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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:

    Subsection 390–5(1) of Schedule 1 to the TAA states a superannuation provider in relation to a superannuation plan must give the Commissioner of Taxation (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 is an interest in either:

    • a superannuation fund
    • an approved deposit fund
    • 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. As a general rule, a superannuation provider's capital is most commonly increased via receipt of a contribution for a member.

    Less easily quantifiable entitlements for example are 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 (excluding self-managed superannuation funds (SMSFS)) 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 a member account is opened, updated or closed or such later date as the Commissioner may allow.

    When you have transmitted the MAAS form within the time frame specified above and we have responded with a technical receipt, you have given the statement to the Commissioner and discharged your obligation to lodge that form.

    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. Regardless of the service used, for the purposes of TFN validation, the trustee must make the request no later than three business days after receiving the information.

    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 determine that an individual holds a superannuation interest you must notify us via the MAAS no later than five business days after the day the account is opened (or such later date as the Commissioner may allow). For example, generally we consider that the individual holds a superannuation interest at the time the contribution is received, and sufficient details are known to identify the member, even if you have not yet allocated the money to a member account .

    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.

    Example 1:

    A super fund receives a contribution for a new member, Brad, from an employer on 1 May 2019. Along with the contribution, the employer provided Brad's:

    • first and last name
    • year of birth.

    As the super fund held incomplete contribution information, it was unable to determine who the superannuation interest belonged to at the date it received the contribution.

    The super fund successfully contacted the employer and obtained complete contribution information on 10 May 2019.

    The fund determined that the account was opened on the 10 May 2019 and reported this in the account status field in the MAAS form.

    End of example

    See also:

    • TR 2010/1: Income tax: superannuation contributions

    A MAAS message is required when you determine that the member holds an interest in the fund even when that interest is held for a minimal period.

    Where you have accounts that open and close on the same day, or you need to pay out member benefits that day, you are still required to report a MAAS for that account. This includes for when the MAAS message you submit is to report the account as closed (only requiring the four mandatory fields to be completed).

    Example 2:

    Sally opens an accumulation account and receives a contribution. On the same day, she chooses to:

    • rollover all the benefits from this account into a pension account
    • close the accumulation account.

    At minimum, a MAAS is required to be lodged with a closed status to report the accumulation account into which the contribution was received.

    A MAAS is also required to be lodged for the pension account being opened (unless this is a pre-existing account).

    End of example

    Reporting account changes

    Whenever there is a change to the account 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:

    Where you are provided with updated personal details (name, date of birth, address) follow the applicable guidance as follows:

    Member detail update is required

    If you receive a request from a member to update their family name and you are holding an unmatched reponse, 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. When we are able to match your member with the updated family name, 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 or address and you are holding a matched response for the member:

    • update your own systems with the new information
    • report the new details to us when you have an account attribute 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 a reversionary income stream

    A superannuation income stream stops as soon as a member in receipt of the superannuation income stream dies. This is the case unless a dependant beneficiary of the deceased member is automatically entitled, under the governing rules of the superannuation provider or the rules of the superannuation income stream, to receive an income stream on the death of the member.

    If a dependant beneficiary of the deceased member is automatically entitled to receive the income stream upon the member's death, the superannuation income stream continues.

    When you are notified of the death of a member and the superannuation income stream automatically transfers to the beneficiary as described above:

    • this is a legitimate change of account holder and the account identifiers can be re-used for the reversionary beneficiary
    • you need to close the deceased member's account and open a new account in the name of the reversionary beneficiary
    • if you choose to re-use the account number, ensure you complete all member account transaction service (MATS) prior to opening the account in the name of the reversionary beneficiary
    • the 'account status date' of the new account is equal to the deceased member's date of death.
    • your record keeping would provide sufficient evidence of the date of death notification in the event that proof is required for timeliness of your message.

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

    Change of USI or member account identifier number

    If the unique superannuation identifier (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 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 to an SMSF), 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.

    Changes in 'lost' status

    A member of a super provider is a lost member if the member is:

    • a lost RSA holder within the meaning of regulation 1.06 of the RSAR
    • a lost member within the meaning of regulation 1.03A of the SISR.

    These regulations define an RSA holder or member of a super provider to be a lost member at a particular time if:

    • they are uncontactable
    • they are an inactive member
    • the member joined the fund from another super provider as a lost member.

    A key underlying concept is that it is the individual that is lost – not the account.

    You are required to report the lost status of your members at a minimum biannually as follows:

    • assessing the lost status of your members on or after 30 June but before 31 October and if there has been a change in the member’s ‘lost status’ account attribute, report that information on or before 31 October
    • assessing the lost status of your members on or after 31 December but before 30 April and if there has been a change in the member’s ‘lost status’ account attribute, report that information on or before 30 April.

    You can report your members' lost status more frequently if you wish.

    If the individual holds multiple accounts within your fund you must lodge an update for each account.

