Super trustees cannot treat investment governance as a product-selection exercise; APRA expects evidence that every option is controlled across its full lifecycle.
The 30-second take
APRA’s 2025 thematic review covered platforms representing about 95% of platform assets under management and identified weaknesses across eight investment lifecycle areas. Consultation on strengthened standards is due to begin, while enforcement action against five trustees shows the issue has already moved beyond guidance.
The control gap is end to end
APRA’s 19 August 2026 announcement points to reforms covering due diligence, conflicts, fees, liquidity, performance, valuation, monitoring and member outcomes. Those controls cannot sit with separate teams that only meet when something fails.
A trustee needs a traceable line from approval criteria to ongoing monitoring, escalation and exit. If an option changes structure, liquidity or risk profile, the governance response should occur before member harm becomes visible in complaints or losses.
What stronger governance looks like
Boards should require a current inventory of investment options, named owners, decision rights, key dependencies and objective triggers for review. Exceptions need time limits and explicit acceptance.
Member communications and operational readiness should be tested alongside investment analysis, not after it.
Questions for your organisation
- Can we trace each investment option from approval through monitoring and exit?
- Which options rely on stale due diligence or unresolved conflicts?
- Are liquidity, valuation and member-outcome signals reviewed together?
- Who can suspend inflows or remove an option when thresholds are breached?
- Does the board receive evidence of control effectiveness rather than process completion?
Test the lifecycle, not the paperwork
Visit the Innovation of Risk to assess whether your governance controls operate as one accountable system.