This sector submission responds to the Fair Work Commission’s Gender‑Based Undervaluation – Priority Awards Review of the SCHADS Award, following the Report to the Expert Panel released on 16 December 2025. It focuses on the proposed Alternative Classification Structure for counsellors, including financial counsellors. The submission welcomes the inclusion of a clear definition of “counsellor,” and the recognition of counsellors at senior professional levels (Levels 7–9), which better reflects the complexity, responsibility, and professional expertise of financial counsellors who support more than 200,000 people face‑to‑face each year.

The submission raises two key concerns about unintended consequences in the current drafting. First, treating Level 5.1 as a “minimum entry point” risks creating a de facto lower entry point for counsellors who, in practice, always work under some level of supervision or direction. Second, the distinctions at Level 6 tied to “direct supervision” versus “general direction” could be applied inconsistently, incentivising misclassification. To address this, the submission recommends confirming Level 7 as the minimum classification for qualified financial counsellors, limiting Level 6 to clearly defined student internship circumstances, and explicitly linking supervision terms to recognised professional benchmarks (e.g., accreditation status, independent practice, and provision of secondary consultation or supervision). It also urges the Commission to acknowledge funding impacts for government‑funded services, consider regional and remote labour‑market pressures, and ensure that no worker is left worse off during transition and implementation timelines.

Submitted jointly with

• Financial Counselling Australia (FCA)
• Financial Counselling Queensland (FCQ)
• Financial Counselling Victoria (FCVic)
• Financial Counsellors’ Association of NSW (FCAN)
• Financial Counsellors’ Association of Western Australia (FCAWA)
• Financial Counsellors Association Tasmania (FCAT)
• Financial Counsellors Australian Capital Territory (FC‑ACT)
• South Australian Financial Counsellors Association (SAFCA), incorporating the Northern Territory

This submission should be read in conjunction with our previous submission, from 5 September 2025.