ASIC RG 276 — ASIC Regulatory Guide – RG 276 Superannuation forecasts: Calculators and retirement estimates

Page 1 REGULATORY GUIDE 276 Superannuation forecasts: Calculators and retirement estimates September 2024 About this guide This guide is for:  superannuation trustees who provide superannuation calculators and retirement estimates to their members; and  other providers of superannuation calculators. It explains what providers need to do to rely on our relief in ASIC Corporations (Superannuation Calculators and Retirement Estimates) Instrument 2022/603 in relation to superannuation calculators and retirement estimates (referred to in this guide as ‘superannuation forecasts’). Page 2 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 2 About ASIC regulatory documents In administering legislation ASIC issues the following types of regulatory documents. Consultation papers: seek feedback from stakeholders on matters ASIC is considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:  explaining when and how ASIC will exercise specific powers under legislation (primarily the Corporations Act)  explaining how ASIC interprets the law  describing the principles underlying ASIC’s approach  giving practical guidance (e.g. describing the steps of a process such as applying for a licence or giving practical examples of how regulated entities may decide to meet their obligations). Information sheets: provide concise guidance on a specific process or compliance issue or an overview of detailed guidance. Reports: describe ASIC compliance or relief activity or the results of a research project. Document history This guide was issued in September 2024 and is based on legislation and regulations as at the date of issue. In April 2026, we updated references to reflect renamed regulatory guidance and legislative instruments and made further minor updates to remove out-of-date information. Previous versions:  Regulatory Guide 276 Superannuation forecasts: Calculators and retirement estimates, issued in July 2022  Regulatory Guide 229 Superannuation forecasts, issued in November 2014 Disclaimer This guide does not constitute legal advice. We encourage you to seek your own professional advice to find out how the Corporations Act and other applicable laws apply to you, as it is your responsibility to determine your obligations. Examples in this guide are purely for illustration; they are not exhaustive and are not intended to impose or imply particular rules or requirements. Page 3 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 3 Contents A Overview ........................................................................................... 4 The purpose and benefits of superannuation forecasts .................... 4 Our relief for superannuation forecasts ............................................. 6 Other requirements that continue to apply ........................................ 7 B Our relief for superannuation forecasts ........................................ 8 Relief for superannuation calculators ................................................ 8 Relief for retirement estimates ........................................................... 9 Breach reporting and record keeping .............................................. 11 Superannuation forecasts that do not rely on our relief ................... 12 Relief for other financial calculators ................................................. 13 C Presentation and disclosure of superannuation forecasts ........... 14 Presentation requirements............................................................... 14 Disclosure requirements .................................................................. 17 No advertising or promotion of specific financial products .............. 18 Good practices for presenting superannuation forecasts ................ 19 When and how retirement estimates may be given......................... 20 D Default assumptions in superannuation forecasts .................... 22 Making assumptions ........................................................................ 22 Investment returns ........................................................................... 28 Retirement income ........................................................................... 29 Factors personal to the user ............................................................ 36 Factors external to the user ............................................................. 38 Ensuring default assumptions are reasonable ................................ 40 Key terms ............................................................................................... 44 Related information ............................................................................... 47 Page 4 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 4 A Overview Key points A superannuation forecast is a numerical indication provided to a superannuation fund member (member) or other person of the balance of their superannuation investment at retirement, or of their income during retirement. A superannuation forecast can be provided in the form of a superannuation calculator or as a retirement estimate. This guide explains the relief we have given to superannuation trustees (trustees) that provide superannuation calculators and retirement estimates to their members. It also explains the relief we have given to other providers of superannuation calculators. This guide sets out: • how our relief for superannuation forecasts applies (see Section B); • how a forecast can be presented, the disclosures it must include, and when and how a retirement estimate may be given (see Section C); and • how the default assumptions that are used in working out a forecast are to be set (see Section D). The purpose and benefits of superannuation forecasts What are superannuation forecasts? RG 276.1 A superannuation forecast is a numerical indication provided to a member or other person (referred to in this guide as a ‘user’) of the balance of their superannuation investment at retirement, or of their income during retirement, taking into account: (a) their current account balance; (b) the impact of fees; and (c) assumptions about future contributions, earnings and other matters. RG 276.2 A superannuation forecast may be provided in the form of a calculator that is not personalised to any particular person and that involves, to some extent, the input of certain information by users of the calculator. RG 276.3 A superannuation forecast may also be generated by a trustee using data it has on a member and provided to the member in the form of a statement (referred to in this guide as a ‘retirement estimate’). This can be a fixed statement (referred to as a ‘static retirement estimate’) or a statement provided through an interactive tool that allows members to input or change certain assumptions (referred to as an ‘interactive retirement estimate’). Page 5 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 5 Potential benefits for users RG 276.4 Most Australians do not engage fully with their superannuation. They may have little idea of how much income they will have in retirement and