Submission – Enhancing member protections in the super system
This submission is supplementary to SMC’s primary submission to Treasury’s consultation on Enhancing Member Protections in the Superannuation System (22 May 2026).
It identifies escalating structural and system integrity concerns in recent switching patterns, major growth in advice fee deductions since the ASIC 781 Review, and a consumer protection gap between APRA-regulated profit-to-member funds and other vehicles — including platform-based super funds and self-managed superannuation funds (SMSFs).
This supplementary submission shares empirical data from SMC’s analysis of member-level switching records from five large profit-to-member funds, and from APRA’s annual fund-level super statistics (back-series, June 2025), to support the analysis with quantitative evidence.
The data is presented in two sections:
- Section 1 examines flows into self-managed superannuation funds (SMSFs), highlighting the regulatory arbitrage created by the absence of equivalent safeguards.
- Section 2 examines recent switching into platform-based super funds, with a particular focus on advice fee settings and related switching patterns.
Where relevant, findings are cross-referenced to the proposals in SMC’s primary submission. Taken together, the analysis is an empirical foundation for targeted policy interventions to address emerging consumer risks in parts of the superannuation system where consumer protections are weakest.
