The submission supports the use of indicators to assess fund offerings but urges that these reflect the varied membership and avoid incentivising unnecessary complexity or overservicing. Trustees should be able to explain their product strategies and cohorting decisions, ensuring transparency without penalising tailored approaches.

Performance transparency is highlighted, with a recommendation for a “soft” performance test for retirement income products, enabling members to see if their product has underperformed. Portability and the absence of vendor lock-in are also seen as vital for competition and member outcomes.

The submission warns against mandating financial advice provision, arguing that trustees should decide what is appropriate for their members. Engagement metrics should be meaningful and voluntary, tailored to fund demographics.

Member outcome metrics such as drawdown behaviour and product take-up are supported, but must be contextualised by age, balance, and member choice. The right to take lump sums is emphasised, and success should be measured by member autonomy and financial security, not product proliferation.

Trustees should have discretion in defining and reporting on member cohorts, and the government should cover the costs of implementing the reporting framework, ideally via a tax offset.

Ultimately, the submission calls for a framework that evolves with member needs, prioritises simplicity, and delivers genuine transparency for all Australians.