Working in Victorian real estate: licence, representative, new CPD

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Kooky

Builder of Shaka, the payment router that pays every agent their commission on closing date.

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Anyone who sells, leases or manages property for other people in Victoria does so under one of two statuses. Either they hold an estate agent's licence, or they work for someone who does, as an agent's representative. The two are not levels of the same thing. They carry different entry rules, different paperwork and different limits on what the person may do, and the second is, under the current rules, the way into the first.

This guide sets out both, as Consumer Affairs Victoria describes them on its licensing pages, most of them updated between June and September 2026. It covers who is eligible, which qualification counts, how a company is licensed and who must run it, how an application goes through the Business Licensing Authority, what the fees are for the 2026-27 financial year and what the annual statement involves. It also covers a system in transition: from 25 November 2026 representatives are to be registered directly with the Authority, and from 1 April 2027 annual continuing professional development becomes a condition of staying in the trade.

Consumer Affairs Victoria, estate agent licensing pages updated June to September 2026. The fee applies from 1 July 2026 to 30 June 2027.

Two statuses, one trade

Consumer Affairs Victoria states that individuals who want to work as an estate agent in Victoria need an individual licence, and that a person who plans to operate through a company needs the company licensed separately as well. The licence is what allows someone to run an estate agency business.

An agent's representative, in the regulator's words, is a person employed by, or acting for, a licensed estate agent. With written authority from that agent, a representative can perform any of the agent's legal functions, and the regulator gives the two familiar examples: acting as a salesperson or as a property manager. What a representative cannot do is operate an estate agency business.

The practical difference lies in who answers for the work. A licensee answers to the Business Licensing Authority directly: the Authority grants the licence, may impose conditions on it, and may vary or revoke those conditions. A representative works under the authority of an employer who has checked their eligibility and put their authority in writing. Until 24 November 2026 a representative does not apply to the Authority at all; that is one of the rules about to change, and it is covered in its own section below.

Who is eligible for an individual licence

The individual licence page of Consumer Affairs Victoria, last updated on 30 September 2026, sorts the conditions into three groups.

The first group is what an applicant must have. There are two parts: experience and education. On experience, the applicant needs at least one year of full-time work as an agent's representative in Victoria, gained within the three years before applying. On education, the applicant needs a prescribed course, described in the next section.

The second group is what rules a person out automatically. A person is ineligible if they are under 18, if they are a represented person under the Guardianship and Administration Act 1986, or if they, or a company of which they are a director or officer, are currently disqualified from holding an estate agent's licence anywhere in Australia or elsewhere.

The third group is what may rule a person out, without doing so automatically. The regulator lists three situations: being insolvent under administration, which it explains as bankruptcy or a debt agreement under Part IX or Part X; having been convicted or found guilty, within the last 10 years, of a disqualifying offence; and having ever had a claim admitted against the Victorian Property Fund or the Estate Agents' Guarantee Fund. A disqualifying offence is one involving fraud, dishonesty, drug trafficking or violence that is punishable by three months or more in prison.

In those three situations a person may apply to the Authority for permission to hold a licence. Permission is a separate application with its own fee, far higher than the licence fee itself: the fees page gives A$1,383.20 for an individual in 2026-27. Whether permission is granted depends on the case, and the pages read for this guide do not set out the criteria the Authority applies.

There are also three routes that do not start from the standard experience-and-course path. A person who has held a Victorian licence within the last five years is eligible on that basis. A person who holds a current equivalent licence in another Australian state or territory, or in New Zealand, can rely on mutual recognition. A person who holds, or has held, an equivalent licence overseas may be eligible for recognition, which the page presents as a possibility and not as an entitlement.

The qualification and the five-year rule

The education requirements sit in the Estate Agents (Education) Regulations 2020, and Consumer Affairs Victoria summarises them by asking one question first: when was the course completed?

Where the course was completed within the last five years, two qualifications count for a licence. One is the Certificate IV in Real Estate Practice, course code CPP41419. The regulator specifies its make-up: 15 listed core units, plus three electives, for 18 units in total. The other is the Diploma of Property (Agency Management), made up of seven prescribed units and five electives, for 12 units in total. In both cases the course must be delivered by a registered training organisation in Victoria.

Where the course was completed more than five years ago, the qualification alone is not enough. The applicant must also show earlier work in the trade, in one of two forms: a Victorian estate agent's licence held within the last 10 years, or at least two years of full-time work as an agent's representative within the last 10 years, with one of those years falling within the three years before the application is lodged. The applicant must also have completed one of the prescribed older courses. The example the regulator gives is the Certificate IV in Property Services (Real Estate) completed on or before 30 September 2021.

A worked example shows how the dates combine. Assume a person finished the Certificate IV in Real Estate Practice in March 2020 and lodges a licence application in October 2026. The course is more than five years old, so the recent-course path is closed. To qualify on the older-course path, that person would need either a Victorian licence held at some point since October 2016, or two full-time years as a representative since October 2016 of which one falls after October 2023, and the course would have to be among those the Regulations prescribe for that path. Whether a given certificate is on that list is a question the Regulations answer, not this example.

