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  • Implementing super reforms – from then to now

    Presentation to the Association of Superannuation Funds of Australia (ASFA) 2019 National Conference

    National Risk and Compliance Discussion Group - Regulator’s Panel
    14 November 2019
    James O’Halloran, Deputy Commissioner, Superannuation and Employer Obligations, ATO
    (Full speech transcript - check against delivery)


    Thank you for the opportunity today to join you at your annual conference. It’s a pleasure to be part of the Regulators Panel session, with Suzanne Smith from the Australian Prudential Regulation Authority (APRA) and Danielle Press from the Australian Securities and Investments Commission (ASIC).

    At last year’s ASFA conference, I highlighted the importance of ongoing collaboration with industry in order for us all to best manage change in any period of reform.

    This time last year, we’d just completed a challenging year on a range of fronts, taking us all in new directions. Indeed, at the ATO we were just bedding down new reforms and working with you on the operational and interpretative impacts for fund members and what action we needed to take together to support them.

    As you’ll recall, ahead of us last November was more change, including working with you to implement event-based reporting and preparing for the individual and industry circumstances that would play out, more broadly in the 2018-19 financial year.

    Of course there were some emerging views arising from reviews into the superannuation system that many needed to consider and work through.

    Our goal then was to continue to find ways to genuinely work with you, to ensure the operational aspects of super were in place and on solid foundations.

    Through this prism and in these changing times, we also wanted to ensure that within the new policy settings, the level of trust in the super system remained central. Such a goal I believe remains as relevant now as it was then.

    I base this on a belief that we all strive, within our own areas of influence, to find ways to continue to promote and demonstrate trust and confidence in what we do; how we do it and why the things we do add value.

    In recent years, we’ve all sought to ensure that the implications and longer term impacts of super reform were understood by individuals, funds and your fund members. This was especially so in terms of identifying emerging unanticipated or unintended consequences, given that the new reforms were now well and truly ‘live’.

    Environment over the past year

    Perhaps the most visible change to date is that we now have a super system which encourages members and even demands them to have an ongoing appreciation of their super account attributes and balances.

    The need for such active management has intensified, whether your member are in accumulation phase or pension phase.

    In our role as a regulator and administrator across the tax and super system, we oversee a system in which the community has confidence. We seek to administer so individuals can participate confidently in their affairs and make judgments according to their personal circumstances.

    For this reason we seek to focus on, and improve, the client experience. We want to share any early insights or areas of emerging concern to prevent non-compliance or regulatory breaches.

    Pleasingly, with an eye on the future and being able to leverage the implementation needs which arose from recent reforms, we now have a more transparent super system. Importantly, with your assistance we were able to deliver on the many outcomes legislated or required by government.

    Of particular importance now is how agile or adaptive we all are for the future requirements of the super system.

    Throughout the implementation journey, there has been the need to understand many new concepts and to change some expectations around super. These matters were not without difficulty, but like many of you, we were charged with turning concepts into reality; and together we did.

    In many ways, we increasingly share the stewardship of a super system which is transparent and dynamic. At least operationally, we have a super system which is now built around a member’s account balance and attributes, and a system which demands that members have a ‘line of sight’ of their total super portfolio.

    I would like to pause for a moment to examine what has been implemented and what is now in place and operating as intended. Indeed in many ways we are now in a business-as-usual environment.

    At one level, super has many interdependencies and considerations. So there can be a tendency by us all at times, to focus on ‘everything’ and yet not necessarily focus on the ‘right things’.

    While it may seem obvious, super could be seen as being built on:

    • effective and responsive administration and management
    • a mandatory (essentially) payment of super guarantee by employers
    • how and where super is held or how it is lawfully accessed.

    Effective and responsive administration and management

    We all quickly started to be very familiar with the implications and nuisances of terms such as ‘total super balance’; ‘transfer balance cap’; ‘carry forward concessional contributions’; and ‘capped defined benefit income stream’ to name a few.

    Total super balance and transfer balance cap

    The total super balance was introduced as a means for assessing eligibility for individuals making non-concessional contributions and determining whether an individual is eligible to access the carry forward concessional contributions rules. From our perspective this is now operating as intended.

    It wouldn’t be possible to reflect on recent super reforms without recognising the transfer balance cap introduced on 1 July 2017. As you’re aware, this placed a limit on the amount that can be transferred to the tax-free earnings retirement phase of super.

