Short answer: how to manage super complaints
ASIC's Report 844 (November 2026) finds that many super trustees are not using complaints as an early warning of wider problems. The report points to one approach: record every complaint, analyse the full data regularly, flag possible systemic issues, fix and report them, and test the whole process.
Over half of the 45 trustees ASIC reviewed identified fewer than five systemic issues in two years. ASIC treats a low number as a possible red flag, not as good performance. It says it will take stronger action where trustees do not act.
What did ASIC find in Report 844?
ASIC reviewed all 45 trustees it regulates and looked in depth at 10 of them. Those 10 hold $1.6 trillion for 12.8 million members. The report focuses on how trustees find and fix systemic issues from complaints, as RG 271 requires.
| Area | What ASIC found |
| Systemic issues found | 24 of 45 trustees identified fewer than five in two years, and 14 identified none. Trustees found 700 from 419,832 complaints. AFCA found 37 from 11,571 complaints, almost twice the rate. |
| Analysis | 11 of 45 trustees did not analyse complaints data regularly, which is an enforceable requirement. |
| Systems and training | 27% had no systemic issue field in any complaint system. 16% gave staff no formal training on spotting systemic issues. |
| Definitions | One third of trustees limited what counts as a systemic issue. |
| Root causes | Several trustees attributed over 60% of recorded root causes to members. |
| Governance | 9 of the 10 reviewed trustees had no measures for finding systemic issues. Only 5 had an audit covering that part of RG 271. |
| Major changes | Only 1 of the 9 trustees that made major changes reviewed members' experience properly afterwards. |
| Slow fixes | 35% of ongoing systemic issues had been open for more than 360 days. |
Members made 257,544 complaints in 2025–26, and 70% were made by phone. Members aged 55 to 74 made 52% of complaints but hold 24% of accounts.
How to manage super complaints
ASIC's 13 actions fall into seven steps.
1. Define complaints and systemic issues clearly
- Use the RG 271 definitions in your policy and apply them. A complaint is any expression of dissatisfaction where a response is expected. A systemic issue affects, or could affect, more than one member.
- Do not carve out "feedback" or information requests. One trustee had over 4,000 complaints logged as feedback.
- Record every complaint. A low complaint rate can mean complaints are not being recorded.
2. Capture useful data
- Add a field to flag possible systemic issues in every complaint system, and make it required.
- Link each complaint to any related incident.
- Flag members who are experiencing vulnerability and First Nations members.
- Record the issue in layers: business area, product or service, detail, and the nature of the dissatisfaction.
- Record a root cause, and train staff not to default to blaming the member.
3. Analyse the data regularly
- Look at individual complaints and at the full data set. Both are needed.
- Look beyond the top categories and short periods. Include complaints closed in the first five days.
- Compare your complaint rate with peers. The industry median was 97 complaints per 10,000 accounts in 2025–26.
- Check whether older members complain more in your fund.
4. Investigate, track and fix
- Escalate possible systemic issues promptly and keep a register with dates, status and owner.
- Do root cause analysis on every confirmed issue, even if it was not logged as an incident.
- Identify affected members, fix the cause, prevent it happening again and remediate fairly and quickly.
- Consider breach reporting under RG 78.
- Watch how long issues stay open.
5. Report to the board and test the process
- Set measures for finding systemic issues. One trustee tracked whether flagged complaints fell below 5% of the total.
- Report to the board on performance against those measures, the number of possible issues, and the status and outcome of each.
- Boards question what is driving complaint trends and what is being done.
- Audit compliance with RG 271 at least once a year, and check the accuracy of complaint recording and data.
6. Learn from major changes
- Monitor complaints and member impact during mergers, successor fund transfers and provider changes.
- Review the members' experience afterwards, not only how the project was delivered.
- Add complaint codes specific to the change.
7. If you use AI, watch for complaints about it
- ASIC sees AI as a way to find missed complaints and possible systemic issues, with human oversight.
- Test models before use and cross-check outputs against complaint files or call recordings.
- Build a fast way to escalate complaints about AI to the business owner.
Where to start
ASIC asks trustees to act now: review arrangements against the report, decide what to improve, and consider outside assurance.
- ☐ Compare your complaints process with the report's findings.
- ☐ Check your definitions of complaint and systemic issue against RG 271.
- ☐ Check that every complaint system has a systemic issue flag and enough detail to analyse.
- ☐ Set measures and board reporting for systemic issues.
- ☐ Arrange an RG 271 compliance audit, or outside assurance if you are not confident.
How can Curium help super trustees manage complaints?
Curium supports super funds with compliance and risk tools. These are the parts that match what ASIC asks for.
| What ASIC expects | What Curium does |
| Find complaints and possible systemic issues in member contact | Auto-Detect scans emails, documents and other records and flags complaints, risk incidents and vulnerable members, so fewer complaints go unrecorded. Similar issues are grouped automatically (auto-triage), so patterns show early. |
| Respond on time | Tracks timelines automatically, so deadlines such as complaint response times are not missed. |
| Spot breaches and reportable situations | Flags breaches and reportable situations as they arise, including those that start as complaints. |
| Investigate, report and learn | Guided investigation and resolution for each issue. Prepares reports, including for ASIC, for your team to review and submit. Systemic risk insights show where issues repeat. |
| Meet RG 271 and test it | Holds your complaints obligations, including RG 271, in one place with owners and evidence, so each audit starts from a current record. |
Frequently asked questions about super complaints handling
What did ASIC Report 844 find?
Many super trustees are not using complaints to find wider problems. Over half identified fewer than five systemic issues in two years, many did not analyse complaints data regularly, and governance and reporting were weak.
What is a systemic issue in super?
Under RG 271, it is a matter that affects, or could affect, more than one consumer. It can come from one complaint, such as a system error, or from a pattern across several complaints.
How long do trustees have to respond to a super complaint?
Within 45 calendar days. Trustees can close some complaints resolved in the first five business days without a written response. Objections to death benefit distribution decisions have a longer period.
Is a low number of systemic issues a good sign?
No. ASIC treats a low number as a possible red flag. It suggests that complaints are not being recorded or analysed well enough to find wider issues.
Do ASIC's findings apply outside super?
ASIC says many of the findings and actions may also be relevant to other financial firms that must comply with RG 271, such as insurers, underwriting agencies (MGAs) and brokers.
What happens if trustees do not act?
ASIC says it may use further supervisory engagement, compliance action, licence conditions and enforcement. In April 2026 the Federal Court found that Telstra Super breached its complaints handling obligations.
Can trustees use AI to handle complaints?
Yes, with guardrails. ASIC says AI can help find missed complaints and possible systemic issues, but trustees need human oversight, testing of outputs, and a way to escalate complaints about the AI itself.
Sources
- ASIC Report 844: Lessons to be learned: How trustees use insights from superannuation complaints (November 2026)
- ASIC Regulatory Guide 271: Internal dispute resolution
Author:
Tetiana George, CEO of Curium, Co-Chair of Insurtech Australia and member of ASIC Digital Finance Advisory Committee. LinkedIn Profile.