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Submission to Australian Treasury consultation on Strengthening the Superannuation Performance Test

COTA Australia supports strengthening and expanding the superannuation performance test to improve transparency, accountability and consumer outcomes, particularly for older Australians and retirees. 

In our submission to the Australian Treasury’s consultation, our key recommendations include:

  1. Extend performance testing to retirement products as a priority, using a framework tailored to retirement objectives rather than simply applying accumulation-phase measures.
  2. Keep consumer outcomes at the centre of reform, ensuring strong protections against underperformance while supporting innovation and better retirement income outcomes.
  3. Maintain clear and simple consumer information, ensuring any increased methodological sophistication does not undermine transparency or consumer engagement.
  4. Adopt a CPI + X% benchmark approach to reduce unintended barriers to investment and improve comparability across an increasingly diverse range of products and investment strategies.
  5. Introduce regular benchmark reviews, ideally as part of Retirement Income Review every five years, to ensure the framework remains fit for purpose and responsive to changing products, markets and consumer needs.
  6. Progressively expand testing to all superannuation products, including externally-directed and single-sector products, while preserving comparability, accountability and strong consumer protections.
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