APRA expects proposed reforms to hit platforms hardest 

APRA has proposed requiring superannuation trustees to set and enforce limits on members’ exposure to high-risk investment options as part of a package of investment governance reforms it expects to fall most heavily on platform trustees. 
 
The proposals, released for consultation on Wednesday, would apply to all trustees, but APRA deputy chair David Bradbury told a media briefing that the regulator expected platforms to feel the greatest effect. 
 
“All of these rules will affect all superannuation trustees, but I think it is worth acknowledging that they are expected to have the greatest impact on platform trustees,” Bradbury said, noting the breadth of investments platforms typically offer, the complexity of some of those products, and platforms’ greater reliance on third parties such as advisers.  
 
The proposals follow the $1 billion collapse of Shield and First Guardian master funds, which Bradbury described as “examples of where we see the severity of member harm that can be felt, where investment governance practices may not meet the standards or expectations that APRA would have”.  
 
He said APRA’s supervisory and enforcement work in recent years, including a thematic review and targeted enforcement action, had not fully addressed weaknesses in the sector. 
 
Under the proposals, trustees would set member-level limits on “concentrated higher-risk options”, subject to a ceiling set by APRA. The paper gives APRA’s preliminary view that a cap of 20 to 30 per cent per option, or group of options, may be appropriate. APRA expects trustees to set lower limits in many cases, the paper says, particularly for illiquid options such as private credit and for single ASX 300 securities. 
 
The limits would apply when a member buys into or adds to an investment. Existing holdings that grow past a limit would not generally have to be sold.  
 
Bradbury said the limits were intended to reduce the risk of members losing most or all of their retirement savings through concentrated positions. 
 
“It’s the difference between having an impact, a general impact on your super fund balance, or seeing it disappear completely,” he said. “So it’s not about eliminating choice; it’s really about putting some guardrails around choice.” 

Conflicts and clawbacks  

The package also proposes strengthening trustees’ management of conflicts of interest and requiring trustees to have the resources and capabilities needed to oversee their investment menus.  
 
Under the proposals, trustees would be required to identify and manage or avoid conflicts involving promoters, advisers and other third parties, and would also have to set and regularly review limits on the size and complexity of their investment menus, relative to their capability and resources. 

The proposals come amidst a broad push by profit-to-member funds and their proxies, including the Super Members Council, for governance uplift among the retail platforms to which they are losing an increasing number of members.  

In November 2025, the SMC proposed the expansion of the Financial Accountability Regime across all super and investment platforms and the reintroduction of ASIC’s “investing between the flags” initiative, which would see consumers warned when they are moving outside of system safeguards. The SMC also welcomed a proposed “cooling-off” period for super switching, which is widely seen as one way of slowing outflows to retail platforms.  
 
APRA is also considering whether remuneration requirements under CPS 511 that currently apply to significant financial institutions, including clawbacks, should be extended to complex super trustees, though Bradbury said that no decision had been made.  
 
“We’re not proposing that as policy change as part of this package,” Bradbury said.  
 
“I’ll make a general observation, and that is that it would seem appropriate that remuneration settings, and particularly those that relate to variable compensation, bear a relationship with the performance of the entity and whether or not the entity is delivering for the best financial interests of its members, and I think that we want to ensure that the overall policy settings are such that there is an alignment between those considerations.”  
 
Bradbury said the proposals were separate from the government’s announcement last month on streamlining compensation arrangements, but were aligned in their objectives and would be complementary in effect. 
 
“All trustees are ultimately responsible for the investments that they offer their members,” he said.