SMSF Setup and Establishment Checklist

Setting up an SMSF for a client? Work through the deed, the SMSF trustee declaration, ABN, bank account, rollovers and investment strategy.

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SMSF setup starts with the trustee choice and signed deed, then registration, a separate bank account and rollover checks. For your accounting practice, the file must show who completed each step before the client’s retirement savings move.

SMSF Setup Order, Step by Step

Establish the fund before applying for its registrations, and complete the banking and SuperStream checks before requesting a rollover.

  1. Record the members’ decision and your engagement scope. Obtain their details, identity evidence and written trustee consents. Separate establishment work from advice about whether an SMSF suits them.
  2. Confirm the trustee choice with the members. For a corporate trustee, arrange director IDs and company registration with ASIC before completing the fund documents.
  3. Have the deed provider prepare the SMSF trust deed. The trustees execute it and hold an initial asset for the members under its terms.
  4. Record the establishment date and evidence of the initial asset. A signed deed without trust property does not complete establishment. The establishment date starts the registration clock.
  5. Collect each trustee declaration within 21 days of appointment. You can manage the checklist, but each trustee or director signs their own declaration.
  6. Apply through the Australian Business Register for the fund’s ABN and TFN, with the election for ATO regulation. Complete this within 60 days of establishment.
  7. Have the bank identify the trustees and activate an account for the fund. Record its BSB, account number and operating authorities.
  8. Obtain an electronic service address that supports rollovers, and match the fund’s details with ATO records. Trustees adopt a written investment strategy before investing.
  9. Have each member request their rollover from the releasing fund. Reconcile the payment and rollover information when they reach the SMSF.

The ATO’s SMSF setup steps explain the dependencies between establishment, registration and funding.

SMSF Establishment Costs and Who Pays

Ask for an itemised setup quote that separates the deed provider’s charge from your accounting fee. A corporate trustee adds ASIC company registration and company-document costs. Ongoing audit, accounting and company-review charges are separate from establishment.

State whether each quoted service fee includes GST. State what the quote covers, including registration assistance and rollover administration. A free or cheap setup offer can still involve ongoing charges or conditions.

Members commonly pay preliminary invoices personally because the fund account is not yet open. If the fund later pays or reimburses an expense, check the deed, invoice recipient and trustee authority. Record any member-paid amount and its contribution treatment before posting it to the accounts.

The ATO treats costs of establishing a super fund as capital expenses, so the fund cannot claim a general deduction for them. Payment from the fund account does not change that character. Distinguish these costs from later operating expenses under ATO expense guidance.

Recommending that a client establish an SMSF can be financial product advice. ASIC’s accountant licensing guidance distinguishes administrative establishment work from advice requiring AFS licence coverage. Keep this checklist to establishment tasks and refer suitability advice through the appropriate licensed adviser.

Corporate Trustee vs Individual Trustee for an SMSF

A corporate trustee SMSF has a company as trustee, usually established solely for that purpose. The members are normally its directors and make the fund’s decisions in that capacity.

An SMSF can have up to six members. In the usual multi-member fund, each member is a trustee or a director of the corporate trustee. Each trustee or director is also a member, subject to statutory exceptions. State and territory trust law can restrict the number of individual trustees.

Setup issueIndividual trusteesCorporate trustee
Establishment costNo separate trustee company to registerCompany registration and company documents add costs
Member changesTrustee changes require asset ownership records to changeThe company remains trustee when directors change
Sole-member fundRequires two individual trustees, with the second meeting the relationship or employment ruleThe member can be the sole director, or one of two qualifying directors
Asset titlesRecord the individual trustees’ capacity for the fundRecord the company’s capacity as trustee for the fund
Administrative penaltiesEach individual trustee can receive the full penaltyThe company receives the penalty and directors are jointly and severally liable
Ongoing recordsFund records and trustee-change documentsFund records plus ASIC and company records

Use Super Fund Lookup’s SMSF definitions for the sole-member conditions. The ATO’s penalty practice statement explains the difference in liability.

