Superannuation Auditor Registration Imposition Amendment (ASIC Fees) Act 2018

The Superannuation Auditor Registration Imposition Amendment (ASIC Fees) Act 2018 is a short Commonwealth Act. Its purpose is to amend the Superannuation Auditor Registration Imposition Act 2012.

The operative amendment is very specific. In Schedule 1, item 1, the Act provides that in paragraphs 4(2)(a) and (b) of the principal Act, the amount "$1,000" is omitted and "$3,000" is substituted.

For businesses, the key point is scope. This is not a broad new compliance code for all businesses and it does not rewrite the whole superannuation auditor registration system. It changes a particular amount in a particular part of the principal Act. If your business is in the SMSF audit or specialist accounting space, that can still matter commercially because registration-related costs can affect pricing, staffing and service-line decisions.

The legal change is narrow and easy to state. The Act amends only the amount appearing in paragraphs 4(2)(a) and (b) of the Superannuation Auditor Registration Imposition Act 2012. The old amount was $1,000. The new amount is $3,000.

That means the amendment increases the amount stated in those paragraphs by $2,000. It does not, on the face of this Act, amend every fee, every charge, or every provision dealing with superannuation auditors. It also does not set out the surrounding rules about when the amount becomes payable, who must pay it in a given case, or what procedural steps apply. Those matters sit outside this short amending Act.

This distinction matters in practice. Businesses should avoid over-reading the amendment. The safer approach is to treat it as changing only the amount used when paragraphs 4(2)(a) and (b) of the principal Act are engaged.

The businesses most likely to care about this amendment are those operating in the specialist superannuation audit market. That includes registered superannuation auditors themselves, people applying for registration, and accounting or audit firms that employ or contract those professionals.

The amendment can also matter to firms that reimburse registration-related costs, build those costs into service pricing, or assess the profitability of an SMSF audit practice. If a firm is buying or selling a specialist audit practice, the change may also be relevant to due diligence because recurring regulatory costs affect margins and valuation assumptions.

Most ordinary small businesses are usually outside the practical scope of this Act. A retailer, café, construction business or software startup would not normally need to act on this law unless it is somehow involved in a specialist audit practice or bears the cost of a superannuation auditor registration process.

The Act itself does not spell out the operational trigger points. It simply changes the amount in the principal Act. So the real trigger question is whether paragraphs 4(2)(a) and (b) of the Superannuation Auditor Registration Imposition Act 2012 apply to your situation.

In practical business terms, the issue usually arises when a firm is planning for registration-related activity, reviewing the cost of maintaining a specialist capability, or checking whether internal budgets and templates still use outdated figures. It can also arise in transactions, such as the purchase of an SMSF audit practice, where the buyer wants to confirm that compliance costs have been modelled correctly.

Because this amending Act does not define the underlying circumstances, businesses should not guess. Before making a payment decision, setting a budget, or advising staff, check the current consolidated principal Act and current ASIC materials.

This Act does not impose a long list of standalone operational duties. Its practical compliance effect is that, where the principal Act says paragraphs 4(2)(a) or (b) apply, the amount to use is $3,000 rather than $1,000 from the commencement date.

For businesses, that translates into a set of practical checks. Finance teams, practice managers and advisers should make sure they are not relying on pre-amendment assumptions. Internal budgets, reimbursement policies, due diligence checklists and service pricing models should all be reviewed if they refer to registration-related costs in this area.

If your business documents who bears professional registration expenses, you should also make sure contracts, policies and approval processes reflect the current amount where relevant. The Act is short, but outdated assumptions can still create budgeting errors, pricing issues or misunderstandings with staff.

The Act received Royal Assent on 28 June 2018. Under the commencement table in section 2, the whole Act commenced on the day after Royal Assent, which is recorded as 29 June 2018.

The legislation record identifies the Act as in force. For practical use, that means the amendment forms part of the current legislative framework. Even so, businesses should still check the latest consolidated version of the principal Act and any current ASIC administration material before acting, because this page deals only with the amendment itself.

Example 1. A boutique accounting firm wants to add SMSF audit services. Its business plan uses an old $1,000 figure copied from historical notes. Before approving the plan, the firm should check whether paragraphs 4(2)(a) or (b) of the principal Act are relevant and, if so, update the model to the $3,000 amount.

Example 2. A buyer is reviewing an SMSF audit practice. The target's internal compliance manual still refers to a $1,000 amount. That is a due diligence issue. The buyer should confirm whether the practice has been using current assumptions since 29 June 2018 and whether pricing or profitability analysis needs adjustment.

Example 3. An employer agrees to reimburse a staff member's registration-related costs. Before approving reimbursement, the employer should confirm the current legal amount under the principal Act and make sure internal policy documents do not rely on outdated figures.

This page is most useful as a guide to the amendment itself. Before relying on it in a live matter, there are a few important checks to make.

First, confirm the current text of the Superannuation Auditor Registration Imposition Act 2012, especially paragraphs 4(2)(a) and (b), so you know whether those provisions actually apply to your situation. Second, check current ASIC materials for any administrative requirements, forms or payment processes. Third, if the cost is being allocated inside a business, review employment terms, reimbursement policies, partnership arrangements or pricing assumptions so the commercial burden is clearly understood.

If there is any uncertainty about whether the principal Act applies, or how the cost should be handled in contracts or internal policy, get tailored advice before acting.