Register For Our Mailing List

Register to receive our free weekly newsletter including editorials.

Home / 680

Individual SMSF Trusteeship directly liable for ATO fines

For years, the debate has raged between advisors and their clients. Should we go to the trouble and expense of getting a corporate trustee for our self-managed superannuation fund (SMSF), or should we just be individual trustees? After all, we as the members are still all involved in any decision making either way, so what’s the real difference – other than the extra costs and hassle?

It’s not a bad question. Under section 17A of the Superannuation Industry (Supervision) Act 1993 (SISA), all members of a SMSF have to either be trustees personally, or alternatively if there is a corporate trustee then they must be the directors of the company. This ensures that every member has a say in the management and investment of their own super.

However, it also means that every member is personally responsible to ensure that their SMSF complies with all the legal requirements for its complying (and hence tax concessional) status to be retained. And if things go wrong, it also means that each and every member will personally suffer the consequences of getting it wrong.

This is where having a corporate trustee of your SMSF comes into its own – limitation of personal liability. Remember that a company is a separate legal entity from its directors and shareholders, and this carries over into the SMSF context. That separate entity status brings with it three clear advantages over having individual members being the trustees of their SMSF:

  1. There is no need to change the trustee if a member dies or leaves the SMSF for any reason – all you need to do is remove or retire the outgoing director. If it was a two-member fund becoming a single member fund, the remaining member can become the sole director (assuming the company constitution allows for this – if not, it can usually be amended accordingly). This is to be contrasted with a fund with individual trustees, where a sole member would need to appoint a second person as co-trustee to satisfy the definition of “self-managed superannuation fund” under section 17A(2)(b) of SISA. There is also no need to advise banks or share registries of a change in trustee, since only the directors of the corporate trustee have changed rather than the trustee itself.
  2. The personal liability of directors of a corporate trustee is limited to the assets held within the SMSF, assuming that the rules of the fund indemnify the trustee against liabilities incurred in the exercise of its trustee duties. In contrast, individual trustees (being the legal persons who transact on behalf of the SMSF) will be directly liable for any liabilities incurred as trustees, and whilst they may have an indemnity from the fund if the assets are insufficient, they may be personally responsible for the excess.
  3. Part 20 of SISA sets out the ‘speeding tickets’ regime which applies to impose administrative and other penalties on SMSF trustees for breaches of the SIS laws – including fines of up to $21,840. Where the SMSF trustee is a body corporate, its directors at the time it becomes liable to the penalty will be jointly and severally liable to pay the amount of the penalty. However, where there are individual trustees, the fine is personally imposed on each and every trustee – so if there are four individual trustees, then the total fines may amount to $87,360! Or, $131,040 if there are six individual trustees. Moreover, these fines cannot be paid or reimbursed out of the fund.

These amounts are the maximum fines which can be imposed as of 1 July 2026. Actual fines imposed depend on which section has been infringed and whether there are any mitigating circumstances. Administrative penalties can be imposed on directors of corporate trustees if the director breaches a SIS provision which directly imposes an obligation on the director (rather than on a trustee) – such as s104A (obligation to sign statement recognising a trustees obligations and responsibilities).

So if you are an individual trustee of your SMSF, the message is clear – make the switch to a corporate trustee as soon as possible. The inconvenience, initial investment and ongoing costs of doing so may pale into insignificance compared to the future inconvenience and costs of staying as you are in the name of ‘keeping it simple’.

 

Michael Hallinan is a superannuation and financial services lawyer with over 25 years legal and superannuation experience gained in both private practice and corporate counsel positions. His work in the superannuation field in various capacities has given him an extensive understanding of the specialised field of superannuation and the superannuation industry.

He is Special Counsel – Superannuation, for SUPERCentral, an independent online platform provider of SMSFs, advice, legal documentation and wealth management services to accounting and financial planning firms throughout Australia.

Please note that these comments are for your consideration only and are provided to assist you in deciding whether to proceed to obtain a formal opinion on the issue. These comments cannot be relied upon by either you or any of your clients until and unless we issue that formal opinion.

