Retirement incomes: from strategy to solution

Since the commencement of the retirement income covenant on 1 July 2022, the regulatory posture has intensified, from initial regulatory flexibility towards increasingly demanding expectations. The question now is not whether trustees have a retirement income strategy — it is whether that strategy delivers meaningful improvements in retirement outcomes for members.

Our independent review of the published summaries of retirement income strategies of APRA-regulated registrable superannuation entities has revealed genuine progress across the sector from the pre-covenant baseline, albeit with material variation in the depth and consistency of approach between funds.

For many funds, there remains a gap between current practice and regulatory expectation, which is most acute in four areas:

• the development of meaningful member cohorts that reflect fund composition; 

• access to lifetime income products; 

• the construction of trustee-designed retirement income solutions calibrated to each cohort; and 

• robust metrics for evaluating member outcomes. 

In our report, we benchmark current practice against Treasury's Best Practice Principles for Superannuation Retirement Income Solutions (published in February 2026) and identify areas of heightened regulatory scrutiny as transparency obligations arise under the Retirement Reporting Framework from 2027.

We assess the sector's readiness for the enhanced transparency brought by the new reporting requirements and offer practical recommendations that trustees and accountable persons can implement to align fund strategy with legal obligations. In delivering quality retirement outcomes for members, funds that move early towards best practice will be well positioned in an increasingly competitive market.

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