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We provided a submission to Treasury's Superannuation Efficiency and Performance Unit on the Your Future, Your Super Measures Review on 14 October 2022.

While DSPANZ is supportive of the policy intent behind the Your Future, Your Super measures, our feedback highlighted the impacts to existing onboarding processes and the importance of early technical feasibility conversations prior to publishing legislative instruments or finalising legislation that impacts Digital Service Providers (DSPs) and their end users.

Our submission highlighted where the current administrative design of super stapling is deficient and prevents the broader take-up of this service by employers. In summary:

  • Many DSPs have embedded a digital version of the Superannuation standard choice form within their products to support onboarding of new employees. 
  • The ATO’s requirement to create an employment relationship between the employer and employee via submission of a Tax File Number (TFN) declaration or Single Touch Payroll (STP) Pay Event is unworkable as the vast majority of employers can not do this until the first payroll has occurred. 
  • DSPs agree that continuing to deliver the super stapling Application Programming Interface (API) through the ATO’s Digital Services Gateway will provide the appropriate foundations to begin developing software for consuming the API.

Access a full copy of our submission here.

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