Insurance claims data shows super funds must step up to protect members

Key points

New analysis on insurance within superannuation identifies which funds are doing worse than others. The large insurer, AIA, which provides insurance for super funds like HESTA, Australian Retirement Trust and Colonial First State, as well as the insurer Resolution Life (incorporating AMP Life), are below par on many measures when it comes to claims and disputes.

• Overall, resolution of one in every five claims for total and permanent disability insurance and income protection insurance exceeds the timeframes under the Life Insurance Code of Practice, to which all insurers have committed. 
• Complaints to the Australian Financial Complaints Authority (AFCA) about delays in claims handling skyrocketed 136% in 2022-23 compared to the previous year. 
• Analysis of claim denials suggests that members are not well informed about coverage, and increasing numbers of withdrawn claims is cause for concern.
• Insurance outcomes are opaque, with super funds typically not reporting metrics about insurance publicly in annual member outcomes assessments (MOAs), and regulators holding significant data they are not publishing.
• Super Consumers is calling for change:
  • the Government should mandate customer service standards for funds,
  • the Australian Securities and Investments Commission (ASIC) should publish data about internal disputes promptly and continue enforcing internal disputes timeframes,
  • the Australian Prudential Regulation Authority (APRA) and ASIC should promptly publish detailed data on how individual super funds and insurers are performing,
  • the Government should establish an independent review of insurance in super, to establish whether the status quo is delivering a net public benefit and how insurance in super could be improved.

Many Australians hold life insurance that is bundled with super, usually by default. It is an industry that costs Australians over $6 billion per year,¹ however it is very complex. Many people never engage with the insurance in their super at all.² Even ASIC—the consumer protection regulator for insurers and super funds—has found it ‘difficult’ and ‘confusing’ to understand disclosures about default insurance in super.³

People are largely ‘captured’ by their super fund when it comes to insurance—the fund, not the member, chooses the default insurance. Taking insurance into account when comparing superannuation products is a highly complex task involving multiple factors. 

It is only when people make an insurance claim that they find out the value of what they’ve been paying for. And it’s usually at a time when they’re facing serious illness, disability or the death of a loved one. 

It is critical that super funds and insurers are held accountable for the quality of their products and customer service. 

So how do the insurers behind the super funds stack up when it comes time to make a claim?

What we looked at

To find out how super fund members are faring when they claim on their insurance, Super Consumers analysed: 

• insurance claims data published by APRA for the last five financial years, covering the period 1 July 2018 to 30 June 2023, and
• the latest report of the Financial Ombuds, the Australian Financial Complaints Authority (AFCA) 2022-23 Annual Review.⁴

Across the three group insurance products in super, we found areas of poor performance in claims timeframes and disputes, including: 

• income protection insurance (IP), also known as salary continuance or disability income insurance, 
• total and permanent disability insurance (TPD), and 
• death insurance, also known as life insurance.

We found evidence of:

• slow claims times, which fall short of the industry’s commitment to claims times under its own Code, and
• high rates of disputes, plus a lack of transparency about what disputes are about, and how they are resolved.

The data tells us that some insurers have been ‘outliers’ over the last few years.

Resolution Life and AIA in particular have been under-delivering for fund members. AIA is the second-largest provider of insurance in super, servicing some of the biggest funds including HESTA, Australian Retirement Trust and Colonial First State. 

These findings are a clear sign that super funds are failing to improve claims handling processes with their insurers—and they must do better.

How to improve insurance in super claims outcomes

Boost super funds’ commitment to better outcomes

Super funds must make genuine inroads to improve the insurance they provide to members. 

We expect funds to identify and work with insurers to improve areas where their members are having bad experiences and outcomes. This starts with identifying where they are falling short of their peers, and implementing process changes to target those failings, for example, in dispute timeframes.

If super funds do not step up, there will be a persistent disconnect between people’s expectations and the reality they face at claim time.

We also expect the regulators to improve funds’ transparency by publishing data about insurance claims outcomes and disputes, and to hold funds to account for poor claims handling and outcomes.

Publish fit-for-purpose data via the regulators

APRA and ASIC should release more detailed super data, including insurance outcomes and dispute data at a granular level, to enable regulators and consumer advocates to understand where people are facing the biggest problems in the claims process. This would include claims data at the fund product level, and more detail on the nature and outcomes of disputes. This will help to focus the efforts of regulators and consumer advocates, with the goal of improving claims experiences for all Australians.

