Welcome to TRR #13 for 2026. This edition looks at ASIC's latest review of how platform trustees monitor advice-fee deductions and switching activity in super. REP 833 is not really a new debate; ASIC and APRA have been raising these issues for years. What has changed is the scale of money moving through platforms, and the question of whether trustee controls have kept pace.
This week’s release of ASIC Report 833 ‘Safeguarding super: How well are platform trustees monitoring risks to retirement savings?', arrives in the wake of the Shield and First Guardian member losses.
Super platforms now account for around 14% of total system assets, or around $420 billion as at end 2025, but REP 833 notes that member benefits in such platforms have more than tripled between June 2015 and June 2025, from $123 billion to $396 billion.
In the first major review of super trustee fee practices since 2024, ASIC reviewed six major super platform trustees over 17 months to October 2025. Together, they were responsible for 72% of platform member benefits, roughly $305 billion across 977,000 accounts.
The report’s findings are as confronting as they are unambiguous: despite years of warnings, oversight of advice fee deductions and inappropriate switching remains inadequate across the board.
The numbers tell their own story. Some of the more revealing include:
Trustees in the sample reported $2.56 billion in advice fees deducted from 720,000 advised members, against just over 2,580 advice document checks and nearly 250 adverse findings.
One trustee performed only 21 checks in the entire period, with 75% of those judged to be adverse.
Dollar-based fee caps ran as high as $25,000, with one trustee seeking approval for a $30,000 cap;
Three trustees had no upper limit on percentage-based caps, permitting fees up to $33,000 on a $1.5 million balance.
Of four trustees applying investment holding limits, only two reported monitoring them.
Manual processes accounted for between 0% and 95% of monitoring activity.
This is not a first warning. ASIC and APRA jointly wrote to trustees in 2019 and again in 2021 on the issue of fee monitoring. In addition, and as mentioned earlier, 2024’s Report 781 reviewed ten platform-related trustees managing $923 billion across 8 million accounts and found:
$990 million in advice fees charged across 476,000 accounts, with fee caps as high as $20,000 or 5% of a member’s balance,
70% of trustees with members charged more than $15,000 in a single year.
REP 833's discovery that caps have actually risen since represents regression.
Adverse findings worsened too: REP 781 reported a roughly 6% adverse rate (82% risk-based checks, 18% random); REP 833 found a near-10% rate, with genuine random sampling reported by just two of six trustees.
Adding to the evidence of inappropriate fee imposition is new analysis from the Super Members Council, submitted to Treasury's consultation on enhancing member protections in the superannuation system. The SMC has found that advice fees deducted from superannuation accounts surged $1.1 billion between 2023 and 2025, with five platforms accounting for $815 million of that increase, concentrated among switchers with balances under $100,000–$200,000; precisely the cohort REP 833 identifies as least protected.
Advice expenses by fund type, 2016 to 2025 (source: Super Members Council)
ASIC's case studies make the human cost of this platform-specific dynamic concrete. One harmful advice licensee was onboarded by four separate trustees, charging over $1.6 million before being detected. Another trustee left a flagged licensee on a watchlist for 13 months while falsified rollover documents continued to be processed.
ASIC's call to action is, in substance, the same call made in 2019, 2021 and 2024’s REP 781: set genuine fee ceilings, protect low-balance members, check advice documents on both risk and random bases, automate monitoring, and act on watchlists.
What has changed is the scale of money moving through a system still relying on the same controls regulators have repeatedly found wanting.
Lumisara's Take 🔎
A 2024 position revisited
In April 2024, as various stakeholders were advocating their positions on the first tranche of the Delivering Better Financial Outcomes legislative package, we suggested that the then-proposed changes to advice fee deduction rules were being mischaracterised.
Elements in the advice sector worried the redrafted SISA section 99FA would force trustees to scrutinise every piece of advice before paying a fee. Our view was more measured: the amendment clarified existing obligations rather than creating new ones, and trustees were already expected to satisfy themselves that fee deductions met the sole purpose test and the covenant obligations more generally.
