MySuper authorisation - frequently asked questions

Updated: January 2026

These FAQs are published for discussion purposes only. The content of these FAQs is not legal advice. Users are encouraged to obtain professional advice about the application of any legislation or prudential standard to their particular circumstances. Users should exercise their own skill and care when relying on any material contained in the FAQs. APRA disclaims any liability for any loss or damage arising out of any use of or reliance on these FAQs. The FAQs may include links to external websites that are beyond APRA’s control. APRA accepts no responsibility for the accuracy, completeness or currency of the content of these FAQs.

The numbering of these questions is fixed and will not change as new questions are added.

MySuper - General and product features

5. Can there be different investment fees for lifecycle products across different stages of the lifecycle

An RSE licensee can charge different investment fees for up to four age ranges of members with an interest in a lifecycle MySuper product. This does not prevent the RSE licensee from structuring the lifecycle strategy with more than four sets of asset allocation.

7. Will members who have a MySuper product, and a separate non-MySuper interest, in the same fund need to have two accounts with separate statements

No, a single account can cover both MySuper and choice interests, just as it can cover both defined benefit and defined contribution interests.

15. What different arrangements for administration fees for employers will be allowed for authorised MySuper products

Within a single MySuper product, administration fees can be varied in accordance with the administration fee exemption for employees of an employer-sponsor. This provides that a different administration fee can be charged in relation to employees of a contributing employer-sponsor or associate of that employer-sponsor and relatives or dependants of those employees. The administration fee in respect of those members must be charged on the same basis for the group. It must be no less than the cost of administration and operation of the fund in relation to that group of members.

For further information, see s. 29VB of the Superannuation Industry (Supervision) Act 1993.

23. Can a large-employer MySuper product be 'white-labelled' for another non-associated large-employer product

No. A non-associated large employer will need to have its own authorised MySuper product or use a generic MySuper product.

30. Can RSE licensees choose not to provide death and total permanent disability insurance on an opt-out basis to certain categories of members

Certain groups of members may be excluded from insurance cover on the basis of ‘reasonable conditions’. APRA would expect reasonable conditions to be based on the RSE licensee’s assessment of the availability and cost of third-party insurance cover, for example, in relation to age or pre-existing medical conditions. In APRA’s view, RSE licensees cannot choose to exclude broad categories of members, such as those who do not have a standard employer-sponsor, from being provided with death and TPD insurance on an opt-out basis unless they can demonstrate that third party insurance which includes the specified group is not available, or is not available at a reasonable cost.

In any assessment of reasonable conditions, the RSE licensee remains bound by its obligation to promote the financial interests of members with an interest in the MySuper product and its general covenants to perform its duties and exercise its powers in the best interests of the beneficiaries, and to act fairly in dealing with beneficiaries within each class of membership, including MySuper. The same obligations and considerations also apply when an RSE licensee is selecting and negotiating insurance.

For more information, see s. 68AA and paragraphs 2.14-2.22 of the Explanatory Memorandum to the Superannuation Legislation Amendment (Further MySuper and Transparency Measures) Bill 2012.

33. If the investment strategy underlying a MySuper product is a lifecycle investment strategy, can a member choose to be in a particular stage of the lifecycle strategy

No. If an RSE licensee offers a lifecycle investment strategy, the RSE licensee may vary the method of crediting investment returns to a member's account only on the basis of the member’s age (and other factors if prescribed, see s. 29TC(2) of the Superannuation Industry (Supervision) Act 1993). It will be a matter of fact which stage of the strategy a member is in at any point in time and therefore no member choice is permissible.

36. Can an exemption be granted from the payment of insurance premiums and fees for casual employees in MySuper

The 'reasonable conditions' flexibility inherent in s.68AA ensures that an RSE licensee can have casual employees as members within their MySuper product but offer them no or different insurance as part of the RSE licensees' group life and TPD policies. This means there is no need for an exemption. The insurance fee is to be charged on a cost-recovery basis.

If casual employees are permitted to join the MySuper product with a differently structured insurance offering, they should be charged an insurance fee which meets the costs of that offering.

44. Under MySuper, switching fees can only be charged to the individual member that has requested a switch i.e. cost recovery. Can a switching fee be embedded in an administration fee

RSE licensees are permitted to apply a switching fee on a cost recovery basis to the extent that the cost is not covered by the administration fee. The standard administration fee may, for example, allow for a limited number of switches, with any additional switches being charged on a cost-recovery basis.