how this compares to the amount they will need. RG 276.5 Superannuation forecasts can help some users to think about how superannuation can be part of their retirement income by, for example, prompting them to review their situation and seek further information. RG 276.6 Superannuation calculators (sometimes called ‘retirement calculators’) can allow users to explore their future retirement income by inputting their own information or assumptions. For example, calculators may be used to illustrate the effects on a user’s retirement benefit of: (a) making alternative decisions; (b) paying different levels of fees; or (c) retiring at different ages. RG 276.7 Retirement estimates can provide an accessible starting point for members to consider whether their superannuation is likely to provide them with adequate income in retirement. Such forecasts may serve as a prompt for further investigation of issues that are relevant to a member’s retirement income. RG 276.8 We think that superannuation calculators and retirement estimates both play an important and complementary role. RG 276.9 However, both types of superannuation forecast have limitations. They are based on assumptions about economic and financial conditions over long periods, as well as assumptions about a user’s future circumstances (e.g. income and retirement age). This means there are inherent limitations on the accuracy of these forecasts and thus on their usefulness as a basis for making financial decisions. Superannuation forecasts may involve personal advice RG 276.10 Superannuation forecasts, whether delivered as a superannuation calculator or a retirement estimate, may involve personal advice. RG 276.11 Without relief, trustees that give their members superannuation forecasts may need to hold an Australian financial services (AFS) licence with an authorisation to give personal advice, and comply with requirements relating to personal advice in Corporations Act 2001 (Corporations Act), including the requirement to prepare Statements of Advice, when providing superannuation forecasts. RG 276.12 Without our relief, these requirements would also apply to providers of superannuation calculators who are not trustees. Page 6 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 6 Our relief for superannuation forecasts RG 276.13 ASIC understands that regulatory requirements under the Corporations Act and/or uncertainty about how they apply may inhibit the provision of superannuation calculators and retirement estimates, particularly because these tools are often provided free of charge. RG 276.14 For this reason, we have given relief to providers of superannuation forecasts in ASIC Corporations (Superannuation Calculators and Retirement Estimates) Instrument 2022/603 (referred to in this guide as ‘our relief’). RG 276.15 ASIC Instrument 2022/603 gives relief from requirements relating to financial product advice in the Corporations Act. The instrument does not give relief from other relevant provisions relating to superannuation forecasts, such as prohibitions on misleading or deceptive conduct: see RG 276.21–RG 276.24. RG 276.16 Under our relief, providers of superannuation forecasts must take steps to minimise the risk of their forecasts being misleading. Our relief also does not permit providers to use forecasts to advertise or promote specific financial products. We do not think that this is consistent with the purpose of superannuation forecasts and would pose particular risks to consumers: see RG 276.86–RG 276.93. RG 276.17 To rely on our relief: (a) a superannuation forecast must meet certain mandatory disclosure and presentation requirements, and must not advertise or promote a specific financial product (see Section C); and (b) the default assumptions used to work out the superannuation forecast must be reasonable and set according to our requirements (see Section D). RG 276.18 It is not mandatory for a trustee to provide superannuation calculators or retirement estimates to its members. However, trustees may choose to make use of our relief in ASIC Instrument 2022/603 to help members think about how much income they could have in retirement. RG 276.19 Trustees could do this by: (a) allowing members to input their own information into a superannuation calculator to obtain an indication of their retirement income; or (b) providing members with a retirement estimate. RG 276.20 Members can also access the general information about superannuation and retirement income, including calculators, that is available on ASIC’s Moneysmart website to help them understand how various factors may influence their superannuation balance and retirement income. Page 7 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 7 Other requirements that continue to apply RG 276.21 Superannuation forecasts, including the accompanying disclosures, are subject to the prohibition against misleading or deceptive conduct in the Corporations Act and the Australian Securities and Investments Commission Act 2001 (ASIC Act). A provider must not give a user a superannuation forecast if doing so would be misleading or likely to mislead. RG 276.22 The prohibition on misleading or deceptive conduct applies regardless of whether or not superannuation forecasts are provided under our relief. However, we are likely to take into account whether a provider of a superannuation forecast is complying with the requirements of the relief in ASIC Instrument 2022/603 when considering action for misleading or deceptive conduct. RG 276.23 Providers of superannuation forecasts can reduce the risk of the forecast being misleading or likely to mislead by following the guidance we have set out in this guide, including our guidance on: (a) presenting and disclosing forecasts in Section C; and (b) setting reasonable default assumptions in Section D. RG 276.24 We consider that providers who rely on our relief to provide superannuation forecasts are likely to meet the requirement to ensure they have reasonable grounds for making a representation in relation to a future matter concerning a financial product: see s769C of the Corporations Act, s12BB of the ASIC Act. This is on the basis that the trustee or other provider complies with all requirements of our relief, including the requirement that the assumptions are reasonable for the purpose of working out the calculation or estimate. Page 8 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 8 B Our relief for superannuation forecasts Key points ASIC Instrument 2022/603 gives relief from requirements relating to personal advice in the Corporations Act, subject to conditions, to providers of: • superannuation calculators (see RG 276.25–RG 276.28); and • retirement estimates (see RG 276.29–RG 276.42). There are requirements to notify ASIC of non-compliance with the relief and keeping records: see RG 276.43–RG 276.49. Providers of superannuation forecasts that do not meet the requirements of our relief in ASIC Instrument 2022/603 may: • provide a user with a forecast that involves providing personal advice and by complying with the personal advice requirements in the Corporations Act; • seek individual relief; or • provide