Welcome to the TRR #2 of 2026 - your regular dose of retirement policy, product, and the regulatory currents driving both.
With the Australia Day long weekend behind us, funds are heading into a busy stretch. Trustees are undertaking their first triennial Retirement Income Strategy review - with outcomes to be reflected in the SPS 515 annual Business Performance Review. More on that in future editions.
In this edition we take a look at APRA’s FY2025 fund-level statistics, focusing on competitive net flows (the difference between inward and outward rollovers).
Any such analysis invariably get framed in ‘industry v retail’ super fund terms. We find these labels somewhat outdated, given board, senior executive and membership compositions of most ‘industry’ funds today.
We prefer ‘profit-to-member’ and ‘for-profit’ as descriptors of the key difference involved. Be that as it may, a comment late last year by UniSuper’s CIO John Pearce (himself previously from the ‘for-profit’ side) caught our attention.
Pearce opined that having benefitted in the wake of the Hayne Royal Commission, profit-to-member funds are now witnessing an increase in members rolling their benefits into technology-focused wealth platforms, often after receiving financial advice. Pearce branded this trend reversal “The Empire Strikes Back”.
So we pulled the FY2025 numbers to see if the data agrees.
🏋 Competitive Net Flows
APRA’s annual fund-level stats are a rich dataset covering the 46 RSE licensees overseeing 77 APRA-regulated funds.
At 30 June 2025, those 77 funds held just over $3 trillion in assets, with ~$124 billion received in employer contributions during FY2025.
Putting contributions and benefit flows to one side, the competitive net flows show up in ‘net rollovers’. We analyzed net rollovers, adjusted for successor fund transfers, and present below (in alphabetical order) a selection of prominent profit-to-member and for-profit funds to test Pearce’s ‘Empire’ observation.
While one year does not a trend make, the FY2025 data is consistent with prior work by The Conexus Institute in their FY2023 and FY2024 ‘State of Super’ studies.
The broad pattern is hard to miss: for-profit platforms (notably HUB24 and Netwealth) recorded significantly positive competitive net flows, while most profit-to-member funds recorded competitive net outflows in FY2024–25 (with UniSuper the notable exception), as did for-profit funds no longer enjoying the support of tied-distribution arrangements.
Lumisara’s Take
On the numbers, Pearce’s observation looks directionally right.
But it may be less the “Empire" returning - and more a structural reset since the Hayne Royal Commission, resulting in a new breed of competitor, powered by the distribution force of non-aligned financial advisers. Here's our thesis:
The Hayne RC ended the ‘Bancassurance’ model of the 2000s. The Big 4 dismantled their tied-distribution channels, as Westpac did in 2019.
Financial advice has undergone a radical transformation, both in adviser numbers (almost halving since the RC) and ownership/operating models. New non-aligned advice groups (some backed by PE capital) are on the ascendency.
These advice groups aren’t wedded to legacy tech and systems (note the outflows from AMP and MLC Super Funds above). Advisers win or lose on client experience, and the new breed of super platforms suit their propositions perfectly (engaging UX, adviser portal access, on-demand reporting, SMA/model portfolios).
Many Australians approaching retirement have complex advice needs; as a general rule - the greater the super balance, the more likely an advice interaction will be sought.
Non-aligned advisers therefore tend to deal with pre-retirees with above-median balances. If a prospect is in a profit-to-member fund and it is in their best interest to be recommended a rollover to a for-profit super/pension platform, that is likely to happen. The net flows to HUB24 and Netwealth are no accident.
In essence (contribution inflows and benefit payments notwithstanding), one fund’s member acquisition play is another’s retention problem in today’s environment.
The challenge for profit-to-member funds, as decumulation moves from the fringes to the centre of engagement/retention, is in creating a compelling end-to-end retirement experience for members. This will need to incorporate quality help, guidance, tools, calculators and advice (traditional, hybrid and digital), all seamlessly connected to fit-for-purpose retirement products.
We are here to help
We’d welcome the opportunity to support you as you strengthen your retirement offering - the member journey, tools plus guidance, and the product design underpinning it.
With the triennial review cycle now underway, SPG 515 notes the potential benefit of input from an operationally independent, appropriately experienced party. If you’re considering external support as you scope and run your review, from evidence and benchmarking to practical next steps, we’d love to help.
🧩 What’s new in product?