    Implementation of this measure has resulted in 1.7 million individuals in retirement phase having a transfer balance account since 1 July 2017. Of these individuals, approximately 5,000 have exceeded their transfer balance cap and received an excess transfer balance tax assessment from us.

    Further, some 6,000 individuals have had the taxation of the income from their capped defined benefit income streams changed.

    To support these changes in the way these capped defined benefit income streams were taxed, an individual amended their withholding arrangements and we changed the personal income tax experience for individuals with income from these income streams.

    We did this by adding a new label, label 7M, to the income tax return and embedding a new tool in myTax. This gave self-preparers a two-click solution to determine their defined benefit income cap, the amount of any income to include at the new label, and the amount of tax offset they could claim at T2. This was also available as a stand-alone tool.

    While the number of people directly affected by these changes has been very small, the changes did put a focus on the retirement phase of super, which had not been present or perhaps previously required.

    From our perspective, to help individuals take advantage of the new opportunity to roll-over their death-benefit income streams, we worked together to design the interim fund-to-fund rollover reporting to ensure the receiving fund had the necessary information to keep paying a death-benefit income stream.

    Overall, the introduction of the transfer balance cap transformed the information funds report to us and the type of information that needed to be monitored and more readily available. This remains an important ‘step change’ for the administration of super for us all and are foundational platforms to bring greater ongoing assurance across the super system.

    In any event, we are now in a business as usual environment whereby APRA funds routinely report retirement-phase events to us through the ATO member account transaction service (MATS). Indeed across the broader super system, many SMSFs also now report transfer balance account information to us at least quarterly on an events basis.

    In addition, the reporting built off the needs of the reforms, has enabled us to provide tangible assistance to individuals and their agents who now have access to current super information for their clients.

    We generally examine and use and share the transfer balance account information you report to us within 24 hours. In some ways this has contributed to an increase in community awareness of the importance of super for their future and their investment decisions.

    Concessional and non-concessional caps

    The government policy was to better target tax concessions to ensure the super system is equitable and sustainable, by better targeting tax concessions to those who most need them to save for retirement.

    To do this, the annual concessional contributions cap was lowered to $25,000 for individuals.

    From this, the ATO issued some 171,000 determinations in 2018-19 to individuals affected by the lower cap.

    The annual non-concessional contributions cap was lowered to $100,000 and further reduced to nil for individuals that have a total super balance of $1.6 million or more. In doing so, this targeted the ability to make these contributions to those individuals seeking to bring their superannuation savings up to the transfer balance cap.

    From this 21,000 determinations in 2018-19 were issued by the ATO to individuals affected by the lower cap.

    Overall the implementation of the cap changes has resulted in approximately 192,000 determinations issued by us in the 2018-19 financial year due to the reduction in caps. Thus ensuring that the tax concessions are targeted as was intended by the government.

    Carry-forward concessional contributions

    Government policy also sought to allow people to carry forward their contributions; the intent being to give individuals with unused concessional cap amounts the opportunity to ‘catch-up’ if they met the eligibility requirements and had the capacity to do so.

    We expect about 230,000 people, including those with interrupted work patterns, will use this flexibility to make additional super contributions in the 2019-20 financial year.

    Division 293 threshold change

    Another reform was the threshold reduction from $300,000 to $250,000 for the Division 293 tax which increased the impacted population.

    In January 2019, we released a redesigned ATO Division 293 Notice, which made it easier for clients to understand what it is and what they need to do. With the process on how money was released from super to pay Division 293 tax also changing last financial year, we’re taking on board feedback we’ve received to continually improve the individual and industry experience.

    You may be aware that industry receives about 100,000 release authorities for Division 293 tax each year. Work to move the release authority into the SuperStream rollover will alleviate significant workloads for industry and the ATO in this space.

    Mandatory payment of super guarantee by employers

    At the core of the super system is the (essentially) mandatory payment by employers to employees (via a complying super fund or retirement savings account) of the super guarantee (SG) contribution. In 2017–18, there were about 935,000 employers and 12.4 million employees in Australia.

    We have an ATO tax gap program which is designed to measure a range of tax gaps. The SG gap is an estimate of the difference between the value of theoretical SG contributions required to be paid and actual SG contributions. We recently estimated the SG net gap to be $2.3 billion (3.9%).

    The value of estimating the SG gap is in monitoring trends and developing insights over time. When comparing the estimate for 2011–12 and 2016–17 the net gap indicates a declining trend during the five-year period, falling from 6.5% in 2012 to 3.9% in 2017.