a user with a forecast that is factual information: see RG 276.50– RG 276.56. Relief is also available for generic financial calculators that are not superannuation calculators: see RG 276.57–RG 276.60. Relief for superannuation calculators RG 276.25 A superannuation calculator can be a facility, device, table or other thing (including an online tool) that uses, as a minimum, certain default assumptions to work out a numerical calculation (or find out the result of a numerical calculation) about a superannuation product. RG 276.26 We give relief to providers of superannuation calculators from the requirement to hold an AFS licence: see ASIC Instrument 2022/603. Where providers already hold an AFS licence, we give relief from the requirements relating to advice in Divs 2, 3 and 4 of Pt 7.7 of the Corporations Act. RG 276.27 Unlike retirement estimates, a superannuation calculator does not use information the provider (such as a trustee) may hold about a user unless the user has inputted that information. RG 276.28 Our relief for superannuation calculators is given on certain conditions: (a) the superannuation calculator does not advertise or promote a specific financial product and complies with presentation and disclosure requirements (see Section C); and (b) the default assumptions are reasonable and set according to our requirements (see Section D). Page 9 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 9 Relief for retirement estimates RG 276.29 A retirement estimate is a superannuation forecast generated by a trustee using data it has on a member and provided to the member in the form of a statement. RG 276.30 An interactive retirement estimate is a retirement estimate provided through an interactive tool that allows members to input or change certain assumptions. It differs from a superannuation calculator in that the default assumptions are based on data a trustee has on the member (rather than being generic defaults). RG 276.31 ASIC Instrument 2022/603 provides licensing relief to trustees who give retirement estimates to their existing members. Where a trustee already holds an AFS licence, we give relief from the requirements relating to advice in Divs 2, 3 and 4 of Pt 7.7 of the Corporations Act. RG 276.32 Our relief for retirement estimates is given on certain conditions: (a) the retirement estimate does not advertise or promote a specific financial product (except to the extent necessary to provide the estimate) and it complies with presentation and disclosure requirements (see Section C); (b) the retirement estimate is included in, or accompanies, the member’s periodic statement or is made available electronically through the member’s online portal (see Section C); and (c) the member’s retirement benefit is worked out using the default assumptions, except to the extent that the member inputs or changes the assumptions in an interactive retirement estimate (see Section D). RG 276.33 Our relief for retirement estimates is limited to retirement estimates provided to members who: (a) have been members of the fund for the year ending on the date of the estimate; (b) are not receiving a transition to retirement income stream in relation to the superannuation entity at the date of the estimate; (c) in the case of a static retirement estimate—hold a superannuation product that is in the accumulation phase at the date of the estimate; (d) have made or received a contribution to their account with the fund in the 16 months before the date of the estimate (unless the member holds a superannuation product in the retirement phase at the date of the estimate); (e) have an account balance with the fund of $6,000 or greater at the date of the estimate; and (f) do not a have a defined benefit interest in the fund. RG 276.34 We have restricted the cohort of members who may receive retirement estimates because, for those groups of members who are excluded, we consider that a retirement estimate is likely to be misleading, regardless of how the retirement estimate is worked out. Page 10 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 10 RG 276.35 For example, a retirement estimate is likely to be misleading for members who do not have a predictable pattern or level of future contributions, or for whom the economic and financial assumptions a trustee may set under our relief are unlikely to be suitable (such as members with a transition to retirement income stream or defined benefit interest). RG 276.36 Some restrictions on the cohort of members who may receive retirement estimates are point-in-time characteristics. This means that individual members may move in and out of this cohort over time. For example, a member in the accumulation phase with an account balance below $6,000 and no contributions could be given a retirement estimate when their account balance has increased to $6,000 or greater and a contribution has been made or received. RG 276.37 The relief for retirement estimates is limited to the cohort of members in RG 276.33, but this does not mean that trustees should give retirement estimates to all of these persons. Trustees must not give a retirement estimate to a member in this cohort if it is misleading or likely to mislead: see RG 276.21– RG 276.23. RG 276.38 Trustees seeking to provide retirement estimates to members who do not meet the criteria in ASIC Instrument 2022/603 can apply for individual relief: see RG 276.50–RG 276.53. How the relief applies to users in the accumulation and retirement phase RG 276.39 A provider can make available a superannuation calculator to users who are currently in either the accumulation or retirement phase under our relief. RG 276.40 A trustee may give a static retirement estimate to a member who is in the accumulation phase under our relief, but not to a member who holds a superannuation product in the retirement phase. We think it can be misleading to give static retirement estimates to members in the retirement phase because the member would not be able to input or change the assumptions to better match their current personal circumstances (e.g. assumptions relating to age pension eligibility in a situation where the member may have already reached the age pension age). RG 276.41 A trustee may choose to give an interactive retirement estimate to members who are currently in either the accumulation or retirement phase under our relief. An interactive retirement estimate allows members to input or change the assumptions and so reduces the risk that the estimate will be misleading. RG 276.42 However, a trustee must not give a retirement estimate (static or interactive) to members who receive a transition to retirement income stream or who have a defined benefit interest in the fund. A retirement estimate worked out in accordance with the default assumptions required in ASIC Instrument 2022/603 is likely to be misleading for these members: see RG 276.35. Page 11 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 11 Breach reporting and record keeping Notifying ASIC of breaches RG 276.43 The requirement to notify ASIC of breaches is an important element of the effective regulation of superannuation forecasts. It