Super Alert – 2 April 2026: ASIC first 3 modules for sustainability reporting, APRA decommissions Direct to APRA’ or ‘D2A’ data submission system
Welcome to the weekly KHQ Super Alert. This week Treasury released draft regulations for public consultation in relation to the recently introduced ban on advertising superannuation products during the employment onboarding process. ASIC announced that the first three education modules for the upcoming sustainability reporting obligations are now available. Meanwhile, APRA decommissioned its legacy ‘Direct to APRA’ or ‘D2A’ data submission system.
Parliament – Bill passed relating to insurer genetic testing ban and other changes to financial framework regulation
On 1 April 2026, the Treasury Laws Amendment (Genetic Testing Protections in Life Insurance and Other Measures) Bill 2025 (Cth) passed both Houses of Parliament. As referred to in our Super Alert of 28 November 2025, the Bill makes the following changes which will impact the superannuation industry:
- ‘establish a ban which prohibits insurers from using certain information about an individual’s genetic testing to inform the offer of life insurance cover, or the terms and conditions of the cover that is offered’; and
- implement the Government’s decision not to proceed with Stage 2 of the financial adviser registration process established by the Better Advice Act, which would have required individual financial advisers to register themselves with ASIC annually from 1 July 2026.
Click here for details.
Parliament – Government report in relation to superannuation objective Bill
On 31 March 2026, the Government released its responses to recommendations made by the Senate Economics Legislation Committee in its final report relating to the Superannuation (Objective) Bill 2023 (now an Act). As referred to in our Super Alert of 5 April 2024, the Committee recommended that the Bill be passed and also that ‘the Government develop a whole-of-system retirement income system objective, outlining the objective of the retirement income system and the roles of the pillars, as suggested by the 2020 Retirement Income Review. Factors impacting home ownership in retirement should be considered as part of the development of this objective’. In relation to this second recommendation, the Government has confirmed that this has been noted, and that the ‘legislated objective of superannuation recognises that superannuation is one part of the retirement system’.
Click here for details.
Parliament – Government response in relation to recommendations for wholesale investor/client test
On 31 March 2026, the Government released its responses to recommendations made by the Parliamentary Joint Committee on Corporations and Financial Services in relation to the wholesale investor test for offers of securities (under section 708 of Chapter 6D of the Corporations Act 2001) and the wholesale client test for financial products and services (under sections 761G and 761GA of Chapter 7 of the Act).
As referred to in our Super Alert of 21 February 2025, the Committee’s two recommendations were as follows:
- Recommendation 1: ‘That the government consider establishing a mechanism for periodic review of the operation of the wholesale investor and client tests; and that any such mechanism include mandatory requirements for engagement and consultation with Australia’s investment industry.’
- Recommendation 2: ‘That, subject to a period of stakeholder consultation, the government amend the Corporations Act 2001 to remove the subjective elements of the sophisticated investor test and introduce objective criteria relating to the knowledge and experience of the investor.’
The Government has confirmed that both recommendations have been noted, and that it ‘is prioritising its response to the collapse of Shield and First Guardian Master Funds with a focus on strengthening consumer protections. The Government is considering targeted reforms to ensure our regulatory system remains fit for purpose and is consulting on these in 2026. This includes stronger regulation of lead generation activities, creating a safer framework for superannuation switching, strengthening superannuation trustee governance standards and enhanced oversight and governance of managed investment schemes’.
Click here for details.
ASIC – Sustainability reporting learning modules released
On 30 March 2026, ASIC released three education modules designed to ‘assist companies in understanding the core concepts behind the new sustainability reporting requirements in the Corporations Act 2001’. According to ASIC, the ‘e-learning modules are primarily aimed at Group 2 and 3 entities [this includes RSE licensees] that are not yet subject to the sustainability reporting requirements but are expected to commence sustainability reporting for financial years beginning on or after 1 July 2026’.
The three modules specifically cover:
- Module 1 – ‘how stakeholders should engage with the materials and introduces the basics of the new sustainability reporting requirements in the Corporations Act’;
- Module 2 – ‘the basics of climate change’; and
- Module 3 – ‘climate-related physical risks’.
Click here for details.
Legislation – AML/CTF transitional rules registered
On 30 March 2026, the Anti‑Money Laundering and Counter‑Terrorism Financing Transitional Rules 2026 were registered on the Federal Register of Legislation. The Transitional Rules are in effect as of 31 March 2026 and are designed to support the implementation of the AML/CTF reforms.
According to an associated web update from the Department of Home Affairs, the Transitional Rules include the following:
- Initial customer due diligence (CDD) – reporting entities may continue to use current ‘applicable customer identification procedures’ instead of the new initial CDD regime for up to three years, provided their AML/CTF programs reflect this, and specify when they will transition to the new CDD regime; and
- Compliance officer – reporting entities have until 30 May 2026 to notify AUSTRAC of the appointment of an AML/CTF compliance officer.
Click here and here for details.
Treasury – Draft regulations supporting superannuation advertising ban opened for consultation
On 27 March 2026, Treasury released an exposure draft of the Corporations Amendment (Ban on Advertising Superannuation Funds During Onboarding) Regulations 2026 for consultation. The regulations would support the Treasury Laws Amendment (Supporting Choice in Superannuation and Other Measures) Act 2026 which ‘introduces a ban on advertising superannuation products to new employees during onboarding’.
Employers can only show the employee’s existing stapled fund, the employer’s default fund or MySuper products during the employment onboarding process. The regulations would support the Act by providing detailed rules for the advertising of MySuper products. These rules will cover:
- ‘clear labelling’;
- ‘prominence of advertising’;
- ‘advertising arrangements’; and
- ‘general disclosures that must appear’.
The consultation period closes on 17 April 2026.
Click here for details.
APRA – Direct to APRA reporting system closed
On 27 March 2026, APRA announced that it has decommissioned its legacy ‘Direct to APRA’ or ‘D2A’ data submission system. The decision to take the system down from 20 March 2026 was reportedly made following the ‘identification of security vulnerabilities through a routine penetration test’. According to APRA, the measure is ‘precautionary’ and is consistent with ‘APRA’s low risk tolerance for system vulnerabilities that may expose APRA or regulated entities to attack’. APRA has confirmed it is not currently aware of any security breaches associated with its systems.
For entities that still use D2A, APRA recommends that they:
- ‘Immediately uninstall the D2A client. The presence of the D2A program could pose a residual risk. Removal is advised to protect your organisation’s data integrity and security.’
- ‘Review system and data security measures and undertake additional checks as a preventative measure.’
Click here for details.
ATO – Payday Super Regulation guidance released
On 27 March 2026, the ATO released guidance for trustees designed to explain how the impending Treasury Laws Amendment (Payday Superannuation) Regulations 2026 will impact funds from 1 July 2026.
The guidance provides that the key details in the Payday Super Regulations are:
- ‘Super funds will have 3 business days (reduced from 20 business days) to allocate or return super contributions’;
- ‘Confirmation of which types of payments are excluded from qualifying earnings (payments that don’t attract superannuation guarantee)’; and
- providing ‘details on how the administrative uplift amount, included within the super guarantee charge calculation may be reduced’.
Click here for details.
Want KHQ Super Alerts delivered straight to your inbox each week? Click here to subscribe.