    From 1 July 2010 to 30 June 2018, as a result of our compliance activities, we’ve transferred over $2.6 billion to employees’ super funds on behalf of 1.8 million employees.

    With increasing awareness in the community of non-payment of SG, it’s pleasing that the changed reporting arrangements we’ve all been working on since 2017 are bringing a greater ability for the ATO to track late or non-payment of SG.

    We’ve also recently completed an examination of SG contributions of some 75 million payment transactions for quarters one, two and three of 2018–19 for some 400,000 employers.

    We’re currently examining the payment transactions and patterns for quarter four of 2018–19 and will shortly start examining quarter one data for 2019-20. As you would know, this was only an aspiration a few years ago.

    Last month, we began contacting 2,500 employers we’ve identified as having paid some or all of their SG contributions late during 2018–19. We also sent due-date reminders to a further 4,000 employers ahead of the 28 October SG due date.

    This is the first direct use of the Single Touch Payroll reporting arrangements combined with what your funds report to us relating to employer SG payments via the Member Account Transaction Service (MATS). It’s a tangible action which demonstrates our increasing ability to effectively follow up in relative real time apparent late or non-payment of SG.

    Of course, our comprehensive SG audit work continues to be resourced. During 2018–19 we completed 27,000 SG cases. From this casework we contacted 22,000 employers and raised assessments for $805 million in outstanding SG.

    As importantly, as a result of our compliance activities, we collected $532 million in outstanding SG and distributed it to 471,000 individuals during 2018–19.

    But of course education is at the heart of any long term success or behavioural change. Earlier in the year we released a new online SG education course to help employers better understand their super obligations.

    It was developed in conjunction with the legislative authority for the ATO to be able to direct and require employers, who are identified as not paying the correct amount of SG, to be required to undertake SG education.

    Although we developed the package to use with the directions power, we’re also encouraging employers to complete this course voluntarily; but where we see that employers aren’t clear about their SG obligations and need a better understanding, we will direct them to complete the course.

    The course takes about two hours to complete and it’s free. There’s also an assessment. Once an employer has successfully completed the assessment (achieved 80% or higher) they will receive a certificate of completion and a copy will be sent to the ATO automatically.

    We continue to receive positive feedback on this course, both from employers directed to do it and those completing it voluntarily.

    SG Amnesty (proposed)

    Of course, closely connected to the SG landscape is the recent government announcement of the proposed SG amnesty. It’s proceeding through parliament and we are ready to administer any final law once passed by the parliament.

    The current bill proposes employers will have until 6 months after Royal Assent to make their disclosure for the historic SG non-payment for quarters from 24 May 2018 back to 1992.

    Therefore, under the proposed law as it currently stands, non-payment for quarters starting from1 April 2018 and beyond will not be eligible for the amnesty.

    An employer won’t be considered eligible for the amnesty if we’ve already informed them that we have commenced a review or audit action. I take this opportunity to remind you that even if there is a change of law to introduce an SG amnesty, we will continue to conduct reviews and audits and apply penalties.

    We’ll also continue to process disclosures made by employers through the lodgment of Super Guarantee Charge forms, in accordance with current law.

    How and where super is held or accessed

    Of course, an immediate focus is our role in the inactive low-balance account (ILBA) reporting aspects of the Protecting Your Super measure and the proactive reuniting by us of super accounts and balances.

    We’ve consulted widely, collaborating with the super industry to develop implementation and guidance material, to ensure super providers can meet their reporting and payment obligations.

    I can advise that the proactive reuniting of accounts and balances has started. To date, we’ve received over 2.3 million inactive low balance account lodgments valued at approximately $2.16 billion and expect to reunite a large proportion of these to an eligible active super account.

    We started our proactive reunification process on 1 November 2019 with 100,000 accounts being rolled over into individuals’ active accounts held by a super provider on their behalf. This process will steadily increase throughout November and will continue into the future.

    (Postscript: Latest available figures at time of publishing show that as at 13 November 2019, we have reunited just over 841,000 accounts worth nearly $1.38 billion. This includes approximately 684,000 accounts worth $1.22 billion that have been transferred into an individual’s active super account and approximately 157,000 accounts worth $161 million directly to individuals’ bank accounts.)

    Where we have reunited members with their super, we’ll notify them via our various communication channels, once we can confirm the fund has accepted their super payment.