is also consistent with our approach in ASIC Corporations (Generic Calculators) Instrument 2026/41: see Regulatory Guide 167 AFS licensing: Discretionary powers (RG 167) at RG 167.111–RG 167.116. RG 276.44 If a provider is relying on our relief and has reasonable grounds to believe it has failed, other than in an immaterial respect, to comply with a condition, the provider must notify ASIC of the breach in writing within 30 days of becoming aware of the breach. RG 276.45 Whether a breach is material will depend on the individual circumstances of the breach. Consistent with our approach in ASIC Instrument 2026/41, we consider that an immaterial breach is a breach of a technical or trivial kind. In the case of superannuation calculators and interactive retirement estimates, see the example in RG 167 at RG 167.114. RG 276.46 A provider should report a breach through the ASIC Regulatory Portal. For information on how to notify ASIC of reportable situations through the portal, see How to submit a reportable situation on the ASIC website. RG 276.47 In determining any regulatory response, we will consider the nature, scope and effect of any breach, including whether the provider has identified the cause of the breach and addressed it so that it is unlikely to recur. Keeping records RG 276.48 A trustee or other provider must keep a copy of the superannuation calculator or retirement estimate provided under our relief for seven years from the date the calculator or estimate was last made available. RG 276.49 In the case of a superannuation calculator that is an electronic facility or device, and an interactive retirement estimate: (a) the copy held by the trustee or provider must be functional—that is, able to reproduce each actual use of the calculator or estimate by an individual user; and (b) the calculator or estimate must not prevent the user from readily printing or electronically storing the estimate. Page 12 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 12 Superannuation forecasts that do not rely on our relief RG 276.50 We think that the relief in ASIC Instrument 2022/603 balances two elements: the need to encompass a wide variety of situations and superannuation products, and the need to keep the relief arrangements simple and relevant for most cases. RG 276.51 In some situations, it may not be appropriate or possible for a provider to rely on the relief in ASIC Instrument 2022/603. In these situations, a provider seeking to provide a superannuation forecast can do so by: (a) giving the user a forecast that involves providing personal advice and by complying with the personal advice requirements in the Corporations Act; (b) applying to ASIC for individual relief; or (c) giving the user a forecast that is factual information (see RG 276.54– RG 276.56). RG 276.52 If a provider already holds an AFS licence with an authorisation to give personal advice, the provider is free to give personal advice in any way it chooses, including by giving forecasts, as long as the personal advice requirements in the Corporations Act are complied with. RG 276.53 Where it is not practical to give licensed personal advice that complies with all of the requirements in the Corporations Act, providers could apply to ASIC for individual relief. In assessing applications for relief, ASIC considers the likelihood of user detriment and how to minimise the scope for superannuation forecasts to be used to advertise or promote financial products, among other factors. Note: For more information on ASIC’s powers to give relief, including factors we may consider and how to apply for relief, see Regulatory Guide 51 Applications for relief (RG 51) and Section B of RG 167. Calculators and estimates that are factual information RG 276.54 If a provider does not provide financial product advice when giving a user a superannuation calculator or retirement estimate, it is likely to be providing factual information and may not need to rely on the relief in ASIC Instrument 2022/603. Note: For more information on providing factual information, and the difference between factual information and financial product advice, see Regulatory Guide 36 Licensing: Financial product advice and dealing (RG 36) and Regulatory Guide 244 Giving information, general advice and scaled advice (RG 244). RG 276.55 Examples of a superannuation calculator or retirement estimate that may be factual information include: (a) a superannuation calculator that works out the amount of a user’s compulsory superannuation contributions based on information the user has inputted about their salary; and Page 13 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 13 (b) a retirement estimate given to a member who is about to retire that shows their lump sum on retirement and does not require assumptions to be made about future contributions or investment earnings. RG 276.56 If a user is given a superannuation calculator or retirement estimate that is factual information, the provider should inform the user that it is only factual information and not general or personal advice. Relief for other financial calculators RG 276.57 ASIC provides relief under ASIC Instrument 2026/41 for providers of certain other financial calculators from certain requirements relating to personal advice in the Corporations Act. This relief has been in place since 2005. RG 276.58 ASIC Instrument 2026/41 gives relief from the requirement to hold an AFS licence to providers of financial calculators that do not advertise or promote a specific financial product. Where providers already hold an AFS licence, it gives relief from the requirements relating to advice in Divs 2, 3 and 4 of Pt 7.7 of the Corporations Act: see Section E of RG 167. RG 276.59 ASIC Instrument 2026/41 applies to financial calculators in general (excluding superannuation calculators), such as calculators relating to insurance. RG 276.60 A calculator that relates to a superannuation product is not covered by the relief in ASIC Instrument 2026/41, even if it also relates to other kinds of financial product. Page 14 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 14 C Presentation and disclosure of superannuation forecasts Key points Providers of superannuation calculators and retirement estimates have flexibility in how they present forecasts to users, subject to meeting the requirements in ASIC Instrument 2022/603. For retirement estimates, these requirements include presenting the retirement benefit as a retirement balance and as an annual income stream: see RG 276.61–RG 276.79. Providers must disclose how the forecast was worked out and its limitations but have flexibility in how they make these disclosures: see RG 276.80– RG 276.85. Providers must not use a superannuation forecast to advertise or promote a specific financial product: see RG 276.86–RG 276.93. We expect providers to adopt good practices that can help users to think about their income in retirement: see RG 276.94–RG 276.98. Superannuation trustees can give a retirement estimate to a member: • at the same time as their periodic statement, or at any time if delivered electronically through the member’s online portal (see RG 