Mandate customer service standards

Super funds are increasingly under the spotlight due to poor management of their core services to members, such as insurance claims, payment of death benefits and dispute handling.⁵ The super industry abandoned its voluntary code before it even commenced (with retail funds replacing it with Standards on claims handling and occupational exclusions),⁶ and has not worked collaboratively to set high-quality standards of service for members. The Government should therefore step in and regulate customer service standards for super funds, which include insurance in super claims and disputes, via a mandatory code of conduct or legislated standards.

Independent review of insurance in super

Given the systemic problems that have emerged, Super Consumers is calling for an independent review of insurance in super by the Productivity Commission. 

A review would assess whether insurance in super is efficient and equitable, and whether insurance definitions and claims handling practices are fit for purpose. A review would be an opportunity to consider whether the insurance in super system is delivering a net positive impact for Australians, and whether regulatory change is needed. 

What we found

Insurers are slow to resolve claims 

Under its own Life Insurance Code of Practice, the life insurance industry has committed to the following timeframes for finalising insurance in super claims:

• two months for an ‘income-related benefit’ (IP claim), and
• six months for a ‘lump sum benefit’ (death or TPD claim).⁷

The lengthy timeframe for TPD claims is cause for concern in itself. It partly reflects the difficulty of proving a permanent disability to an insurer.

These timeframes apply unless there are circumstances the insurer deems ‘beyond our control’. Concerningly, these circumstances can include delays by the super fund in providing information or responding to requests, or even requests for delays/extensions to the claims process by the fund.⁸ In short, an insurer’s commitment to deciding a person’s claim promptly is subject to a disclaimer based on the actions—or inaction—of the fund. The code provisions appear to work in favour of the insurer rather than the consumer.

Over the three years to June 2023, the average lump sum benefit claim was finalised within these timeframes (1 month for death insurance and 5.08 months for TPD insurance). However, the average IP claim took 2.2 months, exceeding the code commitment. 

Averages, however, do not tell us the full story about claim delays. The APRA data also shows that it has taken much longer to finalise a significant number of more recent claims. For example, in 2022-23:

• 20.4% of all IP claims in super exceed the Code’s two-month commitment, and
• 22.7% of all TPD claims in super exceed the Code’s 6-month commitment.

The impact of claim delays on individuals can be severe.

In September 2022, Super Consumers Australia detailed the story of Carol. Carol’s IP claim was delayed by an insurer that wanted information that was irrelevant to her claim. Her claim was finally settled after her lawyer and Super Consumers Australia made inquiries on her behalf, over six months after her claim was lodged. This gruelling process caused untold psychological harm to Carol.

Carol’s experience happened despite the insurance industry’s commitment to resolve her type of claim within two months. And Carol is not alone. Lawyers who represent people with these types of claims have described instances of protracted claims and overly bureaucratic processes as tactics designed to frustrate people making a claim.⁹ In some cases, delays exacerbated people’s mental health conditions and led to people withdrawing their claims.

Despite the devastation that lengthy claims processes can cause in people’s lives, self-regulation is the only current standard for claims timeframes. And this is only a commitment from insurers, which can be undone by delays or decisions by funds. This status quo means there is a lack of genuine customer service standards for insurance in super claims timeframes.

Recommendation 1: The Government should mandate customer service standards for super funds which include timeframes for insurance in super claims, via a mandatory code of conduct or legislated standards. 

Expectations often don’t meet reality at claim time 

The primary reason that insurers reject IP and TPD claims within super is that the claimant does not meet the terms of the insurance contract, making them ineligible to claim. 

This happened in 72.9% of denied IP claims and 83.8% of denied TPD claims over the last three years. In 2022-23, insurers denied 577 IP and 1,531 TPD claims. This means that a lot of people only discover they are not covered by their insurance when they actually need to make a claim. Some of these figures might be due to the superannuation funds themselves, as they decide if someone is eligible to make a claim (meaning they had insurance at the time of the event) and may reject some simpler claims without involving the insurer.

In contrast, for individually advised insurance (that is, where people purchase the insurance outside superannuation), 68.2% of declined IP claims, 69.1% of declined death claims and 74.4% of declined TPD claims were declined for the same reason. This may indicate that people who have policies which are individually underwritten and meant to be suitable for their needs, and who have an adviser to help them understand when they are eligible to claim, may get somewhat better insurance policies and claims outcomes, but not significantly so. 

Nevertheless, high rates of claim denial suggests significant room for improvement in how super funds and insurers design insurance in super, and how super funds communicate to members about insurance cover. 

