APRA consultation - strengthening superannuation investment governance (draft SPS 530)
On 30 September 2026, APRA released a consultation paper and a draft rewrite of SPS 530 Investment Governance. It replaces a largely principles-based standard with more prescriptive requirements. APRA’s stated focus is platform trustees and member-directed investment, following its 2025 review of platform trustees and the Shield and First Guardian collapses, but the requirements would apply to all RSE licensees. Submissions close on 3 February 2027, APRA expects to finalise the standard (with draft guidance) in the first half of 2027, and the proposed start date is 1 January 2028.
What’s in this article:
By our reading, this is a significant change for any fund offering member direct investment options (shares, ETFs, managed funds, LICs, term deposits), and particularly for platforms. Submissions are not due until 3 February 2027, so there is still time to work through the detail and decide whether you want to respond. Our summary follows, but we don’t have the official word on this, so please make sure to reach out to APRA with any confirmations.
What would change
1. Member-level investment limits (the biggest change)
Every member direct investment option would need a limit on how much of a member’s balance can be invested in it, checked whenever a member buys, contributes, transfers or switches into the option. The limit is the lower of your own limit and an APRA maximum, currently shown in the draft as a placeholder of [20-30]% of the member’s balance. An option is excluded only if you are satisfied it is highly liquid, does not use significant leverage, is highly diversified or otherwise low risk, and (where an external party manages or oversees it) that party is well established and well capitalised. Limits apply to advised and unadvised members alike. Members would not be forced to sell where market movements push them over a limit.
2. Onboarding, monitoring and remediation
You would need documented onboarding criteria (covering risk, returns, fees, valuations, liquidity, stress testing, external research and ratings, the external manager and conflicts), with a documented assessment before an investment or option is added. Every option would then be monitored against the same criteria, along with warning signs such as strategy changes, governance concerns, adverse news and unusual fund or adviser flows. Options raising concerns go on a watch list, and you would need pre-set tolerances and triggers, with time-bound action plans when a trigger is met. Where members remain in an option with material or persistent concerns, you would need to take all reasonable steps to obtain their active consent to stay.
3. Capability and menu size
You would need to assess at least annually (and after any material change) whether your capability, resources and systems match the number, complexity and risk of the options you offer, set limits on the size and complexity of your menu, and not offer more options than you can effectively oversee.
4. Third-party conflicts
You would need to identify and assess, on an ongoing basis, conflicts involving promoters, advisers and other third parties that provide services to you or seek to influence you, and ensure they do not influence decisions to offer, monitor or remove investments unless you can show the conflict is effectively mitigated or managed and that it could not affect your ability to comply with your legal and prudential obligations.
5. Valuations at least quarterly
Investments would need to be valued at least quarterly. Current guidance allows less frequent valuation where justified; the draft removes that option. APRA could also direct you to obtain a valuation from an independent external party where it has reasonable grounds to believe an existing valuation is not reliable and that an external valuation would be in members’ interests.
6. Annual attestation
The executive accountable for your investment function under the Financial Accountability Regime would need to attest each year that you have complied with investment governance requirements, and you would need to have regard to the attestation when setting variable remuneration.
How much of this is new?
Most of the onboarding, monitoring, remediation and valuation requirements turn existing SPG 530 guidance and APRA’s October 2025 letter to platform trustees into binding rules, so if you already follow that guidance you will have less to do. The genuinely new elements are the member-level limits, menu limits, third-party conflicts, active consent, the attestation, and new APRA powers (to require an independent review, change your remediation triggers, or direct an external valuation).
Points you may want to raise in your submission
7. Transition arrangements (questions 18 and 19)
The draft has no transitional provisions. APRA has not yet set transition arrangements: it asks about commencement and transition in questions 18 and 19, so you need to ask if you want arrangements. With the final standard due in the first half of 2027, you may have only 6-12 months before 1 January 2028. As drafted, everything would apply from that date, including limit checks on every transaction, monitoring of every existing option against the new onboarding criteria, any reduction in menu size, quarterly valuations and the first attestation. Existing holdings above a limit would not have to be sold. Possible requests include a phased start, a period to review existing menus, a first attestation covering the first full year, and lead time for valuation changes.