46. As part of a MySuper application can an RSE licensee submit a board-approved, amended trust deed initially and provide a copy of the executed trust deed later

At the time of lodgement, MySuper applications must include an up-to-date executed copy of the trust deed or governing rules. APRA does not necessarily expect that the RSE licensee can provide, in all cases, a consolidated deed, but the RSE licensee must provide an executed amending deed which effects the necessary changes to the trust deed. APRA may request a complete copy of the executed trust deed or governing rules if required. RSE licensees may choose to discuss draft amending deeds with APRA during consultation prior to lodgement.

48. Is attaching a copy of legal advice a sufficient statement under A5.1 of the MySuper application form

No. Where an RSE licensee has received legal advice in regards to how the Trust Deed or Governing Rules comply with the requirement in s29TC(1), the RSE licensee should attach that legal opinion. However, APRA also expects the RSE licensee to set out its own understanding, in its own words, of how the Trust Deed or Governing Rules comply with the requirement in s29TC(1).

49. Question B2.5 of the MySuper application form states, 'for each relevant fee category identified at items B2.3 and B2.4, attach a description of the mechanism by which the RSE licensee will establish that the fees charged do not exceed cost recovery.' Question B2.3 includes the option of an advice fee, which can exceed cost recovery. How should question B2.5 be answered for advice fees

Question B2.5 states 'for each relevant fee category'. Since an advice fee does not need to be limited to cost recovery, it is not a relevant fee category and does not need to be included in the response to question B2.5.

50. What are APRA's requirements in relation to changes in policies associated with a MySuper authorisation application? Are they required to be submitted to APRA when a change is made by the RSE licensee

Until the authorisation process is complete, an applicant needs to comply with its attestation C2(c) in the application form that ‘it will notify APRA of any changes to the information contained in the application as soon as practicable.

57. What categories of fees must, if imposed in a MySuper environment, be set at a level that is no greater than a cost recovery basis

If an RSE licensee charges buy-sell spreads, switching fees, exit fees, activity fees and insurance fees in a MySuper environment, sections 99C and 29VC of the SIS Act require them to be charged at no more than a cost recovery basis. In other words, the amount charged to MySuper members for these fees must be no more than an amount that recovers the cost to the RSE licensee of providing the service.

58. How can an RSE licensee charge buy-sell spreads, switching fees, exit fees, activity fees and insurance fees on a cost recovery basis to MySuper members if the activity is performed by an outsourced provider and the charge to the RSE licensee in relation to the activity is embedded within an aggregate fee

An RSE licensee using an outsourced provider must identify the component of the aggregate fee paid to the outsourced provider that relates to the specific activity. This would be expected to be based on calculations provided to the RSE licensee by the service provider. As a matter of sound practice, APRA expects that the relevant charge would be a separately identified cost when the relevant agreement is next negotiated.

59. Can an RSE licensee introduce buy-sell spreads, switching fees, exit fees, activity fees and insurance fees on a cost recovery basis to a MySuper product without a corresponding reduction to the administration and/or investment fee charged to members

An RSE licensee is permitted to charge buy-sell spreads, switching fees, exit fees, activity fees and insurance fees at a rate no more than a cost recovery basis to MySuper members. These fees can only be charged if the cost is not covered by the administration fee and/or investment fee (subsections 29V(2) and (3)). If the relevant service is provided in-house or by a third party on a fee for service basis, the RSE licensee will be able to calculate the cost of provision, and set the fee accordingly.

60. Where a MySuper product offers a lifecycle strategy, can different buy-sell spreads be charged for each life stage

No. Where an RSE licensee chooses to charge a buy-sell spread, the fee charged must apply to every member of the MySuper product. If this fee is charged as a percentage of a member’s account, the percentage charged must be the same for every other MySuper member, regardless of their stage in the lifecycle.

Charging a fee on a cost-recovery basis means that the total amount of the fee charged to all MySuper members should recoup the cost incurred by the RSE licensee for providing the services to which the fee relates.

It should be noted that an RSE licensee is not required to charge a buy-sell spread. Where a reasonable basis of applying cost recovery cannot be determined, an RSE licensee has the option of charging these costs via the administration or investment fee.

MySuper Insurance

41. Can an RSE licensee choose to use a different insurer for a particular employer plan (including MySuper members and choice members), without the use of a 29TB tailored MySuper product

APRA considers that the use of different insurers is permitted by the legislation.

42. Can an RSE licensee stipulate that a member can have life and TPD cover, but cannot opt out of only life cover

RSE licensees may require members who wish to make an election in accordance with s. 68AA(5) to opt out of both life and TPD insurance. However, there is nothing prohibiting an RSE licensee from offering an option to opt out of TPD only and retain life insurance, or to opt out of life only and retain TPD.