    We see this new power to proactively reunite as an important one as we seek to improve people’s retirement savings outcome.

    We also remain committed to helping people engage with their super as well as to assist when it is lawful to release super to individuals before their retirement. To this end we’ve facilitated access for people to their super through a range of government super release and contribution schemes that we administer.

    The First Home Super Saver (FHSS) scheme, in its first 15 months of operation, released over $62 million, to help more than 5,000 individuals buy their first home. Compared with the same period last year (up to 30 September) we’ve seen a 77% increase in the number of people using the FHSS scheme.

    The Downsizer measure has resulted in some 7,400 individuals across every state and territory making super contributions to the value of $1.7 billion. The measure is operating effectively. We would like to take the opportunity to thank industry for their cooperation and assistance in co-designing and user testing the ATO online portal for Downsizer reporting.

    Since 1 July 2018, the compassionate release of super program has assisted some 40,000 people access $600 million to deal with the cost of complex life situations they can’t fund from other sources. This can include expenses due to life threatening or chronic medical conditions, accommodating a severe disability, palliative care, costs associated with the passing of a dependant and preventing foreclosure on their home.

    Consolidating multiple accounts, lost and unclaimed super

    We’ll launch our annual postcode ‘lost super’ campaign in the week beginning 18 November. These campaigns help considerably to raise community awareness of lost super.

    As result of our 2018 postcode campaign, use of ATO online increased as more than 66,000 people used the system to find and consolidate over 105,000 accounts worth over $860 million.

    We’ve also maintained our focus on helping people engage with their super. Naturally, I appreciate the ongoing support and insights that ASFA and its members have provided to the ATO.

    We don’t seek to tell people how to manage their individual super portfolio but we do want to contribute to their ability to make informed decisions that will enable them to reunite or consolidate their super.

    Between 1 July 2013 and 30 June 2018, the number of individuals with two or more super accounts (not including SMSFs) decreased by 16%. Currently, 5.8 million individuals (representing 36% of all individuals) have two or more super accounts.

    Pleasingly, over the past five financial years (1 July 2014 to 30 June 2019), some 2.6 million accounts to the value of $15 billion have been consolidated by fund members using ATO online services. This includes some 540,000 accounts to the value $4.4 billion that were consolidated between 1 July 2018 and 30 June 2019.

    We continue to use a broad range of communication and marketing campaigns to reconnect individuals with their lost and unclaimed super.

    So what builds success

    Success in any endeavour depends on dialogue, appreciation of perspective and at times, to some extent, compromise.

    It was from an agreement between industry and the ATO to move to a contemporary reporting framework that laid today’s foundation to administer new policy changes and directions.

    The basis of the original agreement with industry in 2017 was due to our shared recognition of the emerging reality for more transparency and real reporting into the future. This arose from observations by us, industry experiences from SuperStream, the emerging picture across pending reforms, and the announcement of Single Touch Payroll.

    It was clear that to transform from the existing annual reporting regime based essentially on annual member contribution statements was not sustainable as we needed more frequent and more granular transactional insights both for the ATO and to fund members.

    It was felt that such a change would assist the growing desire for more timely visibility of an individual’s super position and to support streamlining reporting for funds. It was also believed that it would position to respond more easily to new policy developments and provide visibility of SG contributions actually being paid. Working with industry to implement these reforms has led to us achieving all the intended outcomes.

    In the first year of such changed reporting, we received over 200 million reports, most within five or 10 business days of an event or transaction occurring. The information reported an individual’s accounts and their employer contributions and these are now visible to the individual in ATO online within one to three days of the information being reported.

    Of course, the other significant change that has helped with more timely visibility of an individual’s super position has been the introduction of Single Touch Payroll (STP). The intent behind STP is to streamline business reporting obligations and ensure employers are reporting and paying their employees’ super entitlements.

    STP leverages existing business processes (processing payroll) to report employees’ tax and super information to us at the time they’re paid.

    We use the information reported through STP to remove the obligation to provide payment summaries to employees and to potentially pre-fill withholding labels on business activity statements.

    Today, over 540,000 employers covering some 11.3 million individuals are now reported through STP every time they pay their employees. With STP becoming mandatory for all small employers from 1 July 2019 we continue to make a concerted effort to work with small employers to understand any barriers they may be facing and provide support to help them transition to STP reporting.