 

  •   16 September 2026
  •      
  •   

 

Leave a Comment:

RELATED ARTICLES

Why SMSFs should have a corporate trustee

Importance of updating your SMSF Trust Deed

Red flags to watch out for when considering an SMSF

banner

Most viewed in recent weeks

Will you run out of money in retirement?

Fear of running out has become a defining retirement anxiety. Why do some retirees die with substantial wealth while others deplete their nest egg? Evidence suggests the answer is more complicated than we think. 

Why spending more in early retirement can improve lifetime income

Conventional wisdom encourages retirees to preserve superannuation. But if those likely to qualify for the Age Pension later in life spend a little more today, it may deliver higher lifetime income and a more stable retirement.

The investment that sidesteps the new tax traps

Tax rules have changed, but many investors are still using yesterday’s strategies. Insurance bonds may offer advantages for those seeking greater control, tax efficiency and certainty about their wealth.

Testamentary trusts have secured the CGT exemption

Treasury’s latest CGT reform draft delivers a win for testamentary trusts and deceased estates, exempting estate-derived gains from the 30% floor. However, questions on death and divorce rollovers remain unresolved.

Meg on SMSFs: What do we think about reversionary pensions these days?

Reversionary pensions have long been a staple of SMSF estate planning, but are they still the best option? Meg Heffron revisits a once-clear favourite and asks whether changing super rules have shifted the balance.

Welcome to Firstlinks Edition 674 with weekend update

What begins as appetite, grows into excess and ultimately ends in spectacle. Millions of investors just discovered this the hard way.

  • 6 August 2026

Latest Updates

Planning

Testamentary trusts survived the trust tax. The drafting battle has just begun.

The fight over testamentary trusts looked settled. Then the draft legislation arrived. Hidden in a technical detail is a question that could force many families to rethink wills they thought were already future-proof.

Investment strategies

The new capital gains tax trap for your portfolio

Investors have long accepted one portfolio rule without much question. A major tax shift could change that calculation entirely, forcing difficult trade-offs between risk, discipline and an overlooked cost lurking beneath.

Economy

Population growth masks Australia’s productivity problem

For years, investors have benefited from a seemingly reliable growth story. But recent national accounts raise uncomfortable questions about what has really been driving Australia’s economy and whether that can continue unchecked.

Investment strategies

Why tomorrow’s winners may not be today’s index leaders

The stocks that built retirement balances over the past decade now dominate many portfolios. The new challenge is whether these companies can continue meeting the increasingly high expectations embedded in today's share prices.

Investing

What earnings surprises reveal about future returns

Sometimes the most important information in an earnings result isn't the number itself. It's the possibility that the market's assumptions have been fundamentally wrong and future earnings may look very different.

SMSF strategies

Individual SMSF Trusteeship directly liable for ATO fines

A rarely discussed detail buried in SMSF structures could dramatically change who wears the cost when something goes wrong. With penalties rising, a decision many dismissed as administrative may deserve a second look.

Investment strategies

The currency bet you didn’t know you made

Buying global shares means making two bets: on the companies and on the Australian dollar. Most investors consciously choose only the first. Last financial year, the second bet cost 8.5% in returns for many investors.

Sponsors

Alliances

  • ASA-Logo-RGB-ActiveGreen-web.png

© 2026 Morningstar, Inc. All rights reserved.

Disclaimer
The data, research and opinions provided here are for information purposes; are not an offer to buy or sell a security; and are not warranted to be correct, complete or accurate. Morningstar, its affiliates, and third-party content providers are not responsible for any investment decisions, damages or losses resulting from, or related to, the data and analyses or their use. To the extent any content is general advice, it has been prepared for clients of Morningstar Australasia Pty Ltd (ABN: 95 090 665 544, AFSL: 240892), without reference to your financial objectives, situation or needs. For more information refer to our Financial Services Guide. You should consider the advice in light of these matters and if applicable, the relevant Product Disclosure Statement before making any decision to invest. Past performance does not necessarily indicate a financial product’s future performance. To obtain advice tailored to your situation, contact a professional financial adviser. Articles are current as at date of publication.
This website contains information and opinions provided by third parties. Inclusion of this information does not necessarily represent Morningstar’s positions, strategies or opinions and should not be considered an endorsement by Morningstar.