Corporate watchdog maintains focus on superannuation platform advice fees

Key observations

• ASIC calls for platform superannuation trustees to adopt stricter adviser governance. No new processes are expected, but ASIC does expect standards of adviser governance to be stronger and stricter.
• ASIC expects platform superannuation trustees to have already adopted appropriate monitoring and risk reduction processes to address high risk super switching. It appears that ASIC’s view is that a platform superannuation trustee’s duties require it to adopt a quasi-regulator role in taking steps to protect their members from poor adviser behaviour.
• The report focuses on one part of the wealth system. This means that the report does not comment on or raise concerns with other actors in the wealth system and their role in relation to the issues covered by the report.  For example, there is no consideration of adviser obligations in charging reasonable advice fees, the role of ASIC in licensing and monitoring advisers or advice licensees of concern. There is no discussion of the challenges surrounding the ability of competitor platforms to share information about advisers of concern.
• The Financial Services Council released FSC Standard 31 which contains binding rules for platform superannuation trustee governance for FSC members. This report provides a baseline to assess the impact of FSC Standard 31 over time.
• While the law does not recognise a separate concept of platform superannuation trustee and relevant legal obligations applying to these trustees are no different to those applying to superannuation trustees generally, ASIC’s approach suggests that the application of the law requires a more focused approach for platform superannuation trustees given their commercial setting.

ASIC’s latest review of selected platform superannuation trustees and adviser fee arrangements

ASIC Report 833 Safeguarding super: How well are platform trustees monitoring risks to retirement savings?, released 29 June 2026, sets out ASIC’s observations following an assessment of six trustees that operate superannuation platform products.  ASIC’s review was undertaken between 1 June 2024 and 31 October 2025.

The trustees that were the subject of ASIC’s review are not identified in Report 833, however ASIC notes that as at December 2025, these trustees represented $305 billion in member benefits (around 72% of the total funds managed by platform superannuation trustees).

The focus of ASIC’s review was platform superannuation trustees’ oversight of financial advisers who provide advice to superannuation platform members and the financial advice fees paid from platform member accounts.  The review coincided with ASIC’s regulatory investigations and legal actions in connection with high-profile cases of misconduct involving the Shield Master Fund and First Guardian Master Fund, which raised particular concerns for platform superannuation trustees.

While platforms were responsible for just 14% of the total superannuation sector as at December 2025, the platform segment (and advice fees charged to platform accounts) has accelerated relatively quickly, and advisers are the primary distribution channel for platforms.

ASIC (together with APRA) has previously issued communications to RSE licensees in relation to the oversight of advice fee arrangements, and has also previously reported on its surveillance of trustee practices in respect of such arrangements,[1]noting that this previous guidance was not platform-specific.  ASIC’s observations in Report 833 are broadly consistent with those past communications, but the regulator provides additional detail in the context of its Shield/First Guardian investigations.  In summary, ASIC concludes in Report 833 that while there had been some examples of ‘uplift’ since ASIC’s previous review of these issues:

• there has been a lack of progress in key areas, including oversight of advice fee deductions and fee-related conduct, and the monitoring of holding limits and options on investment menus; and
• trustees are still not doing enough to protect members from harmful advice fee deductions and inappropriate investments on platforms.

Report 833 provides further guidance on ASIC’s expectations of how platform superannuation trustees (and superannuation trustees more broadly) should act to protect members from risks associated with advice fees and adviser fee-related conduct – these are summarised below.  Trustees should consider the guidance in Report 833 when formulating approaches to managing arrangements with advisers and advice licensees, and the payment of fees for personal advice from member accounts.

Trustees’ legal obligations

ASIC notes that superannuation trustees are subject to a range of legal obligations relating to oversight of advice fees and advice fee-related conduct, including:

• the obligation of a financial services licensee under section 912A of the Corporations Act 2001 (Cth) to do all things necessary to ensure that the financial services covered by their licence are provided efficiently, honestly and fairly;
• the covenants by a trustee under section 52 of the Superannuation Industry (Supervision) Act 1993 (Cth) (SIS Act), including to perform the trustee’s duties and exercise the trustee’s powers in the best financial interests of the beneficiaries;
• the sole purpose test and requirements that advice fees be charged against a member’s interest only for personal advice and where the member has given written consent meeting prescribed requirements (sections 62 and 99FA of the SIS Act);
• requirements for appropriate oversight by trustees’ senior executive teams to comply with Financial Accountability Regime obligations.

