The paper, released last week, details three potential packages of options, from relatively minor changes to the existing law through to extensive rewrites.

The tone of the proposal seems to indicate the Ministry of Business, Innovation and Employment is keen to emulate the approach of the Financial Markets Conduct Act.

It discusses licensing adviser businesses rather than the advisers themselves, and giving them regulatory responsibility for their employees.

One adviser who did not want to be named said that would be harder on smaller AFA businesses than many other market participants.

“It’s business as usual for QFEs because they are already licensed but the poor old AFAs have to go through the mill again, this time licensing their entities.”

It seems likely that people who are currently registered financial advisers will also have a host of new requirements, including ethical and competence obligations, as well as the need to license their businesses.

The options paper said that would extend the efficiencies of the current QFE model.

If its suggestion of "expert" financial advisers who could handle more complex matters was introduced, they would then be subject to another level of licensing.

The adviser said, if that was the track the Ministry intended to go down, it would make sense to define financial advice as a financial product and scrap the Financial Advisers Act altogether.

He said it seemed that although MBIE said it was consulting widely, there were only two things not decided on – whether all advisers should be subject to the requirement to put clients first and whether there was a need to distinguish “expert” advisers.

The issue of exemptions for accountants, lawyers and some journalists, which many advisers have objected to, seems set to remain.

“They are no more consulting than they are flying to the moon.”