The Financial Institutions Supervisory Levies are designed to recover costs incurred by the Australian Prudential Regulation Authority (APRA) for supervising regulated entities, in line with the Australian Government Charging Framework and Cost Recovery Policy (CRP). While most agency costs are covered by this levy, the Australian Securities and Investments Commission (ASIC) recovers its costs through a separate industry funding model.

The Joint Accounting Bodies believe that a CRIS should have been provided before this consultation, according to our interpretation of the CRP. Providing this statement in advance, even in draft form, would help stakeholders better assess the levy's impact.

The Joint Accounting Bodies support maintaining the levies for Small APRA Funds (SAFs) and Single Member Approved Deposit Funds (SMADFs) at $590 per fund. We make no comment on the proposed application of the levies to PSTs in this submission.

We note that for 2025-26, the proposed tiered charging structure in the Discussion Paper remains largely unchanged, with slight increases in the percentage rate of each component.

The Joint Accounting Bodies acknowledge that current government policies aim to encourage mergers to reduce fees for superannuation fund members. However, we believe that there is more work to be done to ensure that members of smaller funds do not form collateral damage.