For a corporate trustee, collect the ASIC registration certificate, company constitution, director consents and director IDs. Keep a current company record showing its directors. The director ID guide covers the application task.

Decide how the fund will continue if a member leaves or dies. With individual trustees, a sole remaining member still needs a qualifying second trustee or a corporate trustee. With a corporate trustee, director changes require updates to authority records while the company remains the asset owner.

Make this choice before ordering the deed or opening accounts. Use the trustee comparison when you also need to distinguish the trustee of another client trust.

Checking the SMSF Trust Deed

The SMSF trust deed sets the fund’s rules and must be executed by all trustees under the relevant legal requirements. For a company trustee, check company execution requirements. Its terms must support lawful operation and the pensions and investments the members intend to use.

Check the following provisions with the deed provider:

  • Admission and departure of members, including eligibility and consent records.
  • Benefit payments, pension powers and the documents required before paying benefits.
  • Reserve powers and any limits on their use.
  • Death benefit nominations, including whether binding nominations are permitted and how members execute or renew them.
  • Amendment powers, who exercises them and how variations take effect.

An old deed can restrict an otherwise permitted transaction or fail to reflect a change in super law. Keep the signed original, every variation and the deed provider’s details. Record the execution date and organise reviews when legislation or the members’ needs change.

The ATO’s trust deed requirements call for a tailored deed that is regularly reviewed. A generic downloaded deed does not establish that these provisions suit the fund.

An SMSF deed and a borrowing holding-trust deed have different jobs. If a property borrowing is proposed, use the limited recourse borrowing arrangement guide before preparing its separate holding trust.

ATO SMSF Trustee Declaration

Each new individual trustee or director of a corporate trustee must sign the ATO’s Trustee declaration, NAT 71089, within 21 days of appointment. It confirms that the signer understands their duties and responsibilities.

The fund keeps the declaration and supplies it to the ATO if requested. It is not routinely lodged with the registration application. Written consent to appointment is a separate record.

File a signed declaration against each person’s appointment record. Track the appointment date, signing deadline and actual signature. Give the auditor access to every required declaration, including those for later appointments.

Use the ATO’s trustee declaration guidance to obtain the form. Retain the declarations throughout the fund’s operation and for at least 10 years after wind up under the ATO’s setup guidance.

SMSF Registration: ABN, TFN and Electing ATO Regulation

Apply for the SMSF’s ABN and TFN through the Australian Business Register within 60 days of establishment. Select an ATO-regulated SMSF and make the election for regulation in the same application. A company trustee’s ACN is separate from the fund’s ABN.

Prepare the executed deed, establishment date and member and trustee details before applying. Match legal names and identity information across the documents. Keep the application reference and copies of the resulting ABN and TFN notifications.

Check the fund on Super Fund Lookup. A newly registered fund initially appears as Registered, then changes to Complying when the ATO issues its Notice of compliance. The ATO’s registration follow-up guidance explains this sequence.

The Notice of compliance is the ATO document to retain with the registration records. The signed deed and initial asset records establish when the trust began. These documents have different purposes.

An ABN alone does not prove that the election for regulation is complete. If the fund is absent or its status prevents a rollover, check the application and any ATO request for information. Contact the ATO with the application reference and resolve the issue before moving retirement savings.

SMSF Bank Account, Electronic Service Address and Rollovers

Open a bank account for the SMSF and keep its money separate from the members’ personal accounts and employers’ accounts. Record the trustee’s capacity in the account title. The ATO bank account requirements require an account unique to the fund.

Choose the account on factual requirements. Compare fees, trustee access, payment approval settings and the account’s supported connection to your SMSF accounting software. Ask the bank and software provider about the specific account connection. An advertised connection for ordinary business accounts does not establish support for the SMSF product.

Named-Bank Opening Routes

Each bank has its own application and identification rules. For every route, finish with an accepted account for the fund, documented authorised access and independently verified banking details for ATO records and rollovers.