Companies and the officer in effective control

A company that trades as an estate agent needs its own licence. The company application page, updated on 30 June 2026, turns on one role: the officer in effective control.

According to Consumer Affairs Victoria, a company must have an officer in effective control who holds a current individual estate agent's licence in Victoria. That person must work at the company's principal office, be there regularly, and be fully accountable for the day-to-day operations of every office from which the company trades. Two further points are stated plainly: the officer in effective control does not need to be a director, and a company can appoint only one.

The effect is that a company licence never stands alone. Behind it there is always one named individual who met the personal tests described above, including the year of full-time experience, and who carries responsibility for all of the company's offices, not only the one where they sit.

The company is automatically ineligible if it is under external administration, if the company or any director is currently disqualified from holding an estate agent's licence or its equivalent, or if any director is a represented person under the Guardianship and Administration Act 1986.

Each director and the officer in effective control must supply a completed Consent to Nationally Coordinated Criminal History Check form and certified identity documents, at least one of them bearing a certified photograph. The pages read for this guide do not say what a company must do when its officer in effective control leaves; the fees page does list an application for short-term office management approval, used when an absence exceeds 30 days.

Applying through the Business Licensing Authority

Applications are decided by the Business Licensing Authority and lodged through myCAV, the online account system run by Consumer Affairs Victoria.

The identity step has two forms. An applicant can verify identity online. If that is not possible, the applicant sends certified copies of three identity documents, together with the signed consent form. In either case the Authority checks with the Australian Criminal Intelligence Commission, and the regulator notes that a dispute about the result of that check is taken up with the Commission.

Several deadlines apply while the application is open. If any information given in it changes, the applicant must tell the Authority in writing within 14 days. An application can be withdrawn in writing at any time before the Authority decides it, but the fee is not refunded. If the Authority refuses the application, it gives notice in writing, and the applicant can appeal to the Victorian Civil and Administrative Tribunal within 28 days.

Once granted, a licence is ongoing. Consumer Affairs Victoria states that it continues unless it is surrendered, suspended or cancelled, or the holder is disqualified. There is no renewal application in the usual sense. What keeps the licence alive from year to year is the annual statement.

What the fees are in 2026-27

The fees page of Consumer Affairs Victoria, last updated on 30 June 2026, gives the amounts for the 2026-27 financial year. All are exempt from GST, and application fees are payable at lodgement and non-refundable.

The per-director charge is what makes a company's costs move. A worked example, assuming a company with two directors and the 2026-27 amounts: the application costs A$479.90 plus two times A$327.10, which is A$654.20, for a total of A$1,134.10. Each year after that, the annual statement costs A$250.80 plus two times A$229.00, which is A$458.00, for a total of A$708.80. The officer in effective control holds an individual licence as well, so that person's own application fee of A$450.90 and annual fee of A$250.80 come on top if they are not already licensed.

A smaller group of fees applies to particular situations: A$48.20 for a branch manager's annual statement, A$104.30 for a copy of an extract from the register, and A$130.60 for a Registrar's certificate of the contents of the register.

One caution applies to every amount in this section. Consumer Affairs Victoria has announced that fee changes apply to licence transactions from 25 November 2026, under the Estate Agents (Fees) Amendment Regulations 2026. The pages read for this guide do not give the new amounts, so the figures above are those published for 2026-27 as at 30 June 2026.

The annual statement

Every licensed estate agent lodges an annual statement with the Business Licensing Authority and pays an annual licence fee. Both go through myCAV. Consumer Affairs Victoria ties the timing to the licence anniversary date: the statement and fee are due within the six weeks before that date, and the Authority notifies the licensee about six weeks ahead. A licensee who does not receive the notice is expected to tell the Authority, so a missing reminder does not move the deadline.

The consequence at the end of that sequence is automatic. The regulator's annual statement page says that if the Authority still has not received the statement and fee after 21 days, the licence is automatically cancelled. The same page describes a notice giving a final lodgement date, and says a failure to lodge by that date results in automatic cancellation.

A worked example of the cost of lateness, on 2026-27 amounts: an individual who lodges on time pays A$250.80. One who lodges after the late notice pays A$250.80 plus the late fee of A$112.60, a total of A$363.40. One who obtains an extension pays A$250.80 plus A$116.40, a total of A$367.20.

Extensions are for exceptional circumstances. They are granted on request, with the prescribed fee. On the window for asking, the two pages are worded differently: the fees page (June 2026) says the request is made within the six weeks before the anniversary date, while the annual statement page (February 2025) says within six weeks of it. Neither page describes what the statement itself must contain.