    From changes introduced over the past 12 months through APRA fund event-based reporting and STP reporting we have seen an unprecedented level of business transaction flow through our systems. This is giving us all new or improved insights into behaviour.

    To give you some sense of scale, our total transaction numbers across both STP and super services jumped from about 16 million in 2017 to over 550 million in 2019 (to date).

    Through the implementation of STP we (and individuals through myGov) are now seeing near real time information regarding super entitlements. We are now able to see employer’s behaviour regarding their super guarantee payment obligations. Such visibility is what many across the super industry have hoped for over many years. The ATO is now well into drawing from this new capability.

    The modernisation journey continues

    Streamlining release authority arrangements

    In the 2018-19 financial year we issued 79,060 Division 293 notices and 15,126 excess concessional contributions and 978 non-concessional contribution elections were submitted via ATO online. This resulted in just over 95,000 release authorities being sent to super funds.

    With the focus on technology and client service, we’ve sought to enhance the client experience when dealing with us in relation to super. We‘ve done this in recent years by aligning the election and release authority process across the super caps space.

    We’re now building functionality to include electronic release authorities into the SuperStream standard. This will allow us to send electronic requests to super funds for the release of super, further reducing administrative costs.

    APRA fund rollovers to SMSFs

    We continue to work with industry to implement one of the last pieces of the original SuperStream program to allow rollovers from APRA funds to SMSFs; starting from March 2021.

    To this end, we will shortly be releasing the final build specifications for the changes to the SuperStream rollover message and for two new services that will support SMSF rollovers, for the March 2021 start date.

    Collectively, between SMSF rollovers and electronic release authorities we will streamline and digitise hundreds of thousands more transactions, gaining further efficiencies.

    AUSKEY transition and the introduction of MyGovID

    Our teams have also been supporting industry with information, guidance and direction in relation to decommissioning the current AUSkey credential and the transition to MyGovID and Relationship Authorisation Management (RAM) identity credential. 

    AUSkey will be decommissioned and replaced in March 2020 to tighten our security and strengthen our processes to safeguard and protect member data. The transition to the new digital identity solution, myGovID and RAM is underway.

    myGovID is a way to authenticate and access online services using an app. RAM is a whole-of-government relationship and authorisation manager that enables you to control who can act on behalf of your business across eligible government services.

    Trustees may recall a letter that issued in September noting these changes and early action that could be taken by organisations to prepare.

    The new products will not impact the core functionality of current superannuation services or your established business appointments in Access Manager. They will enable you to prove who you are digitally and will also help you manage who can act for you or your business when accessing government online services.

    Looking ahead

    Transfer balance cap indexation

    While we’re now all well in tune with the concept of a $1.6 million transfer balance cap, we’re looking ahead to the potential indexation of the general transfer balance cap depending on the December CPI rate.

    This may occur as soon as July 2020, as required under the Section 960 – 285 Income Tax Assessment Act 1997), although it may be 1 July 2021. We will not know until the release of the December 2019 quarterly CPI.

    When indexation is triggered, those 1.7 million individuals with a transfer balance account won’t have a single transfer balance cap of $1.6 million, but a personal transfer balance cap of between $1.6 and $1.7 million depending on their personal circumstances.

    I mention this now to merely advise you to the possibility of the change and assure you that we’re preparing to make this adjustment. There will no doubt be impacts you may want to consider for your members and possible changes to your withholding arrangements to consider.

    We will advise you if indexation will apply on 1 July 2020 as soon as possible after the December quarter CPI figure is released at the end of January 2020.

    Ongoing monitoring of fund reporting

    After our foundational year of event-based reporting, culminating with the reporting of 27 million 30 June 2019 account balances by the 31 October 2019 due date, we’ve progressed our data monitoring and assurance activities.

    With all funds on-boarded and operating in the event-based reporting framework, we need to be vigilant as to the timeliness and accuracy of the information. Given the downstream impact it has for each individual member, whether that be in relation to the caps, total super balance, transfer balance cap, visibility and understanding of their super position and ability to consolidate accounts or have ATO held super amounts proactively consolidated to them it is important to get it right from the start.

    While we anticipated that timeliness and completeness of data would not be at ideal levels during a first year recognising transitional arrangements and a highly orchestrated on-boarding exercise, we are now starting to see these qualities normalise.

    For example, the completeness of the employer ABN field in an employer contribution report is essential to our ability to monitor SG compliance. During the 2018-19 year, 80% of 162 million employer contribution reports had an ABN in the employer ABN field. Pleasingly, quarter 1 of the 2019-20 year saw this improve to 94% of the 44 million employer contribution reports submitted with a completed employer ABN field.