276.99– RG 276.104); and • as an interactive retirement estimate that allows the member to input or change certain assumptions (see RG 276.105–RG 276.108). Presentation requirements RG 276.61 Providers of superannuation forecasts have flexibility in how they can present these forecasts to users, provided they meet the requirements in ASIC Instrument 2022/603 relating to: (a) elements that must or must not be presented as part of a forecast (see RG 276.66–RG 276.79); (b) required disclosures (see RG 276.80–RG 276.85); (c) not advertising or promoting a specific financial product (see RG 276.86–RG 276.93); and (d) setting the default assumptions (see Section D). RG 276.62 Providers must also not provide a forecast if it is misleading or likely to mislead: see RG 276.21–RG 276.23. RG 276.63 Providers may make their own choices about: (a) the branding, design and layout of the forecast; (b) the placement of the required disclosures; Page 15 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 15 (c) the inclusion, or otherwise, of diagrams, tables and graphs; and (d) whether to provide the forecast in writing, or by video or audio: see also RG 276.102. RG 276.64 We think that giving trustees and other providers flexibility in how they present superannuation forecasts will allow them to tailor these forecasts to the needs of their users. We think that a flexible approach can also support innovation in developing new and effective ways to communicate with users. RG 276.65 However, we expect providers to take a consumer-centric approach by using this flexibility in a way that is helpful for users and consistent with the purpose of superannuation forecasts to provide some users with an indication of how much income they could have in retirement. We have identified some good practices for providers to consider when giving a superannuation forecast: see RG 276.94–RG 276.98. Superannuation calculators RG 276.66 Our relief does not prescribe how to present a superannuation calculator. Providers of superannuation calculators have discretion whether or not to: (a) display a forecast of a user’s superannuation balance at retirement, annual retirement income, or both; (b) include age pension amounts in retirement income; (c) allow the user to calculate how long a specified annual spending level could be sustained in retirement; (d) present the result in the form of a confidence interval (i.e. range) or display numerical confidence or risk levels alongside the result (see RG 276.166–RG 276.172); or (e) illustrate the effect of alternative scenarios (based on different combinations of assumptions). RG 276.67 We think that providers should have flexibility to design superannuation calculators that meet the needs of their users, subject to meeting the requirements in ASIC Instrument 2022/603: see RG 276.61. RG 276.68 A superannuation calculator must contain the required disclosures, including a clear and prominent statement of what assumptions have been used in working out the calculation and an explanation of why these assumptions are reasonable for the purpose of working out the calculation: see RG 276.80– RG 276.85. Page 16 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 16 Retirement estimates RG 276.69 To rely on the relief given in ASIC Instrument 2022/603, a trustee must present certain elements as part of a retirement estimate (including an interactive retirement estimate). RG 276.70 Setting presentation requirements ensures that key elements are present in all retirement estimates. This will help members to know what to look for in their retirement estimate, particularly those members who move to a different superannuation fund, or who have more than one fund. RG 276.71 The amount shown as the estimated retirement benefit must be presented in today’s dollars: see RG 276.188. RG 276.72 The estimated retirement benefit must also be presented as both: (a) a retirement balance (i.e. the estimated lump sum amount at retirement); and (b) an annual income stream (i.e. retirement income). RG 276.73 Both the retirement balance and annual income stream must be rounded to the nearest three significant figures. For example, an amount of $23,289 should be rounded to $23,300. RG 276.74 The annual income stream may be presented as an income amount for each year of the drawdown period or as an annual average income amount. Age pension amounts may be included as part of the annual income stream: see RG 276.160–RG 276.165. RG 276.75 An interactive retirement estimate may include risk measures alongside the primary (or central) estimate of the member’s retirement benefit (retirement balance and annual income): see RG 276.166–RG 276.172. RG 276.76 Under our relief, a static retirement estimate may show only one estimate of the member’s retirement benefit (retirement balance and annual income). It cannot contain risk measures or be used to illustrate the effect of alternative scenarios. We consider that including additional features in a static retirement estimate will undermine the key message and may be confusing for members. RG 276.77 A retirement estimate must also contain the required disclosures, including a clear and prominent statement of what assumptions have been used in working out the estimate and an explanation of why these assumptions are reasonable for the purpose of working out the estimate: see RG 276.80–RG 276.85. RG 276.78 Additional information may be presented alongside a retirement estimate. For example, a trustee could include a statement that the member can see how changes in factors such as contribution rates or their retirement age can affect their retirement income by using an interactive retirement estimate or superannuation calculator. A trustee could also present factual information alongside an estimate (such as information about age pension eligibility Page 17 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 17 criteria and payment rates) or a qualitative explanation of the risk or uncertainty inherent to the estimate. RG 276.79 Additional information may help members to understand their forecasts. However, any additional information must not be misleading and must not be used to advertise or promote a specific financial product: see RG 276.21– RG 276.23 and RG 276.86–RG 276.93. Disclosure requirements RG 276.80 Superannuation forecasts have the potential to mislead or confuse users. Clear and accurate disclosure is necessary (but not sufficient) to help manage these risks, including the risk of users thinking that a forecast can be relied on to make a decision about a specific financial product. Note: For other practices that can help manage the risks of misleading or confusing users, see RG 276.94–RG 276.98. RG 276.81 ASIC Instrument 2022/603 requires providers of superannuation forecasts to disclose certain information as part of the forecast if they are to rely on our relief. RG 276.82 To rely on our relief, providers must take reasonable steps to ensure the superannuation calculator or retirement estimate displays, or has printed on it, a clear and prominent: (a) statement about the purpose and limitations of the calculator or estimate; (b) explanation of the