Key Highlights

  • The 2026 return makes the deductible and non-deductible auditor fee labels (H1 and H2) mandatory.
  • Modified audit opinions are now reported more clearly in the instructions.
  • The ATO page has no dedicated final-return date, so trustees should confirm their own lodgment date.

Every self-managed super fund must lodge an annual return each financial year, even when it owes no tax. A fund that is closing is no different: the last return is the signal that tells the ATO the fund has wound up. With the 2026 return now available, trustees preparing a closing return have a few extra things to check.

What the ATO says about the 2026 return

The ATO's SMSF newsroom confirms the 2026 SMSF annual return and its instructions are available and relate to the 2025–26 year. The instructions run through sections A to K, covering fund information, income, deductions, tax calculation, losses, member details, assets and liabilities, financial arrangements, other information and declarations. The ATO page was last updated on 12 June 2026 and advises trustees to check for changes in fund structure, investments or member contributions as they complete the form.

A separate ATO notice published on 19 June 2026 describes two changes that affect audit reporting. First, the deductible and non-deductible auditor fee labels (H1 and H2) are now mandatory. In the ATO's words, the labels can no longer be left blank or reported elsewhere on the return; if only one applies, the other should be reported as zero. Second, the instructions now state more clearly that all modified opinions in the independent auditor's report, including qualified, adverse and disclaimer opinions, should be reported on the return. The ATO says the aim is better visibility of audit fees and more consistent reporting.

When is the return due?

The ATO's lodgment page, last updated on 24 August 2026, sets out the general pattern. Self-lodged returns for newly registered funds, or for overdue prior years, are due on 31 October, with any amount owing payable by 1 December. Other self-lodged returns are due on 28 February, unless the ATO has asked the fund to lodge on a different date. Funds using a tax agent follow the dates the agent receives under the lodgment program. If a due date falls on a weekend or public holiday, the next business day applies.

The page has no dedicated section on a final return date. Trustees closing a fund should therefore confirm the date that applies to their fund with the ATO or a registered tax agent, particularly if earlier returns are overdue. Overdue returns need attention first, because the ATO's wind-up guidance says trustees must lodge all outstanding returns as well as the final one.

What is different about a final return

According to the ATO's wind-up guidance, trustees confirm the wind-up date on the return and that all lodgment and payment obligations are met. They also complete the supervisory levy adjustment for wound-up funds. The lodgment page explains that a winding-up fund does not pay the levy if it paid it in the previous financial year, and that Label M lets a fund that wound up during the year adjust the levy so it is not charged for the following year.

Importantly, the ATO says all other reporting should be finished before the final return, including transfer balance account reporting and payment summaries for retirement benefits paid. The final audit must also be done by an approved SMSF auditor before lodgment.

Practical points for trustees

Plan the audit timetable first. The ATO's guidance for new funds says an auditor should be appointed at least 45 days before the lodgment due date, and a fund that is closing has no reason to be less careful. Late engagement is a common cause of last-minute stress.

Check that the auditor's fees are recorded at the right labels. Because H1 and H2 are now mandatory, a return prepared from last year's template may be incomplete.

Consider how long the paper process takes if lodging on paper. The ATO notes paper returns can take up to 50 days to process, and a fund's status on Super Fund Lookup can change to 'regulation details removed' if returns are not processed on time. That can interfere with rollovers and contributions, which matters if benefits are still moving.

Finally, keep enough money in the fund. The ATO's wind-up page recommends retaining enough cash for post-lodgment costs such as audit fees, professional fees and tax. Trustees should not close the bank account until the ATO has confirmed the wind-up and any refund has arrived.

Hypothetical example

Imagine two trustees who sell their last asset in August and want to close before Christmas. They would need the final-year financial statements, a completed audit, any overdue returns, and a final return recording the wind-up date and levy adjustment. This is a hypothetical illustration only.

Takeaway

The final annual return is the formal end point of an SMSF, but it depends on everything before it. For 2026, the notable form changes are the mandatory auditor fee labels and clearer reporting of modified audit opinions. Trustees should confirm their own lodgment date rather than assume one, and keep the bank account open until the ATO confirms closure.