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  • Member account reporting and validation

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    Legislative context

    The provisions that outline superannuation member account reporting and tax file number (TFN) validation obligations are in:

    Section 390–5(1) of Schedule 1 to the TAA states a superannuation provider in relation to a superannuation plan must give the Commissioner a statement in relation to an individual if the individual held a superannuation interest in the plan at any time during the period specified in a determination under subsection (6).

    Holding a superannuation interest

    You will need to decide who holds a superannuation interest and ensure that reporting correctly deals with multiple superannuation interests.

    A superannuation interest means an interest in a superannuation fund, an approved deposit fund or a retirement savings account (RSA):

    • An interest refers to a distinct claim of any kind against a superannuation fund or RSA provider, whether it be proprietary in character or not.
    • Cash held in an account for the benefit of a member or investments held on their behalf clearly indicate a superannuation interest but so will less easily quantifiable entitlements such as life or disability insurance policies held in the name of the individual or entitlement to defined benefits.
    • Holding a superannuation interest includes but is not limited to
      • non-member spouse accounts
      • new member registration or first contribution in relation to the Superannuation data and payment regulations and standards
      • having no account with the superannuation fund but have some other interest such as an insurance interest, a defined benefit interest or an annuity.
       

    Reporting under Section 390-5 of schedule 1 to the TAA

    Legislative Instrument ID F2018L00467, effective from 1 April 2018, requires every superannuation provider in relation to a superannuation plan to report all member account phases and attributes including new accounts, updates and closures in relation to a members account using the member account attribute service (MAAS). This replaces Legislative Instrument ID F2017L00142, which required mandatory reporting using SuperTICK.

    See also:

    The MAAS form is to be submitted no later than five business days after the day on which a new member account is opened, updated or closed or such later date as the Commissioner may allow.

    If you receive a technical receipt from the MAAS you have discharged your obligation to call the service and the next actions are dependent on the type of response you receive.

    Once you have started using the MAAS, you will continue to use the MAAS for reporting new/updated/closed member accounts.

    Minimum message requirements for TFN validations

    The Commissioner may give you a TFN validation notice under section 299TD of the SISA or section 143D of the RSAA if you give the Commissioner information you believe to be either the:

    • full name, TFN and date of birth of a person
    • full name, TFN and date of birth and address of a person.

    Although our systems may accept a message with a reduced data set, section 299TD of the SISA or section 143D of the RSAA provides the legal requirements to receive a TFN validation notice from the Commissioner.

    You can use the MAAS or SuperTICK for TFN validation as the legal requirements of the message are the same in both services.

    When you receive a technical receipt through the MAAS or a GEN.OK response through SuperTICK you have discharged your obligation to call the service.

    Reporting open accounts

    When you notify us of newly opened accounts through the MAAS all of the mandatory account attributes are required to be reported. The mandatory account attributes are:

    • unique superannuation identifier (USI)
    • member account identifier
    • account phase
    • account status
    • contributions accepted
    • inward rollovers requests accepted
    • member outward rollover requests accepted
    • government rollovers accepted
    • defined benefit interest
    • insurance
    • grandfathering
    • innovative income stream product.

    Matching responses

    When you submit a MAAS form you will received a response from the MAAS:

    Matched response

    A 'matched' response confirms the TFN data you hold is correct and is a notice under section 299TD of SISA or section 143D of the RSAA, provided the minimum requirements are met.

    The Commissioner may give you a TFN validation notice under section 299TD of the SISA or section 143D of the RSAA if you give the Commissioner information you believe to be either the:

    • full name, TFN and date of birth of a person
    • full name, TFN and date of birth and address of a person.

    Although our systems may accept a message with a reduced data set, section 299TD of the SISA or section 143D of the RSAA provides the legal requirements for a TFN validation message to receive a valid section 299TD or 143D notice from the Commissioner.

    Matched and corrected response

    If you provide a TFN in the MAAS, and the response is a corrected TFN, this is a notice under section 299TA of the SISA or section 143A of the RSAA.

    If a corrected TFN is included in the response, privacy regulations do not permit you to provide the TFN to an employer.

    If a TFN is not supplied in the MAAS and a TFN is returned, it is a notice under section 299TC of SISA or section 143C of the RSAA, meaning the member has provided this TFN for superannuation purposes previously.