BankOpening route and checkpoint
ANZStart with the SMSF Cash Hub and arrange a branch visit. Bring trustee identification and a physical original deed or a copy certified within 90 days. ANZ does not accept digital deed copies. Confirm activation, account title and signing authority before requesting a rollover.
WestpacStart with Westpac’s Business One Account from its SMSF range. Confirm acceptance of the SMSF’s individual or corporate trustee. Obtain that product’s opening checklist and record its account title and trustee access. The former DIY Super Working Account is no longer available for sale. Westpac also documents an SMSF share-trading application with a cash account, which has separate requirements.
St.GeorgeStart from its Investment Cash Account route for SMSFs. Obtain St.George’s application and trustee-document requirements, then confirm who can approve payments. Use its own documents even though it shares ownership with Westpac.
Great Southern BankStart with the Business+ SMSF route. Prepare the fund ABN, registered status and digital deed with variations. Add members’ identity details and email addresses. Confirm that the bank accepts the precise trustee arrangement and account title. Payment approvals do not cover every transaction type. If the arrangement or approval requirements are unsuitable, use a bank with an accepted SMSF route.
CommBankStart with the Commonwealth Direct Investment Account (CDIA) route for SMSFs and its separate SMSF identification checklist. Reconcile the deed, trustee and fund names. Supply registration evidence, identification and account authorities. Confirm the cash account is active before using its details for rollovers or investment services.
MacquarieSelect SMSF in the CMA application and check that the fund’s status is Registered or Complying. Prepare trustee and beneficial-owner identity evidence. Supply a deed copy certified within two years or the permitted professional confirmation letter issued within 12 months. Resolve ABN, fund-name or status mismatches before resubmitting.

Use each bank’s own instructions: ANZ opening documents, St.George SMSF banking, Great Southern Bank’s SMSF route and Macquarie’s CMA documents.

For CommBank, use its SMSF identification checklist. Westpac’s SMSF account range includes Business One. Its investment account information identifies the discontinued account, so its old application instructions are unsuitable for a new fund.

Electronic Service Address and Rollover Checks

The SMSF needs an electronic service address (ESA) for SuperStream employer contributions and rollovers. Select a service that supports the transaction required. An email address is not an ESA. Use the ESA guide for providers, aliases and setup troubleshooting.

Before requesting money, match the ESA and bank details with ATO records. Check the fund’s status and that each member is recorded correctly. A releasing fund checks the SMSF and member details through the ATO’s verification service and checks identity and payment information.

Collect the member’s legal name, date of birth, address, TFN and releasing-fund member number. Record the receiving SMSF’s legal name, ABN, ESA and verified bank details. Resolve a name or bank mismatch before sending the request.

The ATO rollover initiation request for an SMSF requests a whole balance. Send it to the fund currently holding the member’s super, following its accepted request method. A partial rollover needs the releasing fund’s own partial-transfer route.

AustralianSuper’s Apply for a payment form permits a full or partial transfer to an SMSF. Send it to AustralianSuper when it is the releasing fund. Select the SMSF transfer option, complete receiving-fund details and provide the required electronic or certified-paper identity evidence. Its TFN-only identity option is not available for an SMSF transfer.

AustralianSuper also has forms for combining super into AustralianSuper. Those receive money into AustralianSuper and are different from a request to transfer money out to an SMSF. Use its payment form for the outbound request.

A full transfer can end the member’s existing insurance. Resolve insurance and any personal-contribution deduction notice before closing the old account. The ATO’s rollover guidance explains the electronic payment and data requirements.

Keep the request, confirmation, rollover statement and matching bank receipt together. Never direct a rollover or contribution to a personal account while waiting for the fund account.

SMSF Investment Strategy

Trustees must prepare, regularly review and follow a written investment strategy for the fund’s circumstances. Regulation 4.09 requires consideration of risk and likely return, diversification, liquidity, liabilities and member insurance.

The accountant can collect information and record the trustees’ decisions. Recommending investments is a separate advice task. Auditors check whether the strategy exists and whether the fund gives effect to it.