Claims disputes are protracted, murky and on the rise

The Financial Ombuds, AFCA, reported a 136% increase in complaints about delays in insurance in super claims in 2022-23. 

Complaints in this category had by far the biggest increase compared to all other types of complaints against super funds to AFCA. But these complaints form just one element of the increase in claims disputes. They do not capture other categories of disputes which reach AFCA, some of which can be lengthy and complex, and cause difficulties for the people who are waiting for their claim to be paid.

Since October 2021, super funds have been legally required to resolve internal disputes about insurance claims within no more than 45 days and for disputes about death benefit distribution, 90 days.¹⁰ ASIC has current enforcement action underway against Telstra Super for failing to meet their internal dispute resolution requirements, including not responding to complaints within 45 days.

The Life Insurance Code also says that ‘Where possible, the trustee must give you a final written response to your Complaint within 45 calendar days of us or them receiving the Complaint’.¹²

However, over the past three years, the average dispute took longer, specifically:

• 3.1 months for TPD claims,
• 2.8 months for death insurance claims, and
• 1.8 months for IP claims. 

There were some remarkably poor performers on dispute timeframes. Resolution Life had significant delays resolving TPD claim disputes, taking an average 5.4 months in 2022-23, with 61.2% of these disputes taking over 45 days. Resolution Life also took about 2.2 months on average to resolve IP disputes during the same year, and failed to resolve 23.2% of IP disputes within 45 days (higher than  the average of 11.4% across all insurers). 

It is not just the number but also the nature and outcome of disputes that are a major concern. 

The APRA claims dispute data includes any disputes raised with the insurer, super fund, AFCA, a tribunal or court. So disputes could range from an internal complaint about a minor process delay, to court action following a denied claim. While AFCA’s data gives some insight into the nature of external disputes, data about internal disputes remains opaque.¹³

The APRA data is also murky when it comes to how disputes are resolved. Most group super insurance disputes were resolved with an outcome labelled as ‘other dispute outcome’, without clarifying whether the insurer’s original decision was maintained or reversed. Across all insurers in 2022-23, this was the case for:

• 75.9% of the 1,821 IP disputes, 
• 67.9% of the 1,593 TPD disputes, and
• 66.7% of the 93 death insurance disputes.

AIA in particular reported extremely high numbers of ‘other’ dispute outcomes: 94.6% of 37 death insurance disputes, 93% of 548 TPD disputes and 89.3% of 765 IP disputes.

Without any further detail or context, it is difficult to know whether people are getting favourable or unfavourable outcomes in the vast majority of claims disputes.  This could and should be resolved when ASIC begins reporting internal disputes data, as more detail could provide important insights into people’s claims outcomes. 

AFCA data does give some insight into the progress and outcomes of external disputes about insurance in super, although not specific to claims disputes. Of the total 1,896 AFCA complaints about insurance in super closed in 2022-23, 24.1% were resolved at the initial registration and referral stage. Others progressed to case management, where AFCA assists with a resolution through informal methods, and the majority of these were either resolved by agreement (488 complaints) or discontinued (324 complaints). 245 were resolved in favour of the super funds, versus 80 for the person making the complaints. 10.9% had to be resolved via a formal AFCA determination.

Recommendation 2: As part of its internal dispute resolution reporting functions, ASIC should commit to:

• publishing transparent, timely and detailed data on dispute outcomes, and
• continuing to take action against funds and/or insurers that are not meeting the legal requirements for internal disputes. 

Recommendation 3: Super funds should:

• investigate why dispute timeframes are consistently in breach of legal requirements and the industry Code, and
• work with life insurers to meet the mandatory dispute timeframes requirements.

Withdrawn claims are an ongoing concern

Concerningly, the average annual claim withdrawal rate for insurance in super has increased, particularly for IP. It has risen from 4.8% in the 2018-2019 year to 7.6% in 2022-23. Some insurers saw above average rates of claims withdrawals. In particular, over the last three years QInsure saw 11% of IP claims withdrawn, and AIA 10.3% of IP claims. 

However, these numbers do not paint a clear picture of how or why claims were withdrawn. In fact, many withdrawn claims were actually closed by the insurer due to  ‘claimant inactivity’. Over the last year, this was the case for 50% of all TPD claims, 49% of death insurance claims and 38% of IP claims. 

High levels of withdrawn or closed claims could indicate:

• people’s conditions have improved and/or they have returned to work,
• people have discovered during the claims process that they are ineligible to make the claim, even though they have been paying for the insurance—so a number of withdrawn claims would otherwise be declined, or
• onerous claims processes have pushed people to give up on their claims, even if they should have been successful.

