Compliance checks are a normal part of operating a self-managed super fund, but 2026 brings additional areas for trustees to consider. The introduction of Division 296, increased attention on asset valuations, stronger auditor focus and ongoing rollover verification processes all increase the importance of accurate records and evidence.

For SMSF trustees, the practical impact is that familiar compliance requirements may now have broader consequences. Understanding why these areas are receiving more attention can help trustees prepare rather than respond after issues arise.

Division 296 raises the stakes on valuations

A major reason compliance checks matter more in 2026 is the introduction of Division 296, which applies an additional tax on Earnings attributable to portions of an individual’s total Superannuation balance above certain thresholds.

Division 296 commenced on 1 July 2026, making the 2026–27 financial year the first affected income year.

An additional 15% tax applies to the portion of earnings attributable to balances between $3 million and $10 million, resulting in an effective tax rate of up to 30% on that portion. A further additional 10% applies to the portion above $10 million, resulting in an effective tax rate of up to 40% on that portion.

For 2026–27, relevant calculations rely on total superannuation balance information at 30 June 2027.

Because total superannuation balance depends on the value of fund assets, accurate valuations become increasingly important. An unsupported valuation does not only affect financial statements; it may also influence an individual’s tax position where Division 296 applies.

This connection is one reason asset valuation evidence has become a key compliance consideration.

The ATO’s sharpened auditor focus

For 2026–27, the ATO has highlighted several SMSF auditor compliance focus areas.

Market valuations of fund Assets are a key area, particularly where valuations affect broader superannuation measures such as Division 296.

Auditor independence is another focus. SMSF auditors must maintain appropriate independence and comply with professional standards, including restrictions on certain services provided to the same fund.

The ATO is also paying attention to high-risk and high-volume auditors and newly registered auditors.

Every SMSF must undergo an annual audit by an ASIC-registered SMSF auditor before lodging its annual return. The auditor must assess whether financial statements are accurate and whether the fund complies with superannuation rules.

A recurring issue identified by regulators is insufficient evidence supporting asset ownership, existence or market value. In 2026, weak valuation evidence may attract greater attention because of the broader implications attached to asset values.

Verification of rollovers

SMSF rollovers are processed electronically through SuperStream, which requires accurate fund information and verification processes.

To participate in electronic rollover transactions, an SMSF must be registered, maintain complying status, have an electronic service address and ensure relevant details are correctly recorded.

The ATO uses verification processes, including SMSF verification and member verification checks, to protect against Fraud and illegal early access to superannuation.

These checks may occasionally delay transfers, particularly where information is incomplete or inconsistent.

Maintaining accurate fund details helps trustees reduce unnecessary delays and supports the integrity of the rollover process.

Why the annual audit is central

The annual SMSF audit connects many compliance requirements.

It is the process through which asset valuations are reviewed, compliance issues are identified and reportable breaches may be communicated to the ATO through an Auditor Contravention Report.

Given the ATO’s focus on valuations and auditor independence for 2026–27, trustees should view the audit as more than a routine administrative requirement.

Auditors need evidence that assets exist, belong to the fund and have been valued using appropriate information.

Where breaches are identified, the ATO has several possible responses, including education directions, rectification directions, enforceable undertakings, administrative penalties, Trustee disqualification and, in serious situations, making a fund non-compliant.

Administrative penalties are calculated using penalty units and may apply personally to individual trustees. A fund with multiple individual trustees may face multiple penalties for the same breach.

What trustees should check and understand

Consider a hypothetical SMSF holding commercial property, private company shares and listed investments, with one member approaching a large superannuation balance threshold.

During 2026–27, the values assigned to property and private assets may influence the member’s total superannuation balance calculation. If valuation evidence is weak, questions may arise during the audit and the member’s tax position may become uncertain.

Maintaining well-supported valuations can help reduce these risks.

This example is hypothetical and intended only to illustrate why accurate valuations matter.

Common issues include:

  • relying on outdated or informal valuations;
  • insufficient documentation supporting asset values;
  • arrangements that compromise auditor independence;
  • outdated fund information causing rollover delays.

Where valuations involve complex assets such as property or unlisted investments, professional valuation or tax advice may be appropriate.

What to watch next

The first Division 296 assessments are expected from the financial year beginning 1 July 2027, based on relevant superannuation balance information.

Trustees with larger balances should continue monitoring ATO guidance on valuation requirements and maintain supporting documentation throughout the year.

Broader registry changes, including increased integration of director identification information from 1 July 2027, are also expected to improve visibility over fund control structures.

Key Insights

ATO compliance checks may become more significant for SMSFs in 2026 because existing obligations now interact with broader tax and regulatory changes.

Division 296 increases the importance of accurate asset valuations, while auditor focus areas and rollover verification processes reinforce the need for reliable records.

Trustees who maintain strong documentation, support asset values with appropriate evidence and treat annual audits as meaningful reviews can better manage the evolving compliance environment.