Becoming an agent's representative

The eligibility rules for representatives are set by section 16 of the Estate Agents Act 1980, according to the agents' representatives page of Consumer Affairs Victoria, updated on 11 August 2026. A representative must be at least 18 and must have completed a prescribed course. The other conditions are stated as things the person must not be: convicted or found guilty within the last 10 years of an offence involving fraud, dishonesty, drug trafficking or violence punishable by three months or more of imprisonment; insolvent under administration; the cause of a successful claim against the Victorian Property Fund or a corresponding fund; a represented person under the Guardianship and Administration Act 1986; subject to a declaration by the Victorian Civil and Administrative Tribunal making them ineligible; or subject to a disqualifying order from a regulatory body in or outside Victoria.

For a person entering the trade for the first time, the course is the Certificate IV in Real Estate Practice, CPP41419, with the same 18 units as for a licence, completed within the last five years. It must be delivered by a registered training organisation whose course is based on Victorian estate agency law.

Mutual recognition does not help here. Consumer Affairs Victoria states that it does not apply to salesperson registrations from other states or from New Zealand.

Under the rules in force until 24 November 2026, the checking is done by the employer. Before a representative starts, the employing agent must verify that the person is eligible, give them written authority to act, and notify the Authority through myCAV that they have started; the agent updates the record again when the employment ends. The regulator publishes an eligibility checklist for that purpose. The verification is repeated for each new engagement, so moving from one agency to another means being checked again.

The representative supplies two things: a Statement of Attainment for the prescribed course, and a police check obtained through Service Victoria. If the check is more than six months old, a statutory declaration is required with it. The page also requires a new police check within six weeks of starting work; a representative who does not provide it becomes ineligible to continue.

As with licences, the Authority may grant permission to a person who is insolvent, has caused a fund claim or has a disqualifying criminal record. A representative who becomes ineligible while employed can keep working while a decision is pending, provided they apply within 30 days.

What a representative may and may not do

The scope of a representative's work is defined by the written authority. With it, the regulator says, a representative can perform any function the employing agent can lawfully perform. Without it, the person is not acting as a representative at all.

The limits come from two pages. The agents' representatives page gives the general one: a representative cannot operate an estate agency business. The page on licence lending, which dates from February 2021, gives the specific ones. It describes licence lending as an offence committed when an estate agent allows or helps someone who does not hold a licence to use theirs to act as an estate agent, and it offers two examples. The first is a principal agent or officer in effective control who allows an agent's representative to manage a principal office or to supervise an agency business. The second is allowing a receptionist who is not an agent's representative to negotiate the sale or lease of a property.

The offence runs both ways. The regulator says an agent found guilty of licence lending may have their licence cancelled and may be disqualified, temporarily or permanently. It adds that it is also an offence for an unauthorised person to use an agent's licence, and for anyone to help them do so.

Registration from 25 November and CPD from 1 April 2027

Two pages of Consumer Affairs Victoria, updated on 28 May and 8 September 2026, describe changes that follow amendments to the Estate Agents Act 1980 and two sets of regulations made in 2026, one on education and one on fees. The regulator says two rounds of public consultation were held, in late 2025 and early 2026.

The first change concerns representatives and is scheduled for 25 November 2026. From that date a representative must hold a direct individual registration with the Business Licensing Authority. New representatives will register with the Authority and pay a fee. Those already in the trade are carried across: a representative who is employed by an estate agent and listed on the Authority's register on 24 November 2026 will be registered automatically, which the regulator calls deemed registration, and does not need to apply. The registration fee is not given on the pages read for this guide.

The second change concerns everyone and is scheduled for 1 April 2027. From that date, licensed estate agents must complete annual continuing professional development to keep their licence, and representatives must do the same to keep their registration. The September 2026 page states the quantity as at least five activities each year. The activities cover mandatory topics determined by the Authority, bearing on legal, ethical and professional knowledge, and they include written assessments.

The official wording counts activities, not hours. Neither page states a number of hours, the dates on which a professional development year begins and ends, who may deliver the activities or what follows if they are not completed, beyond the statement that they are required to maintain the licence or registration.

A Victorian licence has no expiry date, but from April 2027 it will have two yearly conditions: a statement and a set of assessed activities.

Unlicensed trading and false statements

Consumer Affairs Victoria states the core rule in the application pages themselves: a person or company must not operate as an estate agent until the Business Licensing Authority has granted the licence. Lodging an application, paying the fee or holding the qualification does not allow trading to begin. The same pages say that unlicensed trading carries significant fines, and that knowingly giving false or misleading information in an application is a serious offence, also with significant fines.

The amounts are not on the pages read for this guide. The regulator keeps them on a separate penalties page and in the Estate Agents Act 1980, and neither could be read during the research for this article, so no figure is given here. What can be said from the pages that were read is how the offences fit together: trading without a licence, lending a licence to someone who has none, and using or helping someone use another person's licence are each described as offences in their own right, and the second can cost the lender the licence itself.

Kooky, from Shaka

Kooky edits Agents Estate and builds Shaka, the payment router he made for real estate professionals. One payment comes in, and every agent, agency and party in the deal receives their signed share on closing date.

About Kooky and Shaka →