A federal government proposal to require every new self-managed super fund to have a written Investment strategy from day one is drawing pointed criticism from the SMSF sector. The measure is not law, and its full detail has not been released. But with the SMSF Association and a leading audit firm questioning whether it would work in practice, trustees may want to understand what has actually been proposed, what critics are saying, and what still applies under current rules.

Where the proposal came from

The measure was announced on 19 August 2026 by Daniel Mulino, the Assistant Treasurer and Minister for Financial Services, in an address to the National Press Club.

It sits within a broader package of consumer protections for the SMSF sector.'s report of the announcement, the package followed losses of more than $100 million by SMSF investors after the collapse of the Shield and First Guardian master funds.

A Treasury fact sheet released with the speech lists the investment strategy change as one of seven SMSF measures. It describes improving the Utility and integrity of SMSF investment strategies by requiring funds to have a written strategy upfront, and consulting on Options to uplift the quality of strategies more generally.

What the government has and has not said

The fact sheet does not set a start date, a consultation timetable or draft legislation for the measure. It also does not explain what extra content, if any, a strategy would need to contain.

Industry analysis noted that and that final rules have not been released.

SMS Magazine's reporting describes the proposal as trustees providing a written strategy to the ATO at the time the fund is established. How that lodgement would work, and what the ATO would do with the document, has not been published.

Other measures in the package include mandatory education for new trustees, ATO powers to block rollovers into new funds during Fraud or misconduct investigations, disclosure of advisers involved in establishment, and a supervisory levy increase from $259 to $295. These are also proposals, not enacted law.

What critics are saying

The strongest criticism so far was aired at the ASF Audits Technical Summit 2026 in Adelaide, as reported by SMS Magazine on 21 September.

SMSF Association chief executive Peter Burgess questioned whether the measure suits the way SMSFs are regulated. His central point was that the ATO, unlike a prudential supervisor, does not control where a fund invests. "The ATO is not a prudential regulator of the SMSF sector," he said.

Burgess also argued that a snapshot of a new fund's portfolio can be misleading. A fund may appear concentrated at the outset, for example with a large share of its balance in one property. But once the trustees' Wealth outside super and plans to diversify using future contributions are taken into account, the position may be reasonable.

Jo Hurley, head of technical at ASF Audits, raised a practical timing problem. She said investment strategies are constantly evolving, and that trustees may not have fully settled their strategy before the fund is even set up and money has been rolled in.

Support with conditions

The criticism does not mean the sector rejects reform outright. SMS Magazine reported on 25 August that the SMSF Association supported most of the package, including the investment strategy measure in principle.

However, the association wanted more detail on how the requirement would be implemented. It also argued that better access to advice for prospective trustees should form part of the discussion, and it opposed a one-size-fits-all approach to mandatory Trustee education.

Technical guidance states that many trustees may already comply with the headline requirement, and that the more important question is whether strategies are tailored and genuinely used, rather than existing only as a compliance document.

What the current law already requires

Regardless of how the proposal develops, SMSF trustees already have an investment strategy obligation under the Superannuation Industry (Supervision) Regulations 1994.

Regulation 4.09 requires trustees to formulate, regularly review and give effect to a strategy that considers the fund's whole circumstances. That includes risk and likely return, diversification, liquidity, the fund's ability to pay benefits and other liabilities, and whether to hold insurance cover for members.

In other words, the existing rules already expect a strategy that reflects how the fund is actually invested. The proposed change appears aimed mainly at timing and integrity, rather than creating the obligation for the first time.

What trustees may want to consider

Because the measure is still a proposal, there is nothing new trustees are legally required to do today as a result of the announcement. Existing funds and those being set up now remain subject to the current regulation.

That said, the debate may be a useful prompt. Depending on their circumstances, some trustees may wish to check whether their strategy is documented and reflects the fund's real holdings, and whether any concentration in one asset, such as property, is explained with reference to members' broader position.

Others may consider when the strategy was last reviewed, whether a significant event has occurred since, and whether insurance for members has been considered and recorded.

Trustees establishing a fund soon may also wish to monitor Treasury consultation, where detail is expected to emerge.

The bottom line

The government has proposed that SMSFs have a written investment strategy upfront, with further consultation on strategy quality, as part of a wider response to recent investment scheme failures. The SMSF Association and ASF Audits have questioned whether the measure fits the ATO's role and how it would work before a fund's portfolio is settled. No legislation or start date has been released. For now, regulation 4.09 remains the governing requirement, and the final shape of any reform will depend on consultation.