Superannuation AI Governance

Your AI Makes Investment Decisions with Members' Retirement Savings

APRA expects super funds to have governance over AI used in investment decisions, member services, and retirement projections. SPS 530 requires you to demonstrate appropriate oversight of automated systems handling fiduciary duties.

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Superannuation AI Portfolio Governance Dashboard

Where Super Funds Use AI

Different use cases carry different levels of regulatory scrutiny. Investment and member advice decisions get the most attention.

Investment Decisions

Portfolio allocation, asset selection, rebalancing algorithms. These are fiduciary decisions. APRA expects clear accountability.

High regulatory scrutiny

Retirement Projections

Calculators that estimate retirement income. Members make life decisions based on these numbers. ASIC expects projections to be reasonable.

High regulatory scrutiny

Member Guidance

Chatbots, contribution recommendations, insurance suggestions. Walking the line between general info and financial advice.

Medium scrutiny

Administration

Claims processing, contribution allocation, document handling. Important for efficiency but lower regulatory profile.

Lower scrutiny

What Regulators Expect

APRA-regulated super funds face prudential requirements around AI in investment and member services.

APRA

Prudential Standards

SPS 530, CPS 230, CPS 234

  • SPS 530: Investment governance requires oversight of AI-driven investment decisions and processes
  • CPS 230: AI systems as operational risks requiring identification, assessment, and management
  • Third-party AI: Investment managers using AI need to be in your material service provider register
  • Trustee duties: AI doesn't change fiduciary obligations. The board is still accountable.
ASIC

Conduct Requirements

Member protection, advice boundaries

  • Advice boundaries: Where does "general information" end and "personal advice" begin?
  • Projection standards: Retirement calculators must use reasonable assumptions
  • Member best interests: AI recommendations must serve members, not the fund
  • Design & distribution: AI-driven product suggestions must be appropriate

YourSuper comparison tool obligations

MySuper product performance is publicly compared through the YourSuper comparison tool. AI used in investment decisions for these products needs governance that can withstand scrutiny when performance questions arise.

Super-Specific Concerns

Issues that come up repeatedly when we work with superannuation funds.

Investment Manager AI

Your external managers use AI for trading and portfolio construction. Who owns the governance? How do you get visibility into their AI risk?

CPS 230 expects you to oversee material service providers, including their AI.

Member Chatbots

That helpful chatbot answering member questions at 2am. Is it giving general information or straying into personal advice?

ASIC has clear boundaries around advice. AI doesn't know where those boundaries are.

Retirement Modelling

Members use your projections to decide when to retire, how much to contribute, and whether to take insurance. Are your AI assumptions defensible?

When projections don't match reality, members ask questions. Regulators listen.

Investment AI Needs Fiduciary-Grade Governance

Get a clear view of your AI risk exposure and what APRA expects for super funds. We'll map your AI systems across investment, member services, and administration.

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