ASIC expects more robust oversight of advice fee deductions

ASIC reiterates in Report 833 that it does not expect superannuation trustees to assess the quality, value or appropriateness of individual pieces of advice.  However, ASIC does expect that:

• trustees will confirm (through a methodological program of random checks of a sample of advice documents) that a financial service has in fact been provided (that is, a ‘fee for no service’ is not being passed on to members) and that the advice and fee payments are consistent with the sole purpose test;
• trustees will set advice fee caps (including an upper dollar limit) to safeguard against inappropriate balance erosion, review these fee caps to form a view on the appropriate cost of advice that meets members’ superannuation needs (including protecting low-balance members, by measures such as minimum balance requirements for advice fee deductions or different caps on advice fees for low balance accounts);
• members are protected by trustees allowing few advice fee types that ensure fees are simple and easily distinguishable (such that fees for similar advice services are not ‘layered’ on top of one another). 

ASIC expects trustees to be inquisitive in onboarding advisers and advice licensees, and interrogate potentially harmful business models

There is an expectation by ASIC that trustees will appropriately vet advisers and advice licensees, by:

• using a range of resources (which may include background checks into adverse media coverage, confirming AFCA membership, confirming ABN and GST registration, seeking evidence of professional indemnity insurance, reviewing FSGs);
• identifying and interrogating potentially harmful business models (which might include conducting site visits, engaging with the licensee to understand its business model and making enquiries to determine whether third-party referral sources are used to acquire new clients), and not relying solely on checklists or attestations from the licensee;
• engaging in ongoing monitoring of indicators (including fee flows and member growth).

Trustees should have clear processes for the ongoing monitoring of advisers and advice licensees, with clear triggers for escalation and action

As part of the trustee’s appropriate processes to ensure adequate oversight of advisers and advice licensees to whom advice fees are paid from member accounts, ASIC expects that trustees will:

• monitor advisers and licensees to detect areas of concern, using indicators such as complaints data, rapid business growth and multiple instances of high advice fees;
• frequently monitor ASIC’s Financial Advisers Register and media alerts, to better detect advisers who have engaged in poor conduct, but who have moved between advice licensees or corporate authorised representatives of the same advice licensee;
• actively maintain a watchlist of advisers, corporate authorised representatives and advice licensees of concern, with clear and timely processes to remedy issues or remove the adviser, authorised representative or licensee;
• report any concerns regarding advisers, corporate authorised representatives and advice licensees to ASIC as a matter of priority.

Trustees should also actively monitor advice fees and investment flows into particular investment options

ASIC expects that trustees’ ongoing monitoring of adviser fee arrangements will include monitoring for patterns and irregularities in fees, business volumes or investment flows, to identify:

• breaches of member holding limits in relation to particular investment options;
• over concentration of members advised by particular advisers or licensees in particular investment options (which could indicate ‘cookie-cutter’ advice) – ASIC observes that advisers channelling members into particular investment options was part of the conduct in the Shield and First Guardian matters;
• sharp or unusual increase in member flows to a particular adviser or advice licensee – this can assist in identifying ‘member churn’ and unrealistic volumes of advice (as a best practice example, ASIC noted that one trustee had flagged for further investigation advisers with more than 50 ongoing or fixed-term agreements and advisers with 10 or more new members in two or more months out of the previous 12 months);
• unusual, irregular or distinct patterns of fee deductions (which can identify unscrupulous advisers who are structuring fees to bypass the trustee’s fee cap controls).

ASIC urges trustees to take a strategic and methodological approach to monitoring fees and investment flows, with objective thresholds and clear actions that are consistent with the trustee’s risk appetite.  ASIC’s preference is for monitoring to be automated (with human oversight), as ASIC’s review indicated an over-reliance on manual processes which made the monitoring vulnerable to human error.

It is interesting to consider ASIC’s comments in light of Proposal 6 in ‘Enhancing oversight and governance of managed investment schemes’ Consultation Paper dated February 2026, which proposed reforms for super trustees to alert ASIC about high risk super switching activities.