Given the more stringent scrutiny superannuation funds currently face, including mandatory performance tests, ASFA argues that regulatory bodies must disclose how levies are utilised. The association highlights that the levies are ultimately sourced from member administration fees, estimating that MySuper members will see a cost of approximately $6 per account for the 2025-26 period. However, this cost varies according to the fund's size, with larger funds imposing lesser per-member fees compared to smaller ones.

ASFA's submission detailed that, assuming average fund balances are consistent nationwide, the levy cost per member for 2025-26 is projected as follows: approximately $4 for large funds ($100 billion), around $8 for medium funds ($20 billion), and about $11 for smaller funds ($1 billion).

The submission references a recent paper from the Productivity Commission which underscores the potentially distortionary effects of industry levies on market efficiency and productivity. The Commission supports the use of levies to recuperate regulation costs when they address negative externalities like financial instability or market failures such as underperforming providers.

Conversely, the Commission cautions against excessive reliance on levies for cost recovery, warning that if not adequately linked to specific regulatory needs, they might impede competition and entry into the market, stifling innovation and productivity growth. High levy costs could pose significant barriers, thus affecting the dynamic efficiency of the financial sector.