DSPANZ provided feedback on Draft Practice Statement PS LA 2026/D3 and as a sector we are supportive of publishing guidance that describes how the Commissioner will exercise the exceptional circumstances determination power under the Payday Super reforms.
DSPANZ recommends that the final Practice Statement be strengthened to:
- broaden recognition of dependency failures across interconnected digital services.
- consider operational payroll timing alongside outage duration.
- provide additional implementation guidance for employers and software providers.
- improve communication arrangements through machine-readable digital notifications.
- strengthen engagement with software providers during major technology incidents.
- review the operation of the framework following the first year of Payday Super implementation.