Some insurers are delivering worse outcomes than others

The APRA data we analysed does not link insurance claims outcomes to specific super funds—it only identifies the insurer. This means that the data does not tell us which super funds have the worst insurance claims processes and outcomes. 

APRA did recently publish data on default insurance at the super fund product level, which includes product pricing and claims acceptances rates.¹⁴ While this did not form part of our analysis, it is a positive development and we understand that APRA has further data which it is yet to publish.

We do know that some insurers are clear underperformers at key points in the claims process.

It is also worth noting that there have been major changes across the life insurance sector in recent years. For example, since 2019, AIA acquired CommInsure life insurance, Resolution Life acquired AMP Life insurance, one major fund switched its insurance from AIA to TAL, and Zurich acquired OnePath. During major business changes like these, super funds and insurers must establish, test and resource their claims processes adequately. This is critical to make sure they are delivering good customer service and outcomes. 

Claims timeframes

Resolution Life (which had 1.4% of market share of TPD in super in 2022-23) had the longest wait times for TPD claims overall. They averaged an alarming 8.6 months in the past year, and 44.2% of claims took longer than the promised 6 months time frame in the Code. Over the past three years, claims took Resolution Life an average of 6.4 months, compared to an industry average of 5.1 months. 

In addition, Resolution Life had the equal slowest average timeframe for processing death insurance claims in 2022-23, at 1.2 months. For IP claims, it took an average of 3.2 months over the past year, which is longer than the industry average of 2 months.  Over the past three years, their IP claims took an average of 2.4 months, compared to an industry average of 2.2 months.

AIA, the second largest player in group super, had the equal worst average claim duration for death insurance in 2022-23 (1.2 months compared to an industry average of 1.1 months). It is also the second slowest for TPD (5.6 months versus an industry average of 4.9 months) and IP claims (2.9 months versus an average of 2 months).

Claim declines

Resolution Life delivered the worst claims outcomes over 2022-23 for all three types of insurance, with the insurer declining 13.9% of TPD claims, compared with an industry average of 7.7%. 

Claim withdrawals

QInsure has been a poor performer on withdrawn claims for all insurance products within super compared to the market average. The claim withdrawal rate for each QInsure product over the last three years has been: 

• TPD 8.1% (average 6.2%), 
• IP 11.0% (average 7.7%), and 
• Death 5.8% (average 2.4%).

Last year, QInsure had a very high withdrawal rate of 10.3% for IP claims, compared to an industry average of 7.6%. 

In 2022-23, TAL, the biggest market player in group insurance in super, had the highest rate of death insurance claims being withdrawn. at 3.6%. This was higher than the industry average of 2.8%. Meanwhile, AIA had the highest rate of withdrawn TPD claims, at 8.5%, and Resolution Life second highest at 8.4%, both exceeding the industry average of 6.7%.

Disputes 

Resolution Life has been a very poor performer on disputes in recent years. New disputes as a ratio to finalised claims over the last three years averaged 23.5% for TPD (compared to a market average of 8.5%) and 28.5% for IP (compared to a market average of 10.3%).

In 2022-23, AIA had the highest rate of disputes lodged in relation to death insurance, TPD and IP claims, with many of those disputes having unclear outcomes, as noted above. 

In relation to disputes timeframes in 2022-23:

• AIA took an average of 2.5 months for death insurance claims disputes, compared with an industry average of 2 months. Zurich was second worst, at 2.4 months.
• Resolution Life was by far the worst performer for TPD claims disputes at 5.4 months, with Zurich second at 3.4 months, compared with the industry average of 2.4 months. 61.2% of Resolution Life’s TPD disputes took longer than 45 days to resolve.
• Resolution Life and Zurich were equal slowest on IP claims disputes, taking on average 2.2 months compared with an industry average of 1.5 months. 

The vast majority of disputes raised with AIA were found to be valid. The dispute resolution process upheld the original decision in just 8.9% of IP complaints in 2022-23, compared to an industry average of 24.8%, and 5.8% of TPD complaints, compared to an industry average of 24.2%. This suggests obvious room for improvement in AIA’s original claims processes. 

Recommendation 4: Super funds should understand and take steps to improve the relative quality of service that the insurer is providing to their members, especially if their insurer is delivering poorer outcomes on claim timeframes, dispute rates and outcomes, withdrawn claims, and reasons for disputes and withdrawals.

