AustralianSuper seeks to advocate sustainable and equitable public policy in superannuation and financial services. To this end we engage in advocacy, liaison and write public submissions to Government and Regulators such as APRA, ASIC and the ATO. We also work in industry associations such as Industry Super Australia, Australian Institute of Superannuation Trustees, Association of Superannuation Funds of Australia, and on occasion the Financial Services Council and the SMSF Association.
Policy submissions
Our submissions strategically target four ‘system-level’ policy drivers which determine the adequacy, efficiency, integrity and sustainability of Australia’s superannuation scheme. We advocate to strengthen each driver to ensure that we continue to have a world-leading superannuation system that contributes towards the ability of members to achieve their best retirement outcome.
For more information contact Nick Coates ncoates@australiansuper.com, James Bennett jbennett@australiansuper.com or Richard Murphy rmurphy@australiansuper.com.
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Browse submissions(41)
Superannuation Performance Test Regulations - May 2023 - pdf, 183KB
Multinational tax integrity - April 2023 - pdf, 410KB
Better targeted superannuation concessions - April 2023 - pdf, 285KB
Financial resources for risk events in superannuation - March 2023 - pdf, 207KB
Objective of Super submission - March 2023 - pdf, 300KB
Investment Governance - March 2023 - pdf, 168KB
Non-arms length expense rules - February 2023 - pdf, 146KB
Climate-related financial disclosure - February 2023 - pdf, 406KB
Expansion of Australias tax treaty network - December 2022 - pdf, 307KB
Sustainability Standards Australian Accounting Standards Board AASB - December 2022 - pdf, 289KB
Review of Modern Slavery Act 2018 - November 2022 - pdf, 275KB
Global Agreement on Corporate Taxation - November 2022 - pdf, 138KB
Strategic Planning and Member Outcomes - SPS515 - November 2022 - pdf, 345KB
CPS230 Operational Risk Management - October 2022 - pdf, 376KB
Your Future Your Super - October 2022 - pdf, 219KB
Advice Review: Response to Options Paper - September 2022 - pdf, 253KB
Multinational Tax Integrity Submission - September 2022 - pdf, 278KB
ISSB Sustainability Climate Disclosure - July 2022 - pdf, 400KB
Advice Review - June 2022 - pdf, 692KB
APRA Data - Phase 2 - May 2022 - pdf, 162KB
APRA Data - Confidentiality - April 2022 - pdf, 265KB
Strengthening Financial Resilience in Superannuation - March 2022 - pdf, 157KB
Online Calculators - CP351 - February 2022 - pdf, 344KB
Online Privacy Bill - December 2021 - pdf, 179KB
Improving Outcomes for Litigation Funding - November 2021 - pdf, 242KB
Review of Occupational Exclusions in Default Insurance - October 2021 - pdf, 565KB
Stapling and Group Life Insurance Policies in Superannuation - September 2021 - pdf, 370KB
Implications of Common Ownership and Capital Concentration in Australia - September 2021 - pdf, 198KB
Superannuation Portfolio Holdings Disclosure - Consultation on Draft Regulations - August 2021 - pdf, 375KB
Retirement income covenant position paper consultation - August 2021 - pdf, 497KB
APRA CPG229 - Climate Change Financial Risks - July 2021 - pdf, 208KB
Greater Transparency of Proxy Advice - June 2021 - pdf, 288KB
Your Future Your Super Draft Regulations - May 2021 - pdf, 215KB
Treasury Laws Amendment Your Future Your Super Bill March 2021 - pdf, 534KB
Your Future Your Super - Exposure Draft Legislation - December 2020 - pdf, 269KB
Class Actions - June 2020 - pdf, 542KB
Retirement Income Review - Feb 2020 - pdf, 697KB
Unlawful underpayment of remuneration - Feb 2020 - pdf, 199KB
Fees and Costs - ASIC CP 308 - April 2019 - pdf, 591KB
Royal Commission - Banking Superannuation and Financial Services - August 2018 - pdf, 203KB
Submission in response to the Productivity Commission Draft Report - July 2018 - pdf, 751KB
Adequacy
Ensuring that the policy settings in superannuation are designed to make it most likely to achieve adequate funds for retirement.
Although the government age pension prevents extreme poverty, it is not necessarily enough to support a comfortable lifestyle – especially for those who are not home owners in retirement. Adequacy includes both the overall quantum of retirement savings, as well as longevity – the length of time superannuation funds last in retirement. Adequacy must be included in the objectives of the superannuation system so that our retirement system delivers a financially secure and dignified retirement.
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Browse submissions(3)
Efficiency
Ensuring that the policy settings in superannuation enable the most efficient cost structures in provision of funds for retirement.
Costs are one of the most important determinants of the long run efficiency of the superannuation system. Policy settings that assist to reduce the cost of compliance and variable costs or support lower operational expense to net asset ratios are important to superannuation system sustainability.