impact of any significant limitation of the calculator or estimate; (c) statement of the assumptions; (d) explanation of why the assumptions (unless inputted or changed by the user) are reasonable for the purpose of working out the calculation or estimate; (e) statement setting out the value of the calculation or estimate in today’s dollars (i.e. present value) and identifying that the amount is the value of the calculation or estimate (see RG 276.188–RG 276.197); and (f) statement to the effect that the superannuation calculator or retirement estimate is not intended to be relied on for the purpose of making a decision about a financial product and that users should consider obtaining advice from an AFS licensee before making any financial decisions. RG 276.83 The required disclosures in RG 276.82 must contain as much detail as a retail client using the superannuation calculator or retirement estimate would reasonably expect to find given the nature of the calculator or estimate. RG 276.84 There are limits to the effectiveness of disclosure. For example, not all users read disclosure material or respond to disclosures in the same way. We Page 18 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 18 expect providers to present superannuation forecasts, including the mandatory disclosures, in a way that minimises confusion for the users who are using the forecast. For guidance on good practices, see RG 276.94– RG 276.98. Note: For more information on the limitations of disclosure, see Report 632 Disclosure: Why it shouldn’t be the default (REP 632) released 14 October 2019. RG 276.85 As part of the requirement to give a clear and prominent explanation of why the default assumptions are reasonable, a trustee giving a retirement estimate may provide a clear and prominent statement that: (a) some assumptions are based on the member’s superannuation product, investment strategy or other personal factors; and/or (b) some default assumptions do not necessarily reflect the way the member’s superannuation is currently invested. No advertising or promotion of specific financial products RG 276.86 It is a requirement of our relief that: (a) a superannuation calculator must not advertise or promote a specific financial product; and (b) a retirement estimate must not advertise or promote a specific financial product other than to the extent necessary to provide the estimate. RG 276.87 If a superannuation forecast advertises or promotes a specific financial product (e.g. one of a trustee’s superannuation or retirement income products), it increases the risk that users will, for example: (a) misunderstand the purpose of the forecast; (b) place too much reliance on the forecast when making financial decisions; (c) assume the forecast is a complete substitute for personal advice from a registered financial adviser who is authorised to provide personal advice; and (d) assume the forecast is making a recommendation that is in the user’s best interest and takes into account their objectives, financial situation and needs. RG 276.88 Our approach to the requirements in ASIC Instrument 2022/603 is consistent with our approach to the requirements in ASIC Instrument 2026/41 (as it applies to other generic financial calculators) and our guidance in RG 167 at RG 167.72–RG 167.79. RG 276.89 We consider that a superannuation forecast does not advertise or promote a specific financial product merely because the default assumptions are the same as the actual features of a specific financial product (e.g. fees) or set Page 19 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 19 with regard to a specific financial product (e.g. rate of investment earnings). Providers may refer to the specific financial product, but only as part of the mandatory disclosures about why the assumptions are reasonable for working out the estimate and only if it is material to that disclosure. RG 276.90 If a provider refers to a specific product in their disclosure, they should ensure that the disclosure is less prominent than any other information about the reasonableness of assumptions and the calculator or estimate itself. This is consistent with our guidance for generic calculators in RG 167 at RG 167.95–RG 167.96. RG 276.91 For retirement estimates, we recognise that it may not be possible for a trustee to omit the name of the superannuation product(s) or investment option(s) a member is currently invested in, as retirement estimates may be given on or with a periodic statement or via a member’s online portal: see RG 276.99– RG 276.104. Omitting this information may also be confusing for the member. RG 276.92 We consider that referring to the member’s current superannuation product or investment option(s) is necessary for providing a retirement estimate and would not in itself breach the requirement in ASIC Instrument 2022/603 to not advertise or promote a specific financial product. RG 276.93 However, a trustee may breach the requirement if the trustee refers to other products or investment options that the member is not currently invested in, or that are not relevant to the retirement estimate provided to the member. For example, referring to a specific retirement product may not be relevant except where certain default assumptions for the retirement phase have been set with regard to that product, and the disclosure referring to the specific product is less prominent than other information: see RG 276.89–RG 276.90. Good practices for presenting superannuation forecasts RG 276.94 We expect providers of superannuation forecasts to provide these forecasts in a way that helps users think about their income in retirement. We acknowledge different users will interpret and use superannuation forecasts in different ways. We also acknowledge that disclosure alone does not remove the risk of users being confused by forecasts or using them in unintended ways: see RG 276.84. RG 276.95 We expect providers to present forecasts in a consumer-centric way that puts the needs of the user first. To do this, they should consider how different users may use their superannuation forecasts and use insights into user behaviour to inform how they give forecasts. Providers should design their forecasts to meet the needs of users while seeking to minimise confusion, misunderstanding and overreliance on forecasts (e.g. by using simple language to explain the forecast, outlining which factors have and have not been taken into account, and layering the disclosures based on which information users may find most useful). Providers should consider the limitations of disclosure and ways in which quantitative information can be misunderstood. Page 20 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 20 RG 276.96 Providers should consider the overall framing of a superannuation forecast and any information that accompanies it. The way a forecast is presented, or the material that sits alongside it, could be confusing for some users, particularly if it acts to undermine the purpose of the forecast. It could also, in some circumstances, be misleading or likely to mislead. RG 276.97 We especially encourage providers to monitor—and undertake