We didn't expect it to apply to every piece of advice. More likely, trustees would do “some testing or assurance”. The broader point was structural; that advice and superannuation (particularly post-Hayne and under the Retirement Income Covenant) would have to find ways to work more closely together for improved member outcomes.
Tested, and found wanting
REP 833 is a useful, if uncomfortable, review of that 2024 prediction, but only within the platform segment we were describing. Our read on the law appears correct in hindsight.
The problem REP 833 exposes is that DBFO tranche 1 didn’t materially raise the bar for trustees. That the bar was already too low, and "some testing or assurance" turned out in practice to be as few as 21 checks across an entire review period from one trustee, (with three-quarters of them adverse).
A friction specific to platforms
What's emerging is a genuine structural friction, not just a compliance gap, and it is platform-specific. Platforms exist because advisers want flexibility to deal with clients who often have greater complexity in their financial affairs. Trustees permit relatively high fee caps because that complexity is assumed to justify a higher cost of advice. REP 833 shows what happens when a structural allowance, built for legitimate complexity, becomes the path of least resistance for a smaller number of ‘bad apple’ advisers extracting fees significantly in excess of the advice value rendered.
The commercial tension is clear. The platform trustee is meant to be the gatekeeper, but is also commercially dependent on the very advisers it's supposed to be gatekeeping, since they are the primary channel bringing new members and assets onto the platform.
Profit-to-member trustees mostly don't carry this tension: their inflows arrive largely via default Superannuation Guarantee contributions rather than adviser referral, so the growth-versus-gatekeeping conflict ASIC describes is less acute for them. That's the friction in this edition's title, confined to the advice-led platform corner of the system, and ASIC's patience for trustees managing it to the detriment of members appears to be wearing thin.
The numbers behind the headline
The Super Members Council's $1.1 billion figure adds real teeth to what might read as a slow-moving regulatory grievance. ASIC's own modelling in REP 781 shows why a single fee deduction matters: a $3,000 non-ongoing fee charged to a 25-year-old strips $15,000 from their retirement balance once compounding runs its course; a 3% ongoing fee on a 45-year-old's $100,000 balance compounds to $203,000 less for retirement.
Multiply that arithmetic across 720,000 advised members and $2.56 billion in fees, and the SMC's $815 million, stops reading as abstract.
Taken alongside REP 833's finding that holding limits are barely monitored, the picture is of a segment that's had clear, repeated warnings for years and has chosen, in enough cases to matter, not to act on them.
The licensee onboarded by four different trustees, one twice, under a changed name, isn't really a story about one bad actor. It's a story about four control environments, each failing in a slightly different way.
What this means for trustees
For trustees, REP 833 should read as close to a final warning before enforcement escalates. Commissioner Constant's own language ("no excuse," "extraordinary") signals exhausted tolerance for "we monitor this manually".
The practical remediation work lies ahead, including dollar-ceiling every fee cap regardless of balance size, fund genuine random sampling alongside risk-based checks, and automating the indicators that matter most; holding limits and new-business velocity by adviser.
What this means for advisers
There's a sharper point worth sitting with for the advice profession.
Our 2024 argument was, in effect, that good-faith advisers had little to fear from clearer fee-deduction rules because they were already meeting the underlying standard. We wish nothing but success for forward-thinking advice licensees and their advisers who operate compliantly while prioritising the best interests of their clients. Those two outcomes need not be mutually exclusive.
REP 833 validates this for the vast majority of advisers who are doing the right thing, while showing that the minority exploiting weak platform controls do real, measurable damage to the entire advice sector, and increasingly to the credibility of the super platform model itself.
Shield and First Guardian were extreme cases; the routine fee erosion uncovered in REP 833 is more pervasive, and arguably more corrosive to long-term trust, precisely because it doesn't make headlines.
Where this goes next
The next 18 months will likely bring legislated reporting obligations on suspicious switching, lower fee cap flexibility, and statutory minimum balance thresholds before any advice fee can be deducted at all, within the platform segment specifically.
Platform trustees getting ahead of that now will be better placed than those treating REP 833 as just another report to file.
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Thank you!
— The Lumisara Team