Superannuation Industry Stewardship Group Key messages 10 September 2026

Superannuation regulators

Treasury

Treasury provided an update on the following items of interest:

• The Treasurer's recent address to the Super Members Council Super Summit outlining the Government's superannuation priorities was noted.
• The 2026 Intergenerational Report will be released on 21 September 2026. The key message is that the overall cost of the system is stable over time.
• Consultation on innovative income stream tax changes is expected to start shortly. Treasury encouraged members to participate, particularly on priorities for regulatory reform as well as barriers to the uptake of innovative income streams.
• Work is underway on a range of measures responding to the Shield Master Fund/First Guardian collapses, including
  • enhanced oversight of self-managed superannuation fund (SMSF) establishment, including additional Australian Taxation Office (ATO) powers to intervene where concerns are identified
  • requiring trustees to set and comply with advice fee caps
  • giving Australian Prudential Regulation Authority (APRA) the power to set capital requirements for trustees and allowing Australian Securities and Investments Commission (ASIC) to direct trustees to commence a remediation process where an investment option fails and there is suspicion that the trustees breached their obligations
  • further detail will be provided about the design and timing of legislation.
• Another priority is the Delivering Better Financial Outcomes reforms which aims to clarify the intra-fund advice rules and targeted superannuation prompts.
• Consultation on the Performance Test closed on 19 June 2026. A significant number of submissions were received, and more information on next steps is expected in the coming months.
• Monitoring on the implementation of Division 296 and Payday Super reforms is continuing.
• Members emphasised the need for sufficient time for design consultation and developing targeted regulations that minimise compliance costs.

APRA

APRA provided an update on the following items of interest:

• APRA’s 2026-27 Corporate Plan identifies superannuation platforms and professional trustees as a priority, with continued supervision intensity and follow-up of enforcement activity.
• Progressing the Retirement Reporting Framework is also in APRA’s Corporate Plan. In response to industry feedback, the Framework has just been released for a 4-week final consultation period.
• APRA will strengthen its focus on investment governance and valuation practices, including thematic reviews of superannuation trustees. Cross-industry priorities include responsible adoption of artificial intelligence (AI) and broader system resilience.
• A consultation paper on proposed changes to Prudential Standard SPS 530 Investment Governance is expected to be released this month.
• APRA has completed consultation on Prudential Standard CPS 510 Governance and expects to release final standards by the end of the year.
• Following release of the Comprehensive Product Performance Package results, APRA will engage with trustees of retirement products that would have been identified as significantly underperforming. This is expected to include asking why trustees believe that they are meeting their annual member outcomes assessment for those products.
• APRA will also provide individual letters to all trustees outlining its planned activities over the next 12 to 18 months.
• In response to member questions, APRA advised that the Performance Test did not apply to retirement products and the Best Financial Interests Duty did not operate to extend the Performance Test consequences to related retirement products.

ASIC

ASIC provided an update on the following items of interest:

• ASIC's follow-up report on death benefit claims handling (Report 831 Delivering on death benefits: have super trustees stepped up) found modest improvements by trustees and a 10% increase in claims volume. This challenge is expected to grow as Australia's population ages.
• A review of how well some platform trustees are safeguarding their members’ super was disappointing (Report 833 Safeguarding Super). ASIC will revisit this with a further review of trustee oversight of advice fee deductions in 2026-27.
• ASIC recently issued infringement notices to three superannuation fund trustees after alleging misleading and deceptive disclosures of investment options on superannuation trustees’ websites.
• Upcoming reports for release include:
  • Phase 2 of ASIC’s member services project focused on learning from complaints.
  • A second round of financial reporting and audit surveillance of Registrable Superannuation Entities.
• Targeted stakeholder engagement has commenced on a broader review of Regulatory Guide 97 on disclosing fees and costs in Product Disclosure Statements and periodic statements. The next step will be the release of an issues paper for public consultation.
• Other future work includes Phase 3 of the member services project, and another thematic review on retirement.

ATO

Insights on Payday Super transition

Early implementation data indicates a positive transition to Payday Super. Some expected teething issues have arisen which the ATO has managed through hyper-care arrangements and resolving them as quickly as possible.

Contribution volumes and error rates have been encouraging.

Worker awareness of superannuation entitlements is increasing, as reflected in higher employee notifications about potentially unpaid super. Payday Super has surfaced a lack of awareness about existing entitlements in some industries.

Tax treatment of Compensation Scheme of Last Resort (CSLR) payments

• As with compensation payments generally, Tax treatment of CSLR payments heavily depends on the facts and circumstances of each case.
• The ATO will provide a written update out-of-session on its guidance for affected CSLR recipients.

ATO 2026-27 Corporate Plan

The ATO’s 2026–27 Corporate Plan outlines its role in administering key aspects of the superannuation system. This includes superannuation guarantee (SG) compliance, helping people keep track of their retirement savings, reuniting lost and unclaimed super, and regulating SMSFs.

Better targeted superannuation concessions public advice and guidance

The current focus of better targeted superannuation concessions consultation is on detailed administrative design.