Risk and Likely Return

For your investment strategy template, record the fund’s objectives, time horizon, expected contributions and withdrawals. Explain the risks of making, holding and selling its proposed investments and the likely return sought.

Diversification and Asset Composition

Document the intended asset mix and exposure limits. Explain any concentration, including a fund holding one property or a large cryptocurrency position. Broad allocation ranges without reasons do not explain the members’ circumstances.

Liquidity and Expected Cash Needs

Record accessible cash and how investments can be sold. Allow for expenses, tax and benefit payments. Explain what happens if contributions stop or property rent is interrupted.

Existing and Future Liabilities

Describe how the fund will meet debts, expenses and benefits when due. Include pension payments where relevant and commitments under any permitted borrowing arrangement.

Insurance for Members

Record the trustees’ consideration of insurance for each member. Explain the cover held or the reasons for the decision. Consider the effect of any insurance lost when balances leave another fund.

Use regulation 4.09 for the legal factors. Add trustee approval, review dates and triggers to the document. Review after a member change, pension commencement or a material change in investments or cash needs.

Sample SMSF Investment Strategy Example

This invented two-member example illustrates the record, not an investment recommendation. Both members are in accumulation phase and expect no benefit payments during the next year. Figures are assumed account balances, not service prices.

Strategy factorIllustrative trustee record
Objectives and riskPreserve retirement savings while seeking long-term growth. Both members recognise that investment values can fall and record their capacity to tolerate those falls.
Asset compositionAn assumed $500,000 fund holds $50,000 cash and $450,000 across diversified investments. The trustees document the asset classes and concentration limits in the investment schedule.
LiquidityAccessible cash covers an assumed $8,000 of annual expenses. Trustees assess selling periods for investments and reassess cash needs if contributions stop.
Liabilities and benefitsThe fund has no borrowing or pensions. Trustees reassess liquidity before a benefit payment or new commitment.
InsuranceTrustees record each member’s insurance needs, existing cover and reasons for their decisions.
ReviewReview annually and after a member change, material investment change or unexpected cash requirement. Record approvals and resulting changes.

The sample must be replaced with the actual fund’s circumstances and trustee decisions. An SMSF property investment strategy must explain concentration, vacancy risk and cash available for expenses and benefits. A limited recourse borrowing arrangement also creates repayment commitments and separate legal requirements. Record those matters without treating the strategy as approval to purchase property.

SMSF Establishment Documents to Collect at Onboarding

Build one establishment file that connects the members, trustee, registrations and first transactions. Use the same member details in the form and each application, then check them against identity evidence.

RecordWhat your practice checks
Signed deed and variationsCorrect fund and trustee names, execution and initial asset evidence
Trustee appointments and declarationsEach required consent and signed NAT 71089, with appointment and signing dates
Corporate trustee documentsASIC certificate, constitution, current director record, consents and director IDs
Registration recordsABN and TFN notifications, regulation election and Notice of compliance
Bank recordsAccount title, verified banking details and signed operating authorities
RolloversMember requests, releasing-fund statements and corresponding receipts
Investment strategySigned strategy, insurance consideration and review schedule
Identity recordsRequired member and trustee checks, authority to act and controlled document access
Establishment minutesDeed adoption, member admission, banking authorities and investment strategy approval

Record auditor appointment arrangements in the minutes and appoint an approved SMSF auditor for each required annual audit. A minute cannot replace the auditor’s acceptance or independence requirements. The SMSF audit checklist covers the annual file.

A client form can collect members’ details once, attach trustee roles and request the establishment documents. Give each declaration a required status and a responsible staff member. Flag the missing document before marking that person’s appointment file complete.

Follow your identity and authority checks for each person and their authority. Keep sensitive identity information in controlled records rather than general email attachments.

Before closing the setup job, reconcile the deed names, company details, ATO records, bank title and first rollover. The file must show an established fund, completed registrations, accepted banking and signed trustee records.

SMSF Wind Up

Wind up an SMSF by dealing with members’ benefits, completing the final audit and annual return, and settling the remaining liabilities. Check the deed’s wind-up