On 2 October 2025, the Australian Prudential Regulation Authority (APRA) issued a paper “Delivering member outcomes into the future”.

Challenges facing trustees

In this paper APRA discusses dynamics shaping the ongoing evolution of Australia’s superannuation system, including:

  • continuing industry consolidation leading to the reduction in the number of funds;
  • ongoing growth in the size of the superannuation system with recent growth concentrated in the largest funds;
  • expense ratios trending downwards at an aggregate level, but material difference across funds; and
  • significant differences across funds in terms of natural cash flows and rollover dynamics.

The paper emphasises the importance of trustees actively considering these challenges as part of their strategic and business planning and shines a light on some of the challenges facing trustees in relation to operational efficiency, growth and competitive positioning.

APRA’s expectations

APRA expects trustees to have effective strategic initiatives and business planning processes to ensure they are improving member outcomes over the medium to long term. In relation to trustees facing multiple challenges, APRA feels that it is imperative that trustees look to proactively drive better member outcomes. APRA will continue to maintain a heightened supervisory stance to ensure they are planning and implementing timely and credible actions to improve member outcomes.

APRA Deputy Chair Margaret Cole said consideration of the challenges should also take into account trustees’ focus on delivering strong returns for members and investing for business and risk objectives, such as expanding support to members approaching retirement and putting a strong focus on operational risk and cyber resilience.

“Some super trustees face multiple challenges, not just in relation to matters that affect all super trustees, but specific to their own circumstances. They must have credible strategic plans to face and address the challenges in the best interests of members. Consistent with APRA’s approach over many years, such trustees can expect ongoing engagement from APRA to ensure credible strategic plans are in place and that long-term outcomes for member are firmly front of mind,” she said.