The regulator invited industry feedback on stamp duty and private debt disclosure reforms following its targeted review of investment reporting.
The Australian Securities and Investments Commission (ASIC) has invited the superannuation and investment management sectors to provide feedback on proposed changes to stamp duty reporting and portfolio holdings disclosure, following its targeted review of investment disclosure settings announced in August 2025.
The regulator has proposed that stamp duty be disclosed as an average amount calculated over seven years, rather than an annual sum, within fees and costs summaries.
Implementing this change would require amendments to ASIC Corporations (Disclosure of Fees and Costs) Instrument 2019/1070.
ASIC has also proposed to align portfolio holdings disclosure requirements for internally managed private debt with the rules applied to externally managed private debt, enhancing consistency across the sector.
A working group made up of superannuation funds, investment managers, consumer advocates, government representatives and regulators met twice (in September and October 2025) to assess whether current disclosure settings were distorting investment decisions.
ASIC said broader consultation is now needed to test the proposals.
ASIC Commissioner Simone Constant said the proposals responded to feedback from the Treasurer’s Investor Roundtable.
“The proposals are about promoting regulatory balance and addressing problems without compromising on essential disclosure for consumers,” Constant said. “The proposed approach promotes transparency and disclosure outcomes that can inform good consumer investment allocation decisions. We thank the working group members for their time on this.”
The Financial Services Council (FSC) has welcomed the consultation, calling it a constructive step in refining fee and cost disclosure rules.
FSC chief executive Blake Briggs said the council “appreciates the regulator’s consultative approach” to these proposals.
“We support ASIC’s prioritisation of maintaining the transparency of the superannuation system for consumers,” Briggs said. “RG 97 plays a central role in maintaining confidence in the superannuation and managed funds sectors by promoting clear and reliable disclosure for investors.”
“The FSC acknowledges that stamp duty transaction costs make the reported costs for property investments fluctuate from year to year given it is a large, one-off expense, however stamp duty has a genuine impact on consumers’ superannuation balances and should be transparently reported so that consumers can compare investment options.”
Briggs added that the FSC has recommended refinements to “reduce the disproportionate impact of stamp duty disclosures while maintaining transparency”, and supports the regulator’s decision to continue consultation on this option.
“Smoothing stamp duty over a longer time horizon would better reflect the long-term underlying cost profile of assets, while recognising the inherent variability in when stamp duty is incurred.”
Briggs said the FSC will continue to work with ASIC as it consults on the proposed changes to RG 97 and prepares for the broader review scheduled for the 2026–27 financial year.
Additionally, the Australian Investment Council’s (AIC) chief executive, Navleen Prasad, said the board review has “been a long time coming”.
“…and if we get it right, [this] will set up ustralia for more productive investment and, ultimately, better outcomes form superannuation members.
“We have been highlighting the issues with RG 97 for almost two years, particularly the implications for startups, the innovation ecosystem, and growth companies.”
“The hard work starts now, and we fully appreciate the complexities of this issue, and the challenges ASIC faces in balancing transparency and usability with ensuring superannuation members receive the best possible returns for their retirement,” Prasad added.
According to AIC research, a young person on the average salary could be “more than $20,000 better off at retirement” by having access to investments in start-ups and growth companies.
“We look forward to being able to address the barriers that RG 97 presents to this important member outcome,” Prasad further stated. “It is critical that all key stakeholders are consulted on this issue, and we take the time to get it right for the long term, particularly to understand how these regulatory barriers have contributed to under-allocation to private equity and venture capital.”
Some stakeholders had previously suggested removing stamp duty entirely from transaction cost calculations and ASIC acknowledged the concerns but noted that a range of other fees and costs have also been raised for reconsideration.
As a result, it has committed to conducting a comprehensive review of RG 97 in 2026–27 to ensure the guidance remains robust and relevant.
Under current rules, superannuation funds and investment managers must report all transactional and operational costs — including stamp duty — when disclosing fees and costs to consumers under Instrument 2019/1070 and RG 97.
ASIC is assessing whether these requirements influence investment choices or conflict with the objectives of the superannuation system.
Superannuation trustees must also publish information about their investment options on their websites.
For private debt assets, trustees must disclose the value of each individual asset, even if only a single transaction exists, which may risk confidentiality.