    Timeliness of transaction reporting is also a benefit of the changes that have been made and a significant part of our SG compliance monitoring. For the 2018-19 year, 73% of employer contribution transactions required to be reported within 10 business days was reported on time. Again, pleasingly, we’ve seen this increase to 95% for the first quarter this financial year.

    This has normalised to this extent from a combination of both the assurance work and engagement our teams have had with funds and administrators. But, as I said, we need to continue to monitor reporting performance to continue to reap the benefit of this shared investment.

    New large fund reporting performance report

    We’ve also just established an industry and ATO co-design group that’s focused on developing a new member reporting performance extract that will provide more timely periodic insight into a fund’s reporting performance.

    Funds may be familiar with the Risk Differentiation Framework (RDF) or large fund diagnostic report - an annual assessment of fund reporting against benchmarks of previous reporting requirements.

    While the RDF report provided great insights, improved reporting performance and facilitated good engagement between funds and the ATO, it is no longer fit-for-purpose in the new operating environment.

    We’re looking forward to working with an industry co-design group to develop and then deploy a new performance report early in the new calendar year. 

    Large fund income tax engagement

    Of course, we also administer the income tax system and engage with large super funds to support funds to meet their own income tax obligations.

    Of note over the past 12 months, we’ve been engaging with some of Australia’s largest taxpayers through the Justified Trust program to build trust and confidence in our taxation and super systems. This includes engagement with large APRA-regulated super funds, initially in the Top 100 population and since February 2019, this has been extended to large super funds in the Top 1000 population.

    We expect to review about 80 funds through this program, with 35 reviews already finalised and a further 28 in progress and 17 to commence in the new year.

    Through this program, we adopt an assurance-based approach and seek objective evidence to conclude that funds are paying the right amount of tax. Our engagements are designed to obtain a holistic understanding of the super fund and its business. It also requires a higher level of assurance than only confirming that a certain risk doesn’t arise.

    We engage with each fund through streamlined assurance reviews (reviews) that cover the past four income tax years. We’ve tailored our approach with regard to the unique business profile of large super funds and their reliance on automated systems and third-party service providers.

    From the reviews completed to date, most funds are achieving an overall medium assurance rating. Areas with higher assurance ratings include assessable employer contributions, assessable personal contributions and exempt current pension income.

    Areas where we’ve identified concerns or specific tax risks typically involve more complex investment structures and offshore investments.

    The outcomes of these reviews will help inform our engagement with funds over the next 12 months and will include working collaboratively with industry on areas such as tax governance to obtain higher levels of assurance and engaging with funds on aspects where we’ve identified concerns or specific tax risks.


    We’re pleased to have played a significant role in recent years, working with you to transform the super system and its daily operation.

    From this effort, it’s no longer a system which is ‘set and forget’ nor is it one that essentially is only visible at the end of a financial year.

    We appreciate the importance for all of us to have worked together to develop a clear implementation program. Such a program also had to recognise in its approach the need for transitional arrangements and to design and build infrastructure for the future; it was not just a case of replacing what we had before.

    Implementation of reform must not only be ‘fit for purpose’ but also ‘fit for the future’; for an environment adaptable to future needs.

    As can be seen perhaps from my observations today, there is never just one reform to deal with at a time. Major reforms programs come in ‘packages’ with many layers and many players.

    Packages often have elements of new frameworks with new objectives or emphasis, and of course with changed obligations. Unfortunately they also often have limited lead times to build systems and procedures.

    In many ways, the investment in event-based reporting and the desire for agile design - evident through the tranche of reforms since 2016 - has laid the foundation for greater trust and transparency in super and how it operates.

    Over time there is often an overlap or convergence of multiple reform packages. A live example now is the current intersection across super arising through the Single Touch Payroll program and the resultant transformation of pay-day reporting coupled with the allied changes to SG reporting. All these reforms have taught us all a lot but the main feature is be open and ready for the reality of agreed or directed change.

    Through these programs we’ve learnt a lot about your industry and the needs of members. We’ve learnt the importance of collaboration, co design, how to best manage change and resolve complex problems.

    As I believe we achieved with industry, what does have to happen during the implementation of major reform is to find a common purpose or goal.

    Thank you.

    Last modified: 15 Nov 2019QC 60623