It may not be brand new, but AMP Super Lifetime is causing some consternation within retirement circles.
Critics argue the deferred innovative retirement income stream (IRIS) product design enables a form of Age Pension ‘double dip’, worsening the scheme’s fiscal position over time.
AMP first launched the lifetime income product as MyNorth Lifetime (some three years ago) on its adviser-led MyNorth Wrap platform. In mid-2025 it released a version to AMP Super, defaulting all Choice members into the new AMP Super Lifetime product.
Members who elect the Lifetime Boost option can draw some combination of an AMP Allocated Pension and an AMP Lifetime Pension at retirement.
The Lifetime Boost is designed to comply with SIS Regulation 1.06A (standards for certain innovative superannuation income streams), and delivers income benefits via a guaranteed income for life (longevity risk hedge) and two interconnected Age Pension concession components:
An Asset Test Discount (via the Capital Access Schedule): broadly a 60% - 90% discount of the ‘purchase price’ depending on the age at which benefits convert to the lifetime pension; and
A ‘Growing Discount’ in accumulation: assessed growth is based on Services Australia deeming rates, instead of the actual investment earnings.
Over an extended accumulation period of multiple decades, it is theoretically possible that the assessed purchase price (for Reg 1.06A purposes) may be discounted fully compared to the actual balance as accrued via investment earnings. Hence the suggestion that AMP might be allowing better-off retirees to receive additional Age Pension benefits they wouldn’t otherwise be entitled to, effectively overcoming the Age Pension ‘taper trap’.
Lumisara’s Take
Yes, AMP’s marketing is bold. Claims such as it can “make retirement significantly better for most Australians”, and that their expectation is that “9 out of 10 Australians could be better off with this Lifetime Boost” are eye-catching indeed.
The case study AMP have elected to lead the marketing campaign has also ruffled a few feathers, with its claim that the member (a 39 year-old female earning $88,000 pa) could be $100,000 better off in the first 10 years of retirement.
But marketing puffery aside, isn’t AMP doing exactly what is being asked of the entire superannuation sector by the Retirement Income Covenant? Aren’t all superannuation funds on notice to meet the challenge of The Great Retirement Race?
Reg 1.06A was introduced, in 2017, to encourage deeper thinking about managing longevity risk while overcoming the annuitization puzzle. AMP may simply have thought more creatively about its possible application but that, in and of itself, is no reason to denigrate this retirement innovation.
The decumulation space doesn’t need loud indignation. It needs better retirement solutions - products, services, tools, and guidance, that improve outcomes and stand up to scrutiny. The way to best AMP here would be to out-innovate it with your own lateral retirement thinking, not hope it ceases to do so.
Whatever you think of the marketing, this is the direction of travel: more product creativity creating better retirement solutions, for better retirement outcomes.
In 2026, we’re building a practical map of what “better” looks like - the designs, trade-offs, and delivery models that genuinely lift retirement outcomes.
🏛️ Regulatory Roundup
ASIC Chair Joe Longo has published ‘Key issues outlook 2026’, summarising several initiatives from ASIC’s 2025-2026 Corporate Plan. A number of these relate to the operation of superannuation funds and aim to help “direct attention to where risks are most likely to emerge”.
CROs (and anyone accountable for member outcomes) should have this on their reading list. Here are a couple of issues that caught our eye.
Operational failures by superannuation fund trustees leading to member harm
Longo puts super fund operations firmly in the crosshairs: claims delays, inadequate member support, weak IT/cyber resilience, and rising fraud and scam activity.
From a retirement perspective, he notes that with three million members becoming eligible to access their super in the next decade - and more than $750 billion expected to move from accumulation into the retirement phase - it is “essential that the superannuation system is prepared to manage potential operational challenges”.
This would appear to dovetail with APRA’s CPS 230 requirements on operational risk management, in place effective July 2025.
Poor quality financial reporting, sustainability reporting and audit quality
While this issue applies to entities well beyond superannuation, it was instructive that Longo singled out super for special mention here, stating that “ASIC is concerned with evidence it has found in superannuation financial reports of inconsistent investment disclosures, limited transparency on certain disclosures, and insufficient audit evidence for valuations.”
The entire list of issues outlined by ASIC Chair Joe Longo can be read here.
That’s a wrap for this crossing! We welcome your questions or feedback - simply reply to this email.
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Thank you!
— The Lumisara Team