    See also:

    Reporting closed accounts

    When you notify us of closed accounts via the MAAS, the mandatory account attributes that are required to be reported are:

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

    If other account attributes are reported, our systems will not recognise these account attributes.

    When you receive a 'matched' response for a closed account, the account will be displayed on ATO Online as a closed account. Your members will be able to see transactions on the closed accounts, but no rollovers, etc will be able to be initiated. Accounts closed prior to 1 July 2018 are not displayed on ATO Online.

    If you submit a 'close account' request and receive an 'unmatched' response the individuals account will not have been sucessfully closed and it will remain viewable on ATO online.

    Only report a closed account once:

    • all closure processes have been completed
    • money has been rolled over or paid out
    • no interest is remaining
    • the interest has moved to the reversionary beneficiary
    • 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.

    TFN validation responses

    When you submit a MAAS form to open, update or close a member account you will receive one of the following responses from our service:

    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.

    Note: 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.

    If a TFN has not been quoted for superannuation purposes (by another person) and has not been supplied in the MAAS, it will not be returned in our response. A matched response in this instance does not equate to a TFN validation notice.

    Matched and corrected response

    If you provide a TFN in the MAAS message, 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.

    If we have provided you with a TFN via a matched and corrected MAAS response, there is no requirement to report the updated TFN as a further MAAS update. Instead, update your records with the TFN supplied, once it has been verified by your member.

    When you submit a further MAAS update, you can include the correct TFN. Penalties may apply if you continue to use the incorrect TFN.

    There are some circumstances where we do not return the TFN, and the TFN field is left blank eg when reporting an account closure, and the matching results in a correct TFN, the matching outcome will not be included in the response.

    Unmatched

    A response of ‘unmatched’ means we were unable to match the member details provided to our records with an appropriate level of confidence. In these instances, while we will hold a record of the lodgment against the superannuation provider, the account will not have been associated to the member within our systems. This means that your member will not see these details on ATO Online.

    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, the MAAS message is unmatched against the member in the ATO client register.

    When a MAAS open account is not properly matched to a member in the ATO client register, other MATS interactions will fail to be matched to the member.

    Where you have provided a TFN in your message and subsequently receive an unmatched response you will need to determine whether the unmatched response should be treated as a 'Please resolve' notice and take reasonable steps to rectify the unmatched response as discussed in 'Your obligations to address errors and unmatched responses'.

    Errors

    You have met your MAAS lodgment obligations once you receive a technical receipt.

    If you or your service provider receive an error response from our service you have 30 days to remediate the error from when you become aware of it.

    When will an error be returned

    An error will be returned if:

    • mandatory member information is not provided
    • information is provided in an incorrect format. In this instance the message fails validation and an error will be returned.

    An error will be returned when the MAAS message is successfully formatted but either:

    • a more recent member account request has already been processed (CMN.ATO.SPRMBRINFO.099264)
    • the reported account belongs to a different account holder (CMN.ATO.SPRMBRINFO.096604).

    When an error is returned from our service the message is prevented from being processed in our systems. The information will not be displayed on ATO Online for your member to view nor will we be able to use it to interact with your member until you remediate the error and resubmit the message to us.

    A comprehensive list of the errors returned from the MAAS can be found in the current MAAS BIGExternal Link and the MAAS learnings document.External Link Most of these errors are warnings or informational and require some level of remediation by you.

    Your obligations to address errors and unmatched responses

    Your obligations to resolve unmatched responses and remediate errors are covered under section 390-115 of Schedule 1 to the TAA .

    If you receive an error after receiving a technical receipt the MAAS message will not be processed and you are required to correct the message before resubmitting it to us.

    Reasonable steps need to be taken to determine if there is a material change or material omission in any information you provided. Where you become aware of a material change or omission and are required to correct an error or unmatched response, you have 30 days to provide the corrected information to the Commissioner via the MAAS. All steps taken to remediate an unmatched response should be documented in line with your record keeping obligations.

    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 an employer or financial advisor, we recommend you contact the member directly.

    Example 3:

    A super fund receives a CMN.ATO.SPRMBRINFO.096604 error: the reported account belongs to a different account holder. This means the message will not be processed.

    If the fund is unable to resolve the error within 30 days they will need to either report the account as ‘closed’ under the different account holder, or contact the ATO to confirm the identity of the account holder.

    Remediation work will need to be undertaken before the MAAS message is resubmitted to the ATO.

    End of example

    Account phase must correspond to the correct account status

    An error will be returned if you don't report the correct phase with the correct corresponding status.

    If the account phase is 'Accumulation', then the account status must be either:

    • open
    • transition to retirement income stream

    If the account phase is 'Retirement', then the account status must be:

    • non capped defined benefit income stream
    • capped defined benefit income stream (1 July 2017 onwards)
    • capped defined benefit income stream (pre 1 July 2017)
    • market linked capped defined benefit income stream.

    If the account phase is 'Insurance Only', then the account phase must be open.

    If the account phase is 'Closed', then the account phase must be closed.

    See also:

    Last modified: 30 Apr 2019QC 55581