What we’re calling for

Funds need to be more transparent about insurance outcomes

Super funds are required to document the appropriateness and cost effectiveness of insurance products within super, in an annual document called a Member Outcomes Assessment (MOA), and also to meet certain disclosure requirements.¹⁵

However, the relevant APRA prudential standard¹⁶ does not currently require MOAs to include specific information about insurance products within super, such as claims handling metrics.¹⁷ This is despite APRA’s companion prudential guidance (SPG 516 Business Performance Review) describing the benefits of publishing claims handling metrics.¹⁸ It is optional for super funds to include claims handling metrics, as APRA states: ‘An RSE licensee might also consider metrics that are based on how members engage with and claim on their insurance…’.

Unsurprisingly, when we reviewed the public summaries of MOAs of funds using AIA as their insurer, the insurance information did not include any claims handling metrics which would inform members about the quality of the funds’ insurance products. This echoes previous research by Super Consumers Australia which found most funds fail to provide quantitative metrics on their members’ claim experiences and engagement levels.

Funds appear to be just meeting the minimum legislative requirements for MOAs (at least in the public summaries), and are not reporting actual claims performance as suggested in APRA’s guidance. In an environment where members are only offered one insurance option with their fund, and with little transparency on the price and quality of the insurance, this reporting does little to assist regulators, consumer advocates and fund members to scrutinise funds’ performance in insurance. This dynamic also leaves little incentive for trustees to improve their performance. 

To address concerns with current practices, APRA should prescribe minimum and specific measures funds should include in MOAs, as well as the level of granularity at which  these measures should be reported. Data should be included in MOAs, and published in public summaries.

Recommendation 5: To ensure regulators and advocates have adequate information to assess the value and quality of insurance in a particular fund, APRA should compel super funds to include more information about insurance claims handling in their annual Members Outcomes Assessment and public summary. This means annual metrics over the last three years, including:

• claim denial rates, 
• claim withdrawals rates, 
• average claim duration, 
• open disputes rates, and 
• the claims ratios.

APRA should also require trustees to include in MOAs a credible peer comparison on these metrics. 

We need improved standards for claims and disputes

Unlike other sectors, the super industry does not have an industry code of conduct to regulate its approach to customer service and dealing with members.

The general insurance industry and the life insurance industry each have codes of practice.¹⁹ These codes regulate claims handling, including timeframes, as well as complaints and disputes. The codes also commit signatories to supporting customers experiencing vulnerability as well as First Nations customers.

It appears that the super industry has insufficient capacity or cohesion to develop a code of conduct. The high number of complaints relating to insurance in superannuation demonstrates that more must be done. 

The Government should step in and regulate insurance claims handling and related standards for super funds via a mandatory code of conduct or legislated standards. 

Recommendation 6: The Government should enact a mandatory code of conduct or legislate standards to improve consumer outcomes relating to life insurance within superannuation.

Regulators should release more detailed data

The significant limitations in the data currently available on claims handling mean it is difficult to identify the funds delivering poor claims outcomes to their members. The root causes of people’s poor experiences with making a claim are obscured without more granular data. 

As part of its Superannuation Data Transformation (SDT) project, APRA was meant to have released more insurance data by now, including data at the fund or product level. The first tranche of this data has been collected but not published in full. 

APRA first announced its SDT project in November 2019, with consultations occurring late 2020 after a COVID pause. After multiple delays, it was announced in May 2023 that the expanded product-level super data would be released in June. This occurred, however, no insurance related information was published with that data set. 

Given the importance of this data in understanding the outcomes people are getting, it is past time this data was made available. 

We encourage APRA to release the full SDT insurance data as soon as possible. We also encourage ASIC to publish data or other information from insurers that will help to pinpoint where the problems are in internal claims disputes.

This information is the missing piece of the puzzle if regulators and consumer advocates are going to work with super funds and insurers to improve people’s claims experience and outcomes.

Recommendation 7: Regulators should promptly publish more detailed, fit-for-purpose data on insurance in super claims. This includes APRA publishing product-level insurance claims handling statistics for all super funds, and ASIC publishing more detailed internal disputes data.

We need to review insurance within superannuation

This analysis of insurance claims and disputes suggests life insurance within superannuation is not working for consumers.

Reports published by ASIC support this conclusion.²⁰ ASIC has found:

• inadequate monitoring by super funds of member value from insurance,

• inadequate oversight by super funds of insurers’ claims handling practice and frictions in the claims process,
• little effort by super funds to help members understand their insurance or make appropriate decisions.

