Payday Super Readiness

To: All RSE licensees

In November 2025, the Australian Parliament passed Payday Super legislation¹, with a commencement date of 1 July 2026. In February 2026 the Payday Super Regulations were released.²

Payday Super represents an important reform for Australia’s superannuation system. This reform will help address the issue of unpaid superannuation, estimated by the Australian Taxation Office (ATO) to be over $6 billion in the last financial year.

Payday Super starts on 1 July 2026 and requires coordinated action from different participants in Australia’s superannuation system. This includes not only employers (whose superannuation guarantee obligations are administered by the ATO) and RSE licensees (regulated by APRA), but also administrators, gateways, digital service providers, clearing houses, registry providers, and others.

The ATO has separately noted the multifaceted changes required, and the concern raised that employers will not have had sufficient time to deploy, test and embed changes within their payroll systems and business processes prior to the Payday Super law commencing.³ This letter focuses on the role of RSE licensees specifically, while also acknowledging the importance of, and dependencies with, other system participants.

Roles of the ATO and APRA

The ATO is the lead regulator for implementation of Payday Super. APRA is supporting the ATO in this role, in regard to the responsibilities of RSE licensees. Specifically:

• under Part 3B of the Superannuation Industry (Supervision) Act 1993 (SIS Act), the ATO may determine superannuation data and payment standards (SuperStream) applicable to RSE licensees and employers;
• the Superannuation Industry (Supervision) Regulations 1994 (SIS Regulations) include provisions governing the allocation of contributions by RSE licensees; and
• for compliance with these standards and regulations, the ATO has administrative responsibility in regard to employers, and APRA generally has administrative responsibility as regards to RSE licensees.

The ATO and APRA are working together with an aligned regulatory approach with respect to RSE licensees in the context of Payday Super.

Implementation readiness

Under new regulations, relevantly, RSE licensees must from 1 July 2026 receive and allocate superannuation contributions made by employers to member accounts, or return those contributions, within three business days of receipt.⁴  This change is a foundational component of Payday Super, however, it represents a significant acceleration compared to currently applicable timeframes.

In addition, in July 2025 the ATO finalised the new SuperStream 3.0 standard, which is to commence on 1 July 2026. SuperStream 3.0 is designed to support Payday Super requirements, with key changes including:

• improved verification and error messages, including a Member Verification Request service, to allow an employee’s super fund details to be confirmed prior to contributions being made. The ATO considers the Member Verification Request service key to reducing errors that delay timely allocation of contributions; and
• approval of the New Payments Platform as a payments method, to enable rapid payment.

The ATO with APRA’s support is jointly monitoring RSE licensee readiness. Whilst there is a strong industry commitment to Payday Super, the ATO is concerned that a material number of RSE licensees are not currently on track to deliver all elements of SuperStream 3.0, particularly the key Member Verification Request service.

Next steps

RSE licensees are reminded that:

• the commencement date for Payday Super has been set by Parliament to be 1 July 2026, and RSE licensees have a key role supporting a successful transition alongside other system participants;
• significant breaches relating to Payday Super requirements commencing 1 July 2026 would necessitate a breach notification to APRA⁵; and
• APRA would expect processing of contributions to be part of an RSE licensee’s critical operations, and accordingly be subject to the requirements of Prudential Standard CPS 230 Operational Risk Management.

The ATO and APRA expect relevant RSE licensees to revisit their implementation timelines where necessary, working with their respective counterparties and broader system participants. The ATO and APRA will also engage further with relevant RSE licensees directly regarding their implementation readiness.

Yours sincerely,

Footnotes

¹ Treasury Laws Amendment (Payday Superannuation) Act 2025 (Cth); Superannuation Guarantee Charge Amendment Act 2025 (Cth).

² Treasury Laws Amendment Payday Superannuation Regulations 2026 (Cth).

³ See, ATO’s Practical Compliance Guideline PCG 2026/1 for employers, January 2026. 

⁴ The ATO and APRA are aware of RSE licensees raising with Treasury the application of new regulation 7.07G of the SIS Regulations (set to come into effect from 1 July 2026), particularly as regards to the processing of certain contributions that are not required to be accompanied by SuperStream data. Treasury has confirmed that a technical amendment to the Regulations is planned. In these circumstances, APRA is not planning to prioritise supervisory attention to the processing of such contributions pending such technical amendments being progressed and finalised.

⁵ Refer to section 29JA of the SIS Act.