Four public advice and guidance products are being developed in response to feedback, and consultation is planned by the end of 2026.

Fraud and cyber security

On 18 August 2026 Assistant Treasurer, the Hon. Dr Daniel Mulino MP, held a roundtable on cyber security. Government attendees outlined the current threat landscape and their expectations about trustees’ cyber defences. Cyber security was emphasised as an area of collaboration, and the Assistant Treasurer expects industry associations to work together on threat intelligence sharing and communication during cyber incidents.

Association of Super Funds Australia (ASFA) provided the following update:

• A detailed system-wide cyber response exercise is planned as part of the SC3 framework to test
  • incident management
  • sector coordination
  • communications arrangements
  • activation of the incident response group.
• The exercise responds to lessons from previous cyber events, which highlighted the need for stronger cross-sector coordination. The exercise aims to assess 5 key capabilities
  • incident response capability
  • information sharing and sector coordination
  • regulatory alignment
  • communications coordination
  • government and regulator engagement.
• Lessons learned will be captured as part of the post-incident review and used to inform improvements to the SC3 playbook, and support future sector-wide exercises, which are expected to occur at least annually.

Financial Services Council (FSC) provided the following update:

• Tangible steps have been taken over the past 12 months to uplift cyber resilience, but there is still more work to do.
• The FSC is seeking similar Australian Competition and Consumer Commission (ACCC) clearance to ASFA to ensure all participating organisations have the same legal protections and can collaborate under a common framework.
• A recent exercise demonstrated that the sector requires a single cyber incident playbook and governance structure, which preferably includes representation from all relevant peak bodies.

Super Members Council of Australia (SMCA) provided the following update:

• SMCA is collaborating with ASFA and the FSC on cyber resilience initiatives. SMCA’s primary role is to support member education and communication. This includes the development of a sector-wide cyber education strategy, and a suite of white-label communications materials for use during cyber incidents by super funds, industry associations, consumer groups and regulators.
• The next phase of work involves developing and testing communications materials, with feedback used to determine which messages were most effective and which require further development.

APRA mentioned the upcoming cyber response exercise, noting that the value of industry coordination mechanisms was greatest when all industry participants were party to those mechanisms.

Group discussion noted the opportunity for greater industry-ATO collaboration on fraud prevention and identity assurance. They also discussed prioritising high-impact cyber controls and designing frameworks that can be expanded over time.

Insights from AFCA 2025-26 complaints data

The Australian Financial Complaints Authority (AFCA) gave an overview of its 2025-26 superannuation complaints data. There was a 43% increase in overall superannuation complaints, the highest level recorded in the superannuation area.

In the category of insurance-related complaints, there were also significant increases. Both Total and Permanent Disability and income protection complaints rose by more than 40%. AFCA identified the key drivers of insurance complaints as:

• claim denial complaints which increased by 80%
• delay-related complaints which increased by 35%.

Rising cost-of-living pressures may be contributing to higher complaint volumes, particularly for members experiencing illness, injury or financial hardship.

Death benefit complaints also increased by 10%. Complaints relating to failure to act in a client's best interests were largely driven by Shield and First Guardian related matters, with most of these complaints now progressed through AFCA's case management process.

Overarching themes from 2025-26 data included:

• Service standards and complaint resolution performance are key areas for trustee focus.
• For insurance products, it’s worthwhile examining product design and claims management practices that may be contributing to higher complaint volumes. Increasing accessibility of AI tools may also be contributing to higher volumes.
• Mental health-related insurance claims may also be a driver of increasing volumes because they are more complex, take longer to assess and generate higher complaint rates.

Environmental scan - member updates

Chartered Accountants Australia and New Zealand (CAANZ) provided an update which noted recent research by Oxford Economics Australia which predicts a shortage of about 18,000 accountants in Australia by 2035.

In relation to superannuation tax settings, it was noted:

• Australia has a unique retirement savings taxation model, and retirement income policy should be considered holistically given home ownership is a key determinant of retirement outcomes.
• There is value in examining alternative approaches including reviewing the interaction between SG contributions, tax on contributions and employer deductibility.

Early survey results from CAANZ members about Payday Super were also shared. Key findings included:

• Among those who advise employer clients, there was an increased or significantly increased demand for advice and support.
• Concern about increased administrative burden and costs, as well as cash flow management for some businesses.

It was noted that businesses are implementing Payday Super alongside a range of other reforms, and it would be useful to repeat the survey in 12 months.

The Tax Institute (TTI) provided an overview of TTI’s history and structure. Education and professional development were highlighted as a focus for TTI members. The Institute also has a significant advocacy role and noted the increasing volume and pace of Treasury and regulator consultations.

A range of irritants in the super system were identified including foreign pension transfers, binding death benefit nominations, SMSF residency rules, minimum pension payment requirements and the operation of non-arm's length income provisions. TTI stated that a few current settings produce disproportionate or unintended outcomes and warrant review.

Many tax practitioners are struggling with the volume, pace and complexity of change. TTI calls for simpler, easier-to-digest law, noting concerns that additional compliance obligations were increasing red tape and driving reliance on AI.

