm the conduct standard applies | Code of Professional Conduct | Best interests duty under RG 273 |
Only if they hold the right Australian authorisation for the advice they intend to give. Buying the data is not the constraint; providing credit assistance or financial advice to an Australian consumer requires an Australian Credit Licence or credit representative status, or the equivalent financial services authorisation. Holding a New Zealand FAP licence does not carry across.
Yes. Neither country prohibits purchasing consumer enquiry data. Both regulate what happens next: how the consumer was told their information would be passed on, whether you have consent for the channel you contact them through, and whether you are licensed to give the advice you then give.
On unsolicited contact, generally yes. Australia has a Do Not Call Register and the Spam Act 2003, and ACMA has set out specific expectations for consent records covering method, terms and timestamp. New Zealand has no equivalent call register, though the Unsolicited Electronic Messages Act 2007 governs commercial electronic messages and IPP 3A governs indirectly collected information.
Broker share in Australia reached 81.0% of new residential home loans in the March 2026 quarter, up from 55.3% eight years earlier, driven by aggregator infrastructure, lender panel breadth and consumer habit. New Zealand consumers are more likely to weigh an adviser against dealing with their existing bank, which changes what the first conversation on a purchased enquiry has to accomplish.