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Browse submissions(27)
ACCC Submission - Ausgrid - pdf, 348KB
APRA Prudential Regulation Standards April 2015 - pdf, 220KB
AS Submission APRA on member outcomes consultation March 2018 - pdf, 462KB
AS submission to Treasury - OECD hybrid mismatch rules Apr 2018 - pdf, 223KB
AS submission on APRA Prudential Standards - pdf, 221KB
AustralianSuper Response to PC Alternative Default Models 270417 - pdf, 529KB
AustralianSuper submission to PC Stage 3 - pdf, 639KB
AustralianSuper submission to the Productivity Commission 2016 ldpa20161028 - pdf, 246KB
Financial System Inquiry 2013 - feedback on draft terms of reference - pdf, 510KB
Financial System Inquiry August 2014 - pdf, 520KB
Submission for ASIC Electronic Disclosure consultation paper 2-feb15-eff - pdf, 554KB
Submission on APRA prudential standards Dec11 - pdf, 434KB
Submission on ASIC Consultation Paper 219-feb14 - pdf, 288KB
Submission on CO 14 1252 and RG 97 on fees and costs May15 - pdf, 157KB
Submission on Product Dashboards for Choice Investment Options jan16 - pdf, 550KB
Submission on proposed financial industry levies 1415 Jun14 - pdf, 497KB
Submission on Re Think Tax Discussion Paper jun15 - pdf, 534KB
Submission on Tailored MySuper aug15 - pdf, 423KB
Submission on the Retirement Incomes Framework apr15 - pdf, 548KB
Submission Superannuation discussion paper feb14 - pdf, 273KB
Submission to ASIC Draft class order disclosure of fees consultation - pdf, 483KB
Submission to ASIC s29Q class order proposals mar13 - pdf, 438KB
Submission to ASIC 254 may16 - pdf, 535KB
Submission to Productivity Commission into default super system sept16 - pdf, 564KB
Submission to Senate on exposure draft of Super Reform Package sept16 - pdf, 528KB
Submission to Treasury on Proposed Financial Institutions Supervisory Levies Jun16 - pdf, 473KB
Submission v2 rg97 fees and costs Mar15 - pdf, 441KB
Integrity
Ensuring that the policy settings in superannuation promote the best interests of consumers.
The best outcome for superannuants can only be achieved through system integrity. This refers to the interplay between appropriate regulatory settings, an industry regulator, trustee fiduciary responsibility, oversight and accountability to members, as well as competitive pressure. System integrity also encompasses transparency, robust governance frameworks and consumer protection measures.
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Browse submissions(23)
AustralianSuper Submission to Treasury on Early Release of Super Benefits Feb2018 - pdf, 442KB
AustralianSuper Submission to Treasury on Early Release of Super Benefits Feb2018 - pdf, 768KB
Submission APRA on member outcomes consultation March 2018 - pdf, 462KB
AS submission to DSS on longevity products Feb 2018 - pdf, 424KB
AS Submission to Senate Committee on United Nations Sustainable Development Goals March 2018 - pdf, 2.0MB
AS Submission to Treasury on Proposals Paper March 2017 - pdf, 206KB
AustralianSuper submission on the Insurance in Superannuation Code - pdf, 320KB
AustralianSuper submission to Treasury on CIPRs - pdf, 592KB
Submission to the senate inquiry into economic security of women in retirement - pdf, 472KB
Financial System Inquiry 2013 - feedback on draft terms of reference - pdf, 510KB
Letter to ASFA re Governance Paper-jul13 - pdf, 61KB
Response to the ASFA Discussion Paper Consultation Questions-dec13 - pdf, 167KB
Stakeholder briefing note Expanded risk disclosure May 2012 - pdf, 861KB
Submission on APRA prudential standards dec11 - pdf, 434KB
Submission on CO 14 1252 and RG 97 on fees and costs may15 - pdf, 157KB
Submission on Portfolio Holdings disclosure-jan16 - pdf, 533KB
Submission on Product Dashboards for Choice Investment Options jan16 - pdf, 550KB
Submission on proposed financial industry levies 1415 jun14 - pdf, 497KB
Submission Superannuation discussion paper feb14 - pdf, 273KB
Submission to ASIC Draft class order disclosure of fees consultation - pdf, 483KB
Submission to ASIC s29Q class order proposals mar13 - pdf, 438KB
Submission to Willing to Work Inquiry Dec15 - pdf, 544KB
submission v2 rg97 fees and costs mar15 - pdf, 441KB
Sustainability
Ensuring that the policy settings in superannuation give rise to a system doesn't favour one generation over another.
An ageing Australian population will increasingly place pressure on federal governments to fund the aged pension. The ability to support a larger proportion of the population over the age of 65 will test the sustainability of current superannuation policies. To ensure less future reliance on the government aged pension, it will be important to ensure that the superannuation system is based on a clearly stated objective, provides the right incentives to save, is equitable and flexible enough to ensure all working Australians are given the opportunity to enjoy a fulfilling retirement.
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Browse submissions(9)
Submission to Senate on United Nations Sustainable Development Goals (SDG) - pdf, 2.0MB
Response to discussion paper re: Comprehensive Income Products for Retirement (CIPRs) - pdf, 592KB
Response to discussion paper re: Superannuation Charter - pdf, 356KB
Financial System Inquiry 2013 - feedback on draft terms of reference - pdf, 510KB
Submission on proposed financial industry levies 2014-15 - pdf, 497KB
Submission to RE: THINK tax discussion paper - pdf, 535KB
Submission on review of retirement income stream regulation - pdf, 582KB
Submission on the Retirement Income Framework - pdf, 551KB
Submission to Senate on exposure draft of super reform package - pdf, 529KB