Delivering Better Financial Outcomes - Tranche 2: HSF submission

On 21 March 2025, Treasury released exposure draft legislation for consultation, proposing amendments to a number of statutes in response to the Quality of Advice Review. This exposure draft is the Government’s second tranche of financial advice reform.

Our team has made a formal submission on this consultation.

In summary, our submission addresses:

• the proposed changes to section 99F for the Superannuation Industry (Supervision) Act 1993 (Cth), to clarify when trustees can collectively charge for intra‑fund advice, with our recommendation to remove this section entirely;
• the introduction of a Targeted Superannuation Prompt regime, which, in our view, will likely have a low uptake amongst trustees due to the detailed and onerous requirements of meeting the regime, and potential significant consequences of breaches; and
• the proposed replacement of the current Statement of Advice requirements with a new Client Advice Record, which, in our submission will inevitably encounter the same issues identified with the current regime – namely, result in lengthy documents that are challenging for clients to understand.

While it is commendable that these proposals have been formulated as it demonstrates the Government’s attention to real issues that face the sector, in our view, the proposed amendments do not go far enough to address the aims set out in the Explanatory Materials, nor are they consistent with the Quality of Advice Review Final Report. The proposed amendments run counter to the need for simple laws which foster better engagement with superannuation members. In short, they do little to reduce the regulatory burden on those who provide advice and are unlikely to make such advice more cost-effective or accessible.

If you would like to read a copy of our submission, download a copy here.

If you have any questions, get in touch with one of our experts below.