Highlights

  • Treasury closed a consultation on managed investment scheme data collection reforms on 23 October 2026.
  • The Shield and First Guardian collapses affected approximately 12,000 people and around $1 billion in funds.
  • The SMSF Association opposes any new reporting burden placed directly on SMSF trustees through MIS reform proposals.
  • Wholesale investor tests remain unchanged at $2.5 million net assets or $250,000 annual income thresholds.

Treasury's consultation on managed investment scheme data collection closed on 23 October 2026. The review was prompted partly by the collapses of Shield Master Fund and First Guardian, which left approximately 12,000 people and around $1 billion in funds affected. The outcome could impose new obligations on SMSF trustees who invest in MIS structures.

Background: The Collapses That Prompted the Review

The Shield Master Fund and First Guardian collapses demonstrated gaps in data visibility over managed investment scheme participants and asset flows. With approximately 12,000 people and around $1 billion affected, the failures highlighted how limited regulators' real-time information was when schemes encountered difficulty.

Three proposals are under consideration in the consultation. The precise terms of each proposal are set out in the consultation paper. The SMSF Association submitted that none of the proposals should place additional data reporting obligations directly on SMSF trustees, arguing this would impose administrative burden on trustees who are already subject to extensive ATO reporting obligations.

Industry Positions

The Financial Advice Association Australia has taken a different position, arguing that all managed investment schemes should be required to register, not only those offered to retail investors. This would extend registration requirements to unregistered wholesale schemes, which currently operate with fewer regulatory touchpoints.

The divergence in industry views reflects the tension between broadening data collection to improve regulatory visibility and avoiding additional compliance costs on existing participants, including SMSF trustees investing in MIS products through their funds.

Wholesale Investor Thresholds Unchanged

The wholesale investor tests remain at their existing thresholds: $2.5 million in net assets or $250,000 in annual gross income. These tests determine which investors can access unregistered wholesale managed investment schemes without the consumer protections that apply to retail products. The consultation does not propose changing these thresholds.