Why super complaints are becoming a governance test

ASIC’s Report 844 examined how superannuation trustees use complaint information to identify systemic issues and improve member services. The regulator collected information from 45 trustees it regulates and conducted a deeper review of 10 trustees. Its findings were blunt: close to one quarter of trustees were not regularly analysing complaints data to identify systemic problems, even though internal dispute resolution standards require trustees to record, analyse and escalate complaint information.

The figures point to a gap between complaint volumes and trustee learning. ASIC found that 24 of the 45 trustees identified fewer than five systemic issues from complaints over a two-year period, while 14 identified none. The regulator said that low identification can be a warning sign rather than proof that a fund is performing well, particularly where a trustee has a large membership or high complaint numbers.

The timing matters because complaints are already rising. AFCA’s 2025-26 annual review reported 8,755 superannuation complaints, up 42 per cent on the previous year. Complaints about funds refusing to pay claims also increased sharply. These disputes can involve delays, service quality, payment errors, account access, death benefits, disability cover and insurance claims, all of which can have practical consequences for households relying on timely decisions.

For consumers, the takeaway is that documentation and persistence matter. A member who contacts a fund should keep records of dates, reference numbers, documents supplied and responses received. If a matter is unresolved, a written complaint can make the issue clearer and create a record the trustee must handle through its internal dispute resolution process. If the response is late or unsatisfactory, AFCA may be available as an external dispute resolution pathway.

For trustees, the review raises a broader governance challenge. A complaint may begin as an individual dispute, but repeated themes can reveal deeper weaknesses in communication, administration, systems or oversight. ASIC has also signalled that member service remains an enforcement priority, so trustees that fail to act on known weaknesses may face closer regulatory scrutiny.

There are limits to what the review proves. Not every complaint indicates wrongdoing, and funds vary widely in size, structure and the services they provide. However, the report reinforces a simple expectation: superannuation is compulsory for most workers, so funds need complaint systems that not only resolve individual cases, but also prevent avoidable harm from spreading.