Given this evidence, there is a case to assess whether life insurance within superannuation is efficiently and effectively meeting policy objectives. A review could be established in an agency like the Productivity Commission, given its experience in assessing competition and efficiency in the superannuation industry. Such a review could consider whether insurance definitions and claims handling practices are fit for purpose, and how insurance in super could be improved.

Recommendation 8: The Productivity Commission should hold an independent review of insurance in super to establish whether insurance in super is efficient and equitable, and delivering a net positive impact for Australians, and whether regulatory change is needed.

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¹Group super annual premiums are $6.3b (Life insurance claims and disputes data, APRA, June, 2023).

²Insurance in super engagement can be measured by how many members alter their default insurance. The Super Consumers Pulse Survey (2022) found 28% of Australians were engaged with insurance in their super using this measurement.

³ASIC, Report 675 Default insurance in superannuation: Member value for money, December 2020, 17.

⁴ASIC, Report 675 Default insurance in superannuation: Member value for money, December 2020, 17.

⁵See for example ASIC’s action against Telstra Super alleging failures to respond to complaints within 45 days, and failing to inform complainants about the reasons for delays and about their rights to take their complaints to AFCA: ASIC, Media Release 23-295MR: ASIC takes civil penalty action against Telstra Super in Australian-first case, 6 November 2023.

⁶See Australian Institute of Superannuation Trustees, Association of Superannuation Funds Australia and Financial Services Council, Media release: Insurance in super code owners shift focus to vulnerable customers and claims, Thursday 1 July 2021, https://fsc.org.au/resources/2221-media-release-insurance-in-superannuation-voluntary-code and Financial Services Council Standard 27: Removal of occupational exclusions and occupation based restrictive disability definitions in default cover and Standard 28: Claims handling standard for super funds, https://www.fsc.org.au/resources/fsc-standards-and-guidance-notes/standards.

⁷Code 2.1, clauses 5.48 and 5.49 – equivalent to Code 1.0 clauses 8.16 and 8.17 which applied from 1 July 2017 to 30 June 2023.

⁸Code 2.1, clause 5.47 and Part 9 General definitions (equivalent to Code 1.0 clause 8.14).

⁹Group life insurers are pushing claimants to the brink, 22 October 2019, https://www.choice.com.au/money/financial-planning-and-investing/superannuation/articles/delay-in-group-life-insurance-claims.

¹⁰ASIC, Regulatory Guide 271 Internal dispute resolution, September 2021.

¹¹ASIC, Media release 23-295MR ASIC takes civil penalty action against Telstra Super in Australian-first case, 6 November 2023, https://asic.gov.au/about-asic/news-centre/find-a-media-release/2023-releases/23-295mr-asic-takes-civil-penalty-action-against-telstra-super-in-australian-first-case/.

¹²Code, clause 7.17 (clause 9.10 of the original Code included a 45 day commitment for life insurers, extended to 90 days for complaints involving insurance in super).

¹³This should change when ASIC publishes IDR data under the new IDR reporting obligations, which includes reporting of complaint issues and outcomes. See ASIC, Internal dispute resolution data reporting, https://asic.gov.au/regulatory-resources/financial-services/dispute-resolution/internal-dispute-resolution-data-reporting/

¹⁴APRA, Quarterly Superannuation Product Statistics – Default Insurance Design, 21 November 2023, https://www.apra.gov.au/quarterly-superannuation-product-statistics.

¹⁵SIS Act, sections 52(9)-(11).

¹⁶SPS 515 Strategic Planning and Member Outcomes, Sections 21-23. APRA is currently consulting on a new draft SPS 515 which is largely similar, with the additional requirement that funds show how a product is assessed against the population of products.

¹⁷APRA, SPS 515 Strategic Planning and Member Outcomes, paras 21-23.

¹⁸SPG 516, paras 36 and 37.

¹⁹See General Insurance Code of Practice, https://insurancecouncil.com.au/cop/ and Life Insurance Code of Practice, https://lifeccc.org.au/resources/life-insurance-code-of-practice/.

²⁰ASIC, REP675 Default Insurance in Superannuation: Member Value for Money https://asic.gov.au/regulatory-resources/find-a-document/reports/rep-675-default-insurance-in-superannuation-member-value-for-money/, December 2020, ; ASIC, REP760 Insurance in Superannuation: Industry Progress on Delivering Better Outcomes for Members, March 2023, https://asic.gov.au/regulatory-resources/find-a-document/reports/rep-760-insurance-in-superannuation-industry-progress-on-delivering-better-outcomes-for-members/.