Compliance for superannuation trustees (RSE licensees) in Australia
SIS Act trustee duties, SPS 515 member outcomes, YFYS performance test, CPS 230, AFCA, Best Financial Interests Duty, FAR from 15 March 2025, Payday Super 1 July 2026. The full RSE picture.
Superannuation in Australia is governed by 7+ standards at three regulators — APRA prudential, ASIC market conduct + member protection, ATO for SG receipt + SMSF.
RSE licensees face the most concentrated regulatory load of any AU financial services participant. APRA's heatmap, YFYS performance test, SPS 515 member outcomes, CPS 230 operational risk, FAR from March 2025 — all stack.
Below is the practical RSE compliance picture, ordered by what dominates the trustee board agenda.
1. The RSE licence + trustee duties
RSE licence issued by APRA under Pt 2A SIS Act. Trustees owe statutory duties (s 52) — sole purpose, BFID (best financial interests duty), no conflict of duty, no use of position. Personal liability for breach.
2. SPS 515 — strategic planning + member outcomes
Annual member-outcomes assessment for each cohort (MySuper + Choice). Test investment performance, fees, options, take action where inadequate. Outcomes Determinations are published.
3. YFYS performance test
Annual performance test by APRA. Fail = mandatory member notification, member-block if 2 consecutive fails. MySuper from 2021; TDP from 2022. Subject to reform but in force.
4. CPS 230 — operational risk (in force 1 July 2025)
Replaces CPS 231 + 232 from 1 July 2025. Outsourcing + business continuity + operational risk + material service providers register filings.
5. FAR for super (15 March 2025)
Financial Accountability Regime extends to insurance + super from 15 March 2025. RSE licensees must identify accountable persons, prepare accountability maps + statements, defer 40% of variable remuneration 4 years.
6. Payday Super (employer-side, but RSE-impacting)
From 1 July 2026 — SG payable within 7 business days of pay event. RSE trustees must ensure custodian + administrator process per-pay receipts at scale + reconcile. Qualifying Earnings base from same date.
7. Stronger Member Outcomes + RG 270
ASIC RG 270 on hawking + cold-call ban; RG 271 IDR; member ID + protection from anti-hawking + cooling-off enforcement.
8. AML/CTF (super fund as reporting entity)
Most super funds are AML/CTF reporting entities. Customer due diligence on contributions + benefit payments + rollovers; SMR/TTR/IFTI obligations; AML/CTF program.
9. Climate disclosures (AASB S2)
Super funds typically Group 1 entities under AASB S2 — mandatory climate-related financial disclosures from FY25. Scope 3 (investee emissions) from year 2.
10. Greenwashing enforcement program
ASIC + APRA joint reviews of sustainability-labelled super products — REST, Mercer, others. Ongoing enforcement program.
FAQ
Is the YFYS performance test still in force after the 2024 review?
Yes, but Treasury has flagged design changes — single benchmark + lifetime + service comparison metrics under consideration. Current methodology persists until reform finalised.
When does FAR apply to me?
If you are an RSE licensee, FAR applies from 15 March 2025. Banking phase commenced 15 March 2024.
Do we need to register material service providers?
Yes — CPS 230 Attachment B requires material service provider register filings to APRA from 1 July 2025.
Published obligations that apply to superannuation trustees (11)
- criticalCWLTHAnnual YFYS performance test (MySuper + Choice)
APRA annual performance test for MySuper products + (from 2024) Trustee Directed Products.
- criticalCWLTHComply with APRA CPS 220 (Risk Management)
APRA-regulated entities must have a comprehensive risk management framework.
- criticalCWLTHComply with APRA CPS 230 (Operational Risk Management)
APRA-regulated entities must manage operational risk including a comprehensive third-party / outsourcing register from 1 July 2025.
- criticalCWLTHComply with APRA CPS 234 (Information Security)
APRA-regulated entities must maintain information security capability commensurate with the size and extent of threats.
- criticalCWLTHComply with Design and Distribution Obligations (DDO)
Issuers and distributors of retail financial products must have a Target Market Determination (TMD) and distribute consistently with it.
- criticalCWLTHComply with Financial Accountability Regime (FAR) accountability obligations
Banking entities from 15 March 2024; insurers and super trustees from 15 March 2025.
- criticalCWLTHComply with SIS Act trustee covenants
Super fund trustees owe statutory covenants of care, skill, diligence, best financial interests, and prudent investment.
- criticalCWLTHFAR deferred remuneration arrangements (40% deferral 4 years)
FAR accountable persons must have 40% of variable remuneration deferred 4 years.
- criticalCWLTHStronger Member Outcomes — APRA SPS 515
RSE licensees must annually assess member-outcomes performance + take action.
- highCWLTHComply with SPS 530 (Investment Governance) for APRA-regulated super funds
RSE licensees must have a documented investment governance framework.
- highCWLTHMySuper authorisation for default super products
Default super contributions can only flow to APRA-authorised MySuper products.