“A lot of these clients had many millions of dollars in assets and in super funds and they don’t necessarily need the same protections as people receiving advice on early release of advice [for example],” said Ms Bowler.

“I think the whole definition of wholesale clients, which I don’t think has been updated for 20 years probably needs to be looked at and whether there’s a better framework for advising high-net worth clients.”

Following a raft a regulatory changes including the FSAEA requirements, Ms Bowler said she expects the downward trend with licensing among accountants will continue.

“[During the COVID-19 period] accountants have never been turned to more for advice. It’s such a shame we can’t get a framework to make to make licensing work to allow accountants to give strategic advice,” she said.

BT head of financial literacy and advocacy Bryan Ashenden previously warned that FASEA’s updated guide on its Code of Ethics may place increased scrutiny on advisers that classify their clients as wholesale clients.

“Where the guide discusses standard 1, it talks about advisers taking on personal responsibility to understand their legal obligations and ensuring that the advice provided [is in line with] the intent of financial services law,” Mr Ashenden said.

“What it is calling out in particular is that advisers don’t try and circumvent certain disclosures and consumer protections that consumers are entitled to receive.”

Stating that an individual qualifies as a wholesale accountant simply because an accountant certificate exists could be an example of this, he said.

“You need to be thinking about this from a standard 1 perspective. Is it appropriate to classify that client as wholesale or should they remain as a retail client irrespective of how much money they have or what their wealth position is?” he cautioned.