Register For Our Mailing List

Register to receive our free weekly newsletter including editorials.

Home / 223

New role for outcomes test and member goals

The Treasury Laws Amendment (Improving Accountability and Member Outcomes in Superannuation) Bill 2017 proposes to expand the existing scale test of performance against costs for members to an outcomes test. This will require superannuation trustees to determine, on an annual basis, whether the fund’s MySuper products are meeting the clients’ best interests. 

Many of these questions apply to SMSF trustees who are managing their own superannuation funds. 

The intent of the change is to allow APRA to assess the overall governance and performance of default funds. APRA has advised what needs to be addressed but not ‘the how’. Trustees will need to develop their own framework. 

Is there a need for the change?

To respond to this question, we need to answer the following two questions:
1. Has the scale test achieved what it was set out to achieve?
2. What should an outcomes test do differently?

What should an outcomes test do differently? 

Some cynics say the scale test has failed. In the main, the scale test assesses performance and fees, seeking to prove a correlation between these and the size of the fund. However, in this case, size doesn’t always matter. Many small funds have proven the test wrong, consistently demonstrating good returns and low fees. 

What should an outcomes test do differently? 

The focus of the outcomes test is on sustainability, which in my opinion is a much better measure of a fund’s performance against costs to members. Ultimately its aim is to have funds determine what is in the best interest for their members and test the sustainability of this model. 

In reality, most members rely on their employers to make the important decision when it comes to choosing their superannuation fund. But, superannuation is not most employers’ core business. So, how are they to know what is in the best interest of their employees? This question will become more important if the proposed changes to default fund status are legislated. Regardless of any new regulatory impositions though, all members should receive what’s in their best interest, but many funds, regardless of size, have struggled to define it. 

How can a fund define best interest? 

Firstly, funds need to define the most important goals for the members to achieve. In other words, what outcomes would the funds’ members like as a result of their experience with the fund? Each fund has different cohorts of members, so this definition of goals needs to be done at the member level, rather than at an overall fund level. 

Funds then need to collect information that tells them whether the services, products and experiences offered are having the desired impact on its members. Is the fund making a difference in the lives of the members it serves and does it really know its members? Funds often say “we know our members better than anyone.” While this may be true, how does a fund support this bold statement? 

The next step is for funds to define the strategy needed to meet these goals. The scale test drove a pattern of including growth in funds’ strategies, as there was a fear of not being at scale. Under the new outcomes test, strategies should be about ensuring the fund will continue to be sustainable and achieve the best interests of its members as previously defined. This may not always include growth. 

Finally, funds need to set measurable metrics to support these goals. This is where funds need to be honest with themselves about future sustainability. 

There is no single approach to a best interest assessment and APRA has not defined this. Funds will need to develop their own policy and practices, which reflect the specific circumstances of the fund and its members. It should be based on what the fund’s members value as far as possible. 

How to conduct an outcomes assessment 

Funds will need to evaluate how well they have achieved the defined goals for their members. Have they delivered what they set out to deliver, keeping in mind the different cohorts of members? 

From there, funds should use the results to improve the experience. This is where funds may need to make the hard decisions. If goals have not achieved their desired outcome, the fund must understand why and determine the next steps. What can be done to fix it? And, where things have worked, could the fund be doing more? 

Can we learn from our global counterparts? 

Around the world, regulators are steering in the same direction when it comes to measuring funds’ performance against costs to members. However, the UK seems to be the most advanced, with similar thinking and the imposition by the UK Pension Regulator of a legal duty to assess value. The UK schemes are required to carry out an assessment at least annually, that focusing on the value provided by the scheme for the costs paid by members across the preceding year, and the influence this could have on future outcomes for those members. 

The UK regulator has also issued an illustrative example to the Pension Schemes, highlighting the areas that need to be captured, considered and assessed in order to assess value properly.

Best interest duty test dominates

Whatever approach is chosen, one key test has to be met – the best interest test. Funds should document the steps taken and be prepared to demonstrate the execution of a proper process and provide an explanation of how and why conclusions have been reached. 

 

Maree Pallisco is the EY National Superannuation leader. The views expressed in this article are the views of the author, not Ernst & Young. The article provides general information, does not constitute advice and should not be relied on as such. Professional advice should be sought prior to any action being taken in reliance on any of the information. Liability limited by a scheme approved under Professional Standards Legislation.

 

  •   19 October 2017
  • 2
  •      
  •   

RELATED ARTICLES

Minister Jane Hume on SMSFs and superannuation reform

Check pension outcomes when making a will

Super complex: the advice gift keeps on giving

banner

Most viewed in recent weeks

Warren Buffett's final lesson

I’ve long seen Buffett as a flawed genius: a great investor though a man with shortcomings. With his final letter to Berkshire shareholders, I reflect on how my views of Buffett have changed and the legacy he leaves.

13 ways to save money on your tax - legally

Thoughtful tax planning is a cornerstone of successful investing. This highlights 13 legal ways that you can reduce tax, preserve capital, and enhance long-term wealth across super, property, and shares.

The housing market is heading into choppy waters

With rates on hold and housing demand strong, lenders are pushing boundaries. As risky products return, borrowers should be cautious and not let clever marketing cloud their judgment.

Why it’s time to ditch the retirement journey

Retirement isn’t a clean financial arc. Income shocks, health costs and family pressures hit at random, exposing the limits of age-based planning and the myth of a predictable “retirement journey".

Taking from the young, giving to the old

Despite soaring retiree wealth, public spending on older Australians continues to rise. The result: retirees now out-earn the young, exposing structural flaws in the tax system and challenges for fiscal sustainability.

Welcome to Firstlinks Edition 637 with weekend update

What should you do if you think this market is grossly overvalued? While it’s impossible to predict the future, it is possible to prepare, and here are three tips on how to best construct your portfolio for what’s ahead.

  • 13 November 2025

Latest Updates

Investment strategies

Howard Marks: AI is "terrifying" for jobs, and maybe markets too

The renowned investor says there’s no shortage of speculative investors chasing AI riches and there could be a lot of money lost in the process. His biggest warning goes to workers and the jobs which will be replaced by AI.

Property

The 3 biggest residential property myths

I am a professional real estate investor who hears a lot of opinions rather than facts from so-called experts on the topic of property. Here are the largest myths when it comes to Australia’s biggest asset class.

Retirement

Australia's retirement system works brilliantly for some - but not all

The superannuation system has succeeded brilliantly at what it was designed to do: accumulate wealth during working lives. The next challenge is meeting members’ diverse needs in retirement. 

Retirement

Retirement affordability myths

Inflated retirement targets have driven people away from planning. This explores the gap between industry ideals and real savings, and why honest, achievable benchmarks matter. 

Retirement

Can you manage sequencing risk in retirement?

Sequencing risk can derail retirement, but you’re not powerless. Flexible withdrawals, investment choices and bucketing strategies can help retirees navigate unlucky markets and balance trade-offs.    

Retirement

Don’t rush to sell your home to fund aged care

Aged care rules have shifted. Selling the family home may no longer be the smartest option. This explains the capped means test, pension exemptions and new RAD exit fees reshaping the decision.

Shares

US market boom-bust cycles - where are we now?

This gives comprehensive data on more than 100 years of boom and bust cycles on the US stock market - how the market performed during these cycles, where the current AI uptick sits, and what the future may hold.

Property

A retail property niche offers a lot more upside

Retail real estate is outperforming as a cyclical upswing, robust demand and constrained supply drive renewed investor interest. This looks at the outlook and the continued rise of convenience assets. 

Sponsors

Alliances

© 2025 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.