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Wednesday 1 November 2017

17-369MR ASIC updates work on fee transparency for super and managed investment schemes

ASIC is committed to improving the transparency and comparability of fees and costs for managed investment and superannuation funds, through its work on Regulatory Guide 97 Disclosing fees and costs in PDSs and periodic statements (RG 97).

As part of the ongoing work with industry to develop better costs disclosure, ASIC is today announcing that it:

  • has extended beyond 30 September its facilitative compliance approach to fee and cost disclosure; and
  • will work with an external expert to conduct a review of the fees and costs disclosure under RG 97 to ensure that it is best meeting in practice the objective of greater transparency for consumers.

ASIC is undertaking these actions in response to feedback from across the industry around challenges with the practical implementation of RG 97. ASIC has been pleased that funds have been investing in improving fee disclosure, but ASIC recognises that accurate fee and cost disclosure is complex to implement, and that this implementation takes time. ASIC will continue  to work with industry to make sure that disclosure works for consumers.

Importance of fee and cost transparency

Through its engagement with industry, modification of the law and updating guidance, ASIC's work has led to a greater focus by industry and improvements in disclosure that has benefited consumers.

Understanding fees and costs across superannuation and managed investment fund products remains an ongoing challenge for consumers and ASIC will continue to focus on getting the requirements right so that consumers can be well informed.

ASIC notes that fees and costs are not the only significant consideration for consumers, as some higher cost investments may produce higher net returns in the long term.

ASIC will appoint an external expert to consider the RG 97 reforms and their impact, liaise with industry and produce any necessary recommendations about how better transparency and comparability of fees and costs may be achieved. Supported by ASIC and building on previous stakeholder feedback, it is anticipated that this process will be concluded in the first half of 2018.

ASIC's approach to reviewing fee and cost disclosure

During this period, funds should provide accurate information about fees and costs to consumers. 

While the expert review is underway ASIC's oversight of PDS and periodic disclosure will maintain its current facilitative compliance approach,focusing on the key aim of ensuring that consumers are not misled. 

ASIC will shortly liaise with industry bodies to outline ASIC's approach in greater detail.


The changes to reporting of superannuation and managed funds fees arise from ASIC's concerns with inconsistency and under-reporting of fees. This issue was investigated in Report 398 Fee and cost disclosure: Superannuation and managed investment products, which identified the following key issues:

  • under-disclosure of fees and costs associated with investing indirectly through other vehicles
  • tax treatment of fees and costs
  • performance fees
  • under disclosure of management costs 

Following the release of Report 398, in November 2015 ASIC issued updated Regulatory Guide 97 Disclosing fees and costs in PDSs and periodic statements to bring greater consistency and transparency to fees reporting.

Last updated: 30/03/2021 09:30