testing—to understand if and how users access, understand and use superannuation forecasts and the information being conveyed. Providers should seek to draw on credible and reliable data sources and information that is fit for purpose and unbiased. This can help to manage the risks that forecasts may confuse users and can provide a rich evidence base for providers to refine and improve their forecasts to suit the needs of users. RG 276.98 We think it is good practice to refer users to other sources of information or tools they may find helpful. This could include referring users to a superannuation calculator or an interactive retirement estimate, or to ASIC’s Moneysmart website. When and how retirement estimates may be given RG 276.99 If a trustee relies on the relief we have given in ASIC Instrument 2022/603 for retirement estimates, it may give its members their retirement estimates at the same time as it gives them their periodic statements. Receiving their statements and retirement estimates at the same time may also enhance members’ understanding of both documents, as they will be able to cross- reference information in each. RG 276.100 If a trustee chooses to give a retirement estimate alongside a periodic statement, it has flexibility in whether to incorporate the retirement estimate into the same document as the periodic statement or provide it in a separate document that accompanies the periodic statement. This is regardless of whether members receive their periodic statement in writing or electronically. RG 276.101 For example, if a member is sent their periodic statement by mail, and the trustee produces a separate retirement estimate for them, the two documents should be mailed together. If the member is provided with an email notification that their periodic statement is available for viewing online, the notification should also refer them to the retirement estimate. RG 276.102 A retirement estimate will usually be in the form of a written statement, but it does not have to be. A trustee may choose to give a retirement estimate to its members in another format, such as by video or audio, or a combination of formats. If a trustee does so, the estimate must meet all the requirements of ASIC Instrument 2022/603, including requirements for the presentation and disclosure of retirement estimates as set out in this section. Page 21 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 21 RG 276.103 A trustee may also give members their retirement estimates electronically when they log in to the fund’s website to access their account information using the member’s online portal. We think that making a retirement estimate visible on a member’s online portal may make it more likely that the member will see and engage with their retirement estimate. It would also allow members to cross-reference the retirement estimate with other information in their online portal, and it may allow members to receive more timely estimates based on their current balance in the fund. RG 276.104 If a trustee chooses to give a member their retirement estimate through the member’s online portal, it is not required to also provide a retirement estimate on (or alongside) their periodic statement, and vice versa. However, a trustee may choose to deliver retirement estimates to a member through both the member’s online portal and the periodic statement. There are no restrictions on how frequently trustees may give a retirement estimate to their members. Interactive retirement estimates RG 276.105 An interactive retirement estimate is a retirement estimate that is worked out using data a trustee has on a member, but where the member can also interact with the estimate by inputting or changing certain assumptions. For example, the estimate could be an electronic facility on a member’s online portal. RG 276.106 An interactive retirement estimate differs from a superannuation calculator because the default assumptions are based on data a trustee has on the member (rather than being generic defaults): see RG 276.30. RG 276.107 We think that interactive retirement estimates can help members to engage with their estimate by inputting information or changing assumptions to better reflect their personal circumstances or to explore the impact of different scenarios. Interactive retirement estimates allow members to do this without needing to access a superannuation calculator and re-input information about their age, current balance and other factors. RG 276.108 If a trustee chooses to provide an interactive retirement estimate, it must: (a) set the default assumptions according to the requirements in ASIC Instrument 2022/603 for retirement estimates, including using specific types of data a trustee has about its members (see Section D); and (b) allow the member to change any of the assumptions that are applied in working out the estimate, except for statutory assumptions or assumptions about how the superannuation balance is drawn down in retirement (excluding the retirement age and length of the drawdown period, which the user must be allowed to change) (see RG 276.118). Page 22 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 22 D Default assumptions in superannuation forecasts Key points ASIC Instrument 2022/603 sets out requirements for the default assumptions trustees and other providers must set for a superannuation calculator or retirement estimate when relying on our relief: see RG 276.109–RG 276.123. These requirements vary depending on whether the assumptions relate to: • investment returns (see RG 276.124–RG 276.136); • retirement income (see RG 276.137–RG 276.172); • factors personal to the user (see RG 276.173–RG 276.187); or • factors external to the user (see RG 276.188–RG 276.200). Where providers have flexibility to set their own default assumptions, they must ensure that these assumptions are reasonable for the purpose of working out the calculation or estimate: see RG 276.201–RG 276.222. Making assumptions RG 276.109 Superannuation forecasts (i.e. superannuation calculators and retirement estimates) involve a degree of inherent uncertainty. This is because the forecasting process requires making assumptions about several factors. What eventuates is likely to differ from what is assumed will occur. RG 276.110 Some inputs to a forecast depend on known facts that are personal to the user (e.g. their current account balance). Others involve factors that are inherently uncertain (e.g. rates of future investment earnings) or factors that may be known to a user but not a provider (e.g. future intentions to make voluntary contributions or spend time out of the workforce). RG 276.111 Although superannuation forecasts have some limitations and are likely to differ from what actually occurs, these forecasts have a useful role to play. In ASIC’s view, the purpose of a superannuation forecast is not to give an exact prediction of a user’s retirement balance or retirement income. RG 276.112 As noted in Section A of this guide, we think that the primary purpose of: (a) a superannuation calculator is to allow users to explore how various factors or scenarios may affect their future retirement income; and (b) a retirement estimate is to provide an accessible starting point for members to consider whether their superannuation is likely to provide them adequate income in retirement. RG 276.113 The assumptions used to provide a superannuation forecast should be reasonable for the users who are likely to be using a superannuation calculator or are receiving a retirement estimate. It is important that users Page 23 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 23 have confidence in how a forecast is being made, including the quality of the assumptions. Even where a user can change the assumptions, behavioural economics research suggests that default settings are powerful and users are reluctant to change them. Selecting and setting default assumptions RG 276.114 ASIC has set standardised assumptions that trustees and other providers must use when relying on the relief provided in ASIC Instrument 2022/603 to provide a superannuation calculator or retirement estimate. Some standardised assumptions are defaults that a user can change in a superannuation calculator or interactive retirement estimate. We have also given trustees and other providers the flexibility to set their own reasonable assumptions in some cases. Note: An interactive retirement estimate is a retirement estimate that is worked out using data a trustee has on a member and where the member can interact with the estimate by inputting or changing certain assumptions: see RG 276.105–RG 276.108. RG 276.115 Table 1–Table 4 summarise the requirements relating to assumptions in ASIC Instrument 2022/603. These requirements are based on stakeholder consultation and advice from the Australian Government Actuary. Note: For more information on the stakeholder consultation, see Report 731 Response to submissions on CP 351 Superannuation forecasts: Update to relief and guidance (REP 731) released 5 July 2022. RG 276.116 We think the requirements for setting assumptions need to be stricter for retirement estimates than for superannuation calculators. This is because a retirement estimate contains personalised information and it may be provided to a member without the member having to request it (i.e. the estimate is unsolicited by the member). By contrast, a user needs to actively choose to use a superannuation calculator, and the inputs and assumptions can be freely manipulated based on a generic starting position. RG 276.117 It is a requirement of ASIC Instrument 2022/603 that all assumptions applied by a provider to a superannuation calculator or retirement estimate (i.e. default assumptions) are reasonable for working out the calculation or estimate. We have provided guidance on how trustees and other providers can set their own reasonable assumptions: see RG 276.201–RG 276.222. RG 276.118 A superannuation forecast can also be worked out using assumptions inputted or selected by users instead of default assumptions. If the superannuation calculator is an electronic facility or device, or if the retirement estimate is an interactive retirement estimate, it must: (a) allow the user to input or change any of the assumptions that are applied by the calculator or estimate, except for the following (which the provider may choose to fix or allow the user to change): (i) assumptions that reflect certain statutory fixed factors (e.g. taxation rates); Page 24 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 24 (ii) assumptions about how the superannuation balance is drawn down in retirement (excluding the retirement age and length of the drawdown period, which the user must be allowed to change); and (b) work out, or enable the user to work out, a forecast on the basis of the changed assumptions. RG 276.119 Providers can meet the requirement in RG 276.118(a) by requiring a user to directly input their own assumptions or by inputting assumptions directly with the consent of the user. For example, a trustee could provide a function that helps users to copy across account data into a superannuation calculator or interactive retirement estimate. RG 276.120 Providers can meet the requirement in RG 276.118(b) by using assumptions inputted or changed by the user on a previous occasion (e.g. as a starting point when the user next accesses the calculator or interactive estimate, instead of reverting to generic defaults). However, in this case, the provider should take steps to ensure they are not misleading or confusing the user. Assumptions inputted by user could become outdated if a significant period of time has elapsed, or unrealistic if the user had previously been inputting assumptions to explore extreme scenarios. RG 276.121 ASIC Instrument 2022/603 does not allow trustees to use data a member has inputted into a calculator or an interactive retirement estimate to tailor a static retirement estimate given to the member under our relief. We think the risk of misleading or confusing the member is greater in these circumstances because the data the member inputted may not be accurate, and members cannot input or change assumptions in a static retirement estimate. RG 276.122 Providers of superannuation calculators and interactive retirement estimates relying on our relief may choose to require users to input information or assumptions before a forecast is shown. For example, a provider might require a user to input their desired retirement age or partner status before a forecast is shown. The provider does not need to apply any default assumptions about factors for which users are required to input a value, including factors where we have set standardised default assumptions. RG 276.123 A superannuation calculator or retirement estimate must include clear statements about the limitations of the calculator or estimate and why the provider considers the default assumptions to be reasonable: see RG 276.80–RG 276.85. Page 25 REGULATORY GUIDE 276: Superannuation forecasts: Calculators and retirement estimates © Australian Securities and Investments Commission September 2024 Page 25 Table 1: Default assumptions about a user’s investment returns Assumption Superannuation calculators Retirement estimates Investment earnings, fees and costs The default assumptions about investment earnings, investment fees and costs, and administration fees must be reasonable for the purpose of working out the calculation: see also RG 276.124–RG 276.130. The assumptions may be based on specific financial products as long as the superannuation calculator does not advertise or promote those products: see also RG 276.86–RG 276.93. The default assumptions about investment earnings, investment fees and costs must be reasonable for the purpose of working out the estimate: see also RG 276.124–RG 276.130. The trustee must make reasonable assumptions about administration fees based on the administration fees payable by the member on their superannuation account: see also RG 276.131–RG 276.136. The assumptions may be based on specific financial products as long as the retirement estimate does not advertise or promote those products, other than to the extent necessary to provide the estimate: see also RG 276.86–RG 276.93. Table 2: Default assumptions about r