This week we released two submissions to Treasury’s proposed reforms to strengthen consumer safety; one focused on lead generators and another on the need to lift governance and accountability obligations for platforms and SMSFs to match the high standards that apply for mainstream APRA-regulated super funds.
Australians trust the super system to deliver on one simple promise: that the super money they set aside every payday will be there for them in retirement.
But recent events have shown that promise can be undermined when gaps in consumer protections are exploited — and when bad actors find ways to game the system.
The collapses of Shield and First Guardian, which left almost 12,000 Australians facing losses of more than $1 billion, exposed how aggressive sales tactics and regulatory erosion can combine with devastating consequences.
Those failures were not isolated incidents, but an ominous warning sign about serious risks of consumer harm in all parts of the super system where governance, accountability and regulatory oversights are weaker.
A big part of this problem is a growing wave of predatory “super switching” advertising. Disguised as helpful advice or comparison tools, these lead generation funnels harvest personal data and pressure Australians into moving their retirement savings into higher-risk products.
For many Australians, it’s hard to tell the difference between a legitimate ad and a clickbait scam — with more than 70 per cent of Australians saying they find it difficult to distinguish between the two.
That’s why a clear, decisive response is needed.
First, we must shut down the pipeline of harm at its source. Banning predatory lead generation practices isn’t about limiting information — it’s about stopping industrial-scale sales operations that steer people into decisions that are not in their best interests.
Second, we need to ensure the entire super system operates to consistently high standards — no matter where a member’s money is invested.
Right now, safety gaps persist between APRA-regulated parts of the system and some investment vehicles, platforms, and ATO-regulated SMSFs.
Following APRA’s thematic review of platforms last year, it announced this morning it was taking enforcement action against one major platform’s trustee over concerns about investment governance and conflicts of interest management. This is the fifth platform trustee APRA has taken action against recently.
A level playing field with strong, uniform governance, accountability and oversight across all super products, is critical to restoring confidence and preventing future harm.
Thirdly, access to safe, affordable, high-quality financial advice is also a crucial consumer protection, and a key defence against predatory practices. Each day of delay in the Delivering Better Financial Outcomes (DBFO) reforms is a day that leaves Australians exposed to safety risks, with the affordable advice gap making consumers more vulnerable to lead generation and high‑pressure sales.
This is particularly important when APRA data shows advice fee deductions from super have doubled over the past five years — growing from $1.464 billion in 2020 to $2.975 billion in 2025, with a sharp $1.1 billion increase in just the past two years, largely concentrated in platform channels.
The lesson from recent failures is clear: strong safeguards in one part of the system are not enough if they don’t apply everywhere.
Australians deserve a super system that works for them at every step — not just most of the time.