51. Can permanent incapacity insurance on an ‘own occupation’ basis be used to support the provision of permanent incapacity benefits to a MySuper member under s 68AA of the SIS Act

Generally, yes. ‘Own occupation’ insurance covers a person who is unable to perform the functions of their own occupation, even if they are able to perform in other occupations for which they are reasonably qualified. Section 68AA (read with the definition of ‘permanent incapacity’ in section 10(1) and regulation 1.03C) requires the provision of permanent incapacity benefits on an ‘any occupation basis’ – that is, where the RSE licensee is reasonably satisfied that the member is unlikely to engage in gainful employment for which the member is reasonably qualified by education, training or experience. ’Own occupation’ insurance is therefore more generous than ‘any occupation’ insurance. If a member becomes permanently incapacitated on an ‘any occupation’ basis, they usually will also be unable to undertake their own occupation at the time of injury. Accordingly, they would ordinarily be entitled to a payout under the ‘own occupation’ policy, thus enabling the trustee to satisfy the obligation in s 68AA (in relation to MySuper members). However, where the member is only permanently incapacitated on an ‘own occupation’ basis, and is or will be capable of working in an occupation for which they have skills, training and experience, the ‘permanent incapacity’ condition of release will not be satisfied, and the benefits will not be able to be released from the fund on the basis of that condition. Note that SIS Regulation 4.07D requires the phasing out of ‘own occupation’ benefits, unless the member has had this coverage on a continuing basis since before 1 July 2014.

52. If the insurance policy includes additional benefits (e.g. benefits for loss of limb, even where this does not result in permanent incapacity on an ‘any occupation’ basis), can the policy be used to support the provision of permanent incapacity benefits to a MySuper member under s 68AA of the SIS Act

Yes, the policy can be used to support the provision of permanent incapacity benefits to MySuper member under s 68AA of the SIS Act, provided it also covers permanent incapacity. For example, a policy that provides for benefits upon (a) ‘any occupation’ permanent incapacity; or (b) loss of limbs; or (c) loss of cognitive function may be used to meet the requirement in s 68AA to provide ‘any occupation’ permanent incapacity benefits because of benefit (a), despite additional benefits (b) and (c) being available under the policy. However if the member becomes entitled to an additional benefit, but is or will be capable of working in an occupation for which they have skills, training and experience, the ‘permanent incapacity’ condition of release will not be satisfied, and the benefits will not be able to be released from the fund on the basis of that condition. Note that SIS Regulation 4.07D requires the phasing out of these kinds of additional benefits, except where the member has had this coverage on a continuing basis since before 1 July 2014.

53. If an insurance policy in respect of permanent incapacity provides for a waiting period (e.g. that in order to be considered for a permanent incapacity benefit, the MySuper member has to be unable to work for a qualifying period of X months), and this is reflected in the terms and conditions upon which the benefit is provided by the fund, will this be a ‘reasonable condition’ within the meaning of s 68AA of the SIS Act

Generally yes, because the condition imposed by the fund (i.e. the waiting period) will be the same as the condition in the policy of insurance taken out to provide the benefit; as a result it will be a ‘reasonable condition’ under subsection 68AA(4). However, RSE licensees need to consider whether agreeing to such a policy is consistent with their general covenants and duties (see ss 29VN and 52) in particular whether the length of the waiting period is justified as ‘reasonable’.

55. Where non-conforming insurance is grandfathered by SIS regulation4.07D, because the member was covered by the insurance prior to 1 July 2014 and continues to be so covered, can the amount of coverage be increased

Yes. As noted in the Explanatory Statement to Superannuation Legislation Amendment Regulation 2013 (No 1), from 1 July 2014 the exemption under subregulation 4.07D(3) cannot be used to provide a member with a type of cover they did not have prior to 1 July 2014. However, a member can vary their level of cover from 1 July 2014. For example, subject to the governing rules, the cover could be increased or decreased, and associated premiums adjusted, after 1 July 2014.

56. If the member is covered by non-conforming insurance in fund A prior to and after 1 July 2014 on a continuing basis, and is successor fund transferred to fund B after 1 July 2014, will the non-conforming benefit continue to be grandfathered in fund B under regulation 4.07D

As noted in the Explanatory Statement to Superannuation Legislation Amendment Regulation 2013 (No 1), the grandfathering still applies if the member is transferred to another fund under the successor fund transfer rules. The new fund will be able to offer the same insurance benefits as were available to the member in former fund.