8. Term deposits and the exclusion test
APRA’s consultation paper lists term deposits among the options it expects to meet the exclusion test, but the draft’s test requires an option to be “highly liquid” (a term the draft does not define), and the draft names term deposits as an example of a member direct investment option. Depending on their break and notice terms, term deposits may not meet that test, in which case they would need limits. Annuities raise the same question if offered as a member direct option. This is worth asking APRA to clarify.
9. An onboarding override
The draft allows an investment that fails your onboarding criteria to be added if a Board committee or an operationally independent senior manager approves it (para 41). This is not described in the consultation paper, and APRA’s October 2025 letter described better practice as approvals “only granted where defined acceptance thresholds are met”.
10. Active consent
The consultation paper says trustees would be required to obtain active member consent, with members informed of the concerns. The draft only requires “all reasonable steps” to obtain consent, and does not say members must be told what the concerns are or what happens if consent is not given.
11. Overlap with draft CPS 510 Governance
APRA’s separate draft CPS 510 Governance, which would replace SPS 521 Conflicts of Interest, is also drafted to start on 1 January 2028. It frames conflicts around the trustee’s own duties and interests, and requires conflicts to be avoided where they cannot be effectively managed, with a conflicts register and an annual independent review of the conflicts policy. The draft SPS 530 frames third-party conflicts around the third party’s interests, applies a different test, and does not refer to CPS 510. As drafted, you could be running two conflicts processes with different definitions and tests, and no clear rule on which register applies.
12. Undefined terms
Several terms that decide how far the requirements reach are not defined, including “external party”, “investment menu”, “highly liquid”, “significant leverage”, “highly diversified” and “material or persistent concerns”.
13. Calibration questions
APRA is specifically asking whether the 20-30% maximum is right (question 10), whether your exposure should be aggregated across several higher-risk options (question 11), and whether your systems could support the thresholds, triggers and monitoring proposed (question 12). Question 13, on reporting long-running watchlist items, is covered in item 17.
Reporting considerations
We have also compared the draft with the superannuation reporting standards. These points may affect how you report, and we are looking at whether to raise them with APRA ourselves.
14. Investment caps are already reported
SRF 605.0 already collects an “investment cap” for each investment option and investment menu (leave blank where there is no cap). The draft creates “member-level investment limits” without referring to these fields. If limits become mandatory, it is not clear whether the caps you report are meant to be your SPS 530 limits, a blank cap would no longer distinguish an excluded option from a missing limit, and where you aggregate direct shares, term deposits, hybrids or fixed income options, only the lowest cap is reported.
15. Internally and externally managed are defined differently
For reporting, SRS 101.0 defines an internally managed investment option, for SRF 551.0 and the SRF 553 forms, as one where you or a connected entity set its investment strategy, drawing on the management type and strategy setting fields you report in SRF 605.0. The draft SPS 530 instead asks who selects the investments, and makes no distinction for connected entities. Options managed by a manager in your own group (a connected entity), or multi-manager options where you set the asset allocation but external managers pick the investments, could be classified one way for reporting and another way for SPS 530.
16. Valuation cycle
If you currently report any investments in SRF 553.1 with a valuation cycle less frequent than quarterly, those would be affected by the quarterly minimum. It is not yet clear exactly how the requirement applies to investments held through externally managed pooled vehicles.
17. Possible reporting of long-running watchlist items (question 13)
APRA is considering whether trustees should report to APRA on investments that remain on a watchlist for more than 12 months, and is asking for feedback on the benefits, implementation challenges and unintended consequences (question 13). No existing reporting standard defines or collects watchlist information, so this would be a new data collection. The draft requires you to keep a watch list (para 47) but does not set criteria for when an investment goes on or comes off it, or how time on it is measured. If you respond to question 13, you may want to comment on how those terms would be defined, whether existing identifiers (such as the Investment Option Identifier and Investment Identifier) would be reused so the data links to what you already report, and the likely cost of building the reporting.
Next Steps
There is still some time before submissions close on 3 February 2027. Let us know if you have any questions, or would like to discuss any of these items in further detail, including how they might affect your own reporting.
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