Super funds seek standardised 10-year past performance

Major superannuation fund group, the Association of Superannuation Funds of Australia (ASFA) is urging the Australian Securities and Investments Commission (ASIC) to embed 10 years as the standardised period for advertising the past performance of investments.
ASFA has used a submission responding to ASIC’s update of its Regulatory Guide 234 dealing with Advertising Financial Products and Services to urge the removal of the current five year standardised period and its replacement with the 10 year period.
It said this would “more accurately reflect the longer term nature of investments held in Australia’s superannuation funds”.
It said that where an investment had been available for less than 10 years, ASIC should allow for more standard comparable periods of one, three and five years to be used.
However, it argues that the regulator should not allow reference to performance “from inception” because such references “can lead to confusing comparisons as they are unique to each fund”.
The ASFA response also makes clear that the organisation believes that superannuation fund administrators should be captured by the regulatory requirements.
It said digital platforms and third-party services providers which deliver onboarding and longer term employee administration services should be made clearly subject to the RG 234 requirements.
ASFA also pointed to capture the activities of influencers and social media channels.
It pointed to the need for further guidance expressly on digital channels, for example, search engines, social media, streaming, podcasts, influencer-distributed content), comparison sites, and interactive tools including calculators, with guidance on when such content constitutes ‘advertising’ versus general information.
“This would extend to banner‑style restrictions or tight character limits, and clarification on minimum disclaimer expectations – such as required wording, acceptable placement, and how prominence should be achieved where space is constrained,” ASFA said.
It also suggested a need for clearer guidance on how time-sensitive advertising formats – such as stories, reels, short-form videos and TikTok clips – should be assessed under existing “first-viewer’ expectations and misleading or deceptive conduct provisions would also be of assistance.









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