    Update your records to delete the incorrect TFN and record the correct number. Penalties may apply if you continue to use the incorrect TFN.

    Unmatched

    A response of ‘unmatched’ means we were unable to match the member details provided to our records with an appropriate level of confidence.

    We may have been unable to match the member details for the following reasons:

    • Your member has provided you with incorrect details.
    • The records we hold are incorrect.
    • The TFN has a compromised or duplicate status on our systems.
    • Our data matching system cannot establish a single match.

    While an unmatched response from the MAAS is not always a 'Please resolve' notice, you have not met the requirement to report an open account to us if you are holding an unmatched response.

    When a MAAS open account is not properly matched to a member in the ATO client register, subsequent member account transaction service (MATS) interactions will fail to be matched to the member.

    We strongly encourage you to take reasonable steps to verify the member information you hold and re-submit the open account. What is reasonable depends on the specifics of each case and how likely your efforts would be to achieve a result.

    For example:

    • if the account has been created by an employer then we recommend you contact the employer in the first instance
    • if the member has a financial advisor, we recommend you contact the financial advisor
    • if you are unable to confirm details through and employer or financial advisor, we recommend you contact the member directly.

    Reporting account changes

    Whenever there is a change to the account phases and/or attributes relating to a superannuation account, you must notify us within five business days or such later date as the Commissioner may allow.

    All of the mandatory member account attributes required to report an open account are also required to be reported in an update message, not just the attribute which is being changed.

    Refer to the MAAS business implementation guide for message requirements relating to changes and updates to TFNs.

    See also:

    You must report any member account changes through the MAAS once you have started to use the service:

    Member detail update is required

    If you receive a request from a member to update their family name, check the member's record. If the last update sent to us was returned an unmatched response, it may be possible that the difference in family name may be the cause.

    Report the updated member family name along with all the other attributes of the account. Our systems will then return a matched response and cancel the previous unmatched form.

    Member detail update is not required

    If a member tells you that they have changed their name, address and marital status, but you are not holding any unmatched responses for the member:

    • update your own systems with the new information
    • report the new details to us when you have another update to report for the member
    • advise the member to ensure they update their details directly with us so that any future reporting to us is properly matched to their records.

    Changes due to an auto reversionary pension

    If you are notified of the death of a member and the superannuation income stream automatically transfers to the beneficiary (an auto reversionary pension):

    • this is a legitimate change of member and the account identifiers don’t change
    • you need to close the deceased member's account and open a new account in the new member's name.

    When you report the open account for the new member, an error may be returned. In these instances you will need to contact SuperCRT@ato.gov.au to process the new account.

    Change of USI or member account identifier number

    If the USI or member account identifier number (member account number) changes for a member account, you should submit a:

    • 'close account' request, quoting the old USI/member account identifier number (member account number)
    • separate 'new account' request for the new account (identified by the unique combination of the USI and the new member account identifier).

    Rollovers

    You must ask the Commissioner for a TFN validation notice when you receive a request to rollover an account to another provider (except a self-managed superannuation fund), unless:

    • you do not hold the member's TFN
    • the rollover request was sent by us
    • you have previously received a successful matched response from the service.

    If you receive an unmatched response from us you may ask the member for proof of identity information that you reasonably need to process the request. You can use information in the form in Schedule 2B to the SISR to ask the member for proof of identity details in accordance with regulation 6.33D of the SISR or regulation 4.35G of the RSAR.

    Reporting closed accounts

    There are specific member account attributes to be reported when an account is closed. You don't have to update account attributes such as 'Contributions accepted – none' or 'Rollovers accepted – none' to reflect the closed nature of the account.

    When unnecessary attributes are reported, our systems will not use the account attributes for a closed account.

    The mandatory attributes to be reported when an account is closed are:

    • USI
    • member account identifier
    • account phase
    • account status

    Reporting closed accounts removes the account from ATO online, where a 'matched' response has been received.

    If an ‘unmatched’ response is received it will remain as a viewable account online until a successful closed account request is sent.

    Only report a closed account once:

    • all closure processes have been completed
    • money has been rolled out or paid out
    • no interest is remaining
    • it is not possible to receive further contributions.

    When the account closure is complete, notification of the closed account through the MAAS should be submitted within five business days, or such later date as the Commissioner may allow.

    See also:

    Last modified: 25 May 2018QC 55581