Solving the platform puzzle: ASIC's push to complete the picture on superannuation platform oversight and governance

ASIC's recently released Report 833, Safeguarding super: How well are platform trustees monitoring risks to retirement savings? (REP 833), marks the latest piece in the regulator's expanding focus on the gatekeeper obligations of platform operators and superannuation trustees. The report builds on a clear trajectory of heightened scrutiny, with ASIC having already signalled its expectations regarding platform investment governance through enforcement actions against Shield and First Guardian. These developments underscore that ASIC expects platform trustees to move beyond passive oversight and demonstrate robust, proactive monitoring of the risks to which members' retirement savings are exposed. ASIC Commissioner Simone Constant clearly warns that where significant non-compliance is identified, ASIC "will not hesitate to exercise [its] regulatory powers, including enforcement action".

ASIC's intention is laid clear in the executive summary, where they provide the reader a straightforward reminder of Trustees' legal obligations, including "efficiently, honestly and fairly", "best financial interests", and "oversight of advice fee deductions".

The context: growth, misconduct and regulatory concern

ASIC recognises the unique role played by platform superannuation products role in Australia's superannuation system, which offer members a broader range of investment options and control over their retirement savings. As at December 2025, platforms were responsible for $424 billion in superannuation member benefits, just 14% of the total superannuation sector, but have seen extraordinary growth, with member benefits more than tripling between June 2015 and June 2025. However, the collapses of the Shield Master Fund and First Guardian Master Fund cost more than 11,000 Australians around $1 billion in retirement savings and have exposed particular weaknesses in parts of the platforms segment.

ASIC notes that these concerns, together with the growth in platform member benefits and advice fees charged from superannuation platform accounts over the past 10 years, were the key motivating factors for ASIC's review and findings in REP 833. Having said that, ASIC and APRA have been concerned about gaps in trustees' oversight of advisers, advice licensees and investments for a number of years, evidenced through joint letters issued in 2019 and 2021 and the publication of Report 781 Review of superannuation trustee practices: Protecting members from harmful advice charges (REP 781) in May 2024. REP 833 follows this regulatory trajectory and represents a further escalation of ASIC's supervisory expectations for the sector.

What ASIC reviewed

ASIC reviewed a sample of six platform trustees (and a corresponding fund) representing $305 billion in member benefits and 977,000 member accounts as at December 2025, covering the period from 1 June 2024 to 31 October 2025. The reviewed trustees are responsible for 72% of platform trustees' member benefits. Over the data period, trustees reported $2.56 billion in advice fees deducted from 720,000 advised members and over 2,580 checks of advice documents were reported with nearly 250 adverse findings.

Key findings: what concerns ASIC

While some trustees performed materially better in one or more areas, all had significant room for improvement according to ASIC. The key deficiencies identified in REP 833 fall across several areas.

Inadequate advice fee caps and low-balance protections

ASIC found that percentage-based fee caps ranged from 1.66% to 10%, with three trustees not setting an upper limit. The highest dollar-based fee cap was $25,000, although one trustee proposed to implement a cap of $30,000, well beyond the caps identified in REP 781. Five trustees did not have a minimum balance requirement and therefore permitted advice fees to be charged to accounts with balances at or below $20,000. Several trustees had percentage-based fee caps that were not subject to a lower bound, resulting in very high proportionate fees for low-balance accounts. ASIC considers that setting a minimum balance for advice fee deductions is better practice and queries whether even a $20,000 threshold is too low.

Insufficient advice document checks

Half of the trustees reported they did not conduct any advice document checks for at least one of the months in ASIC's review period. Platform trustees reported over 240 adverse findings from their checks, representing nearly 10% of all checks performed, with adverse findings rates ranging from 3% to 75%. ASIC found that trustees with higher rates of adverse findings performed the least checks. In one case, a trustee performed just 21 risk-based advice checks over the entire data period and reported an adverse findings rate of 75%. Commissioner Constant observed that it is "extraordinary to see some trustees not carrying out any checks in a month despite a 75% adverse finding rate".

Insufficient focus on business models during onboarding

There was insufficient focus on understanding advice licensees' business models during onboarding, including whether such advice licensees use lead generators or other third-party referral sources. For example, ASIC identified a harmful advice licensee that was onboarded by four trustees in the review, with over $1.6 million in advice fees charged by that licensee, which targeted low-balance members. Commissioner Constant described the failure to look into an advice licensee's business model before onboarding as "a clear breach of trust".

Watchlists without clear action points

While watchlists were widely used, some lacked clear triggers for escalation or action. In one disturbing case, a trustee failed to take further action for 13 months after becoming aware of suspicious activity from a representative of an advice licensee. During that time, another representative of that same licensee submitted applications to rollover superannuation balances containing the falsified signatures of a deceased adviser.

Manual monitoring and subjective thresholds

Four trustees reported at least one threshold that was unnecessarily subjective or relied on discretion in place of clear and objective thresholds. Complaints data was underused, and some trustees over-relied on staff discretion and manual processes, which increased the risk and incidence of human error. One trustee's monitoring process was fully manual, leaving it vulnerable to human error. Some trustees focused their monitoring narrowly on specific topics, such as anti-money laundering or counter-terrorism financing issues, which, while important, are less helpful in monitoring for inappropriate switching business models or excessive advice fees.

Inadequate monitoring of holding limits and investment flows

Despite all trustees offering investment options with holding limits on their platforms, only two trustees reported monitoring their holding limits. ASIC notes that holding limits provide little protection to members unless they are monitored and enforced effectively.

Prioritising relationships over members

ASIC is concerned that some platform trustees may be prioritising their relationships with advisers at unacceptable risk to members' retirement balances. REP 833 found that some trustees' senior executives did not know what advice fee caps and other controls were in place on their platforms. Trustees' senior executive teams should have access to timely, accurate and targeted reporting on advisers and advice licensees, including oversight of advice fee deduction and switching behaviour, to satisfy themselves that they are complying with their Financial Accountability Regime obligations.