Being an SMSF trustee is not passive. Unlike being a member of an industry fund — where compliance is handled entirely by the fund — SMSF trustees bear personal legal responsibility for ensuring the fund operates within the law. Penalties for breaches can reach $18,750 per trustee per contravention, and serious breaches can result in the fund losing its complying status (which means an effective tax rate of 45% on the fund's assets).
Use this checklist to stay on top of your annual obligations.
Every Year — Non-Negotiable
These tasks must be completed every financial year, without exception:
| Task | Due | Who |
|---|---|---|
| Prepare annual financial statements | Before audit | Accountant / administrator |
| Arrange independent audit (approved SMSF auditor) | Before tax return lodgement | Approved auditor |
| Lodge SMSF Annual Return (SAR) with ATO | 31 Oct (or later if via tax agent) | Trustee / tax agent |
| Pay ATO supervisory levy ($259) | With SAR lodgement | Trustee |
| Review and update investment strategy | At least annually | Trustees |
| Value all fund assets at market value | 30 June each year | Trustees / valuer |
| Pay ASIC annual fee (corporate trustee) | As invoiced (~Jan) | Corporate trustee |
| Review member insurance adequacy | Annually with investment strategy | Trustees |
Every SMSF must have its financial statements and compliance audited by an approved SMSF auditor registered with ASIC — not just any accountant. Your accountant typically arranges this but cannot audit a fund they also prepare accounts for.
Ongoing Throughout the Year
These obligations don't have a specific annual deadline — they must be observed continuously:
- Separation of assets — fund assets must always be kept completely separate from trustees' personal assets. Mixing funds, even temporarily, is a serious breach.
- Arm's length dealings — all transactions must be made and maintained on commercial terms. You cannot give the fund a "good deal" or receive one from it.
- No loans to members — the fund must never lend money to members or their relatives under any circumstances.
- No personal use of fund assets — members and related parties cannot use or benefit from assets owned by the fund (e.g. holiday use of investment property, personal use of collectibles).
- Sole purpose test — all decisions must be made for the purpose of providing retirement benefits to members, not for other purposes.
- Record keeping — trustees must keep financial records for 5 years and trustee minutes and declarations for 10 years.
- Contributions caps — monitor that contributions don't exceed annual caps ($32,500 concessional / $130,000 non-concessional in 2026–27).
When a New Member Joins or Leaves
- Update the trust deed if required
- New member signs a trustee declaration (must be done within 21 days of becoming a trustee)
- Update ASIC records if using a corporate trustee (new director appointment or resignation)
- Review and update investment strategy for the new membership profile
- Arrange rollover to/from the new member's existing super fund
- Update binding death benefit nominations if applicable
When a Member Reaches Preservation Age
When a member reaches preservation age (currently 60 for most Australians) and meets a condition of release, you may need to:
- Establish an account-based pension for the member if they wish to start drawing income
- Calculate and pay the minimum annual pension amount (as a percentage of pension balance, set by the ATO)
- Ensure the pension is paid as cash at least annually — in-specie pension payments are generally not permitted
- Segregate pension assets if using the segregated method for tax purposes
- Obtain an actuarial certificate if using the proportional (unsegregated) method
New in 2026: AML Identity Verification
From 2026, SMSF trustees must comply with expanded Anti-Money Laundering (AML) obligations when dealing with reporting entities such as banks, brokers, and financial service providers. This includes providing certified identity verification documents and keeping records of verification. Ensure all trustees and corporate directors have current certified identification on file with all service providers.
Common Mistakes That Get Trustees in Trouble
- Late lodgement of the SAR — even one year of late lodgement can attract an ATO audit and administrative penalties
- Temporary borrowing from the fund — "I'll pay it back next week" is still a breach; any loan to a member is prohibited regardless of intent
- Buying assets from related parties — purchasing a property or shares from a family member is generally prohibited
- Underpaying minimum pension — failing to pay the minimum required pension amount by 30 June results in the pension failing, with tax consequences
- Not keeping trustee minutes — every investment decision should be documented in trustee minutes; lack of documentation is a common audit finding
- Using collectibles without proper procedures — artwork, coins, and other collectibles held in SMSFs must be insured, stored away from trustees' residences, and not used personally
Related Articles
- How to Set Up an SMSF in Australia — Step-by-Step Guide (2026)
- How Much Does an SMSF Cost Per Year? (2026 Guide)
- Is an SMSF Worth It in 2026? — The Honest Answer
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