It was observed that the ATO had been taking a less pragmatic approach and moved away from detailed and durable technical guidance for practitioners. The ATO noted an interest in pursuing more practical approaches to manage technical and minor breaches where possible.

SMSF oversight

Guests from the University of NSW Tax and Business Advisory Clinic provided some practical insights about financial abuse and coercion in a SMSF environment. Eighty percent of clients referred to the clinic report experiencing intimate partner financial abuse. According to the Australian Bureau of Statistics, 16% of women and 8% of men are victim-survivors.

Clinic casework has highlighted that identity assurance cannot be conflated with consent. A victim-survivor may appear fully involved in decision making, but their credentials are controlled by the perpetrator.

Access to documentation or digital records can also be difficult, as victim-survivors try to resolve arrangements established in their name. Insufficient independent verification about rollovers from APRA-regulated funds to SMSFs was raised as a concern.

Guests emphasised the need for practical pathways, such as self-reporting via a portal to help victim-survivors to resolve compliance issues and regain control of their affairs. They welcomed the recent government announcement to provide the ATO with powers to stop rollovers where financial abuse is suspected.

The ATO outlined the current protections that are in place. It was emphasised that preventing high-risk SMSFs from entering the system is more effective than addressing issues after registration.

The ATO has no visibility of an SMSF until it applies for an Australian business number (ABN), so the ATO works with a range of intermediaries to identify and mitigate risks early in the SMSF establishment process. It was noted that approximately 95% of SMSFs are linked to a tax agent at the time of ABN registration.

Risk models are used at the registration stage to identify high-risk funds, with some of those funds selected for tailored engagement. The ATO contacts all associated trustees to verify their identity, confirm awareness of the fund's establishment and ensure they understand their ongoing obligations. Trustees are encouraged to complete ATO’s educational products at this stage.

The ATO issues alerts to all trustees or members when significant events occur, such as rollover requests or bank account updates. These alerts are sent using an individual's existing client contact details rather than contact information from the SMSF application, to attempt to ensure communications reach the intended person.

The recently announced SMSF reforms will help the ATO identify and address vulnerability at the point of fund establishment. Mandated education including vulnerability focused content, will enable more engagement with funds and provide support avenues for potential victim-survivors.

The ATO advised that frontline staff receive specific vulnerability training and can access escalation pathways for specialist support when supporting vulnerable clients. It was acknowledged that vulnerability can arise at any stage of a SMSF's lifecycle, not only during registration.

Participants agreed to take offline a discussion to explore whether additional questions, indicators or engagement approaches could better identify vulnerable individuals and potential financial abuse.

Treasury noted upcoming policy consultation on new ATO powers relating to debt recovery in fraud cases. This consultation will consider whether similar mechanisms could help victim-survivors of financial abuse, by allowing the ATO to pursue perpetrators and recover losses on their behalf.

Special purpose working group

Membership of the new Special Purpose Working Group is being finalised, and invitations to the first meeting will be issued by the end of September.

Attendees

Attendees list

Organisation	Attendee
ATO	Ben Kelly (Co-chair), Superannuation and Employer Obligations
ATO	Aleesha Moore, Superannuation and Employer Obligations
ATO	Chontelle Weyman, Superannuation and Employer Obligations
ATO	Justin Micale, Superannuation and Employer Obligations
ATO	Kim Nguyen, Superannuation and Employer Obligations
ATO	Lyndal Ratcliffe, Superannuation and Employer Obligations
Actuaries Institute	Timothy Jenkins
Australian Financial Complaints Authority	Benjamin Norman Paul Woodburn
Australian Financial Complaints Authority	Paul Woodburn
Australian Prudential Regulation Authority	James Douglas
Australian Securities and Investments Commission	Nicole Chew
Australian Securities and Investments Commission	Pippa Lane
Business Council of Australia	Michael Potter
Chartered Accountants Australia and New Zealand	Tony Negline
Council on the Aging	Corey Irlam
Financial Services Council	Blake Briggs
Financial Services Council	Kirsten Samuels
Gateway Network Governance Body	Michelle Bower (Co-Chair)
Grow Inc	Adam Gee
Law Council of Australia	Anne Clarke
MUFG Pension & Retirement Solutions	Deborah Schembri
SMSF Association	Mary Simmons
Super Consumers Australia	Lily Jiang
Super Consumers Australia	Xavier O'Halloran
Super Members Council of Australia	Hannah Cole
Super Members Council of Australia	Nick Coates
The Association of Superannuation Funds of Australia	Julian Cabarras
The Association of Superannuation Funds of Australia	Mary Delahunty
The Tax Institute	Phil Broderick
Treasury	Brendan McKenna
Treasury	Sally Greener
University of NSW Tax and Business Advisory Clinic	Annette Tasker
University of NSW Tax and Business Advisory Clinic	Ann Kayis-Kumar
University of NSW Tax and Business Advisory Clinic	Madhvi Madhvi

Apologies list

Apologies list

Organisation	Member
Australian Prudential Regulation Authority	Ian Beckett
Australian Prudential Regulation Authority	Sarah Nicholson
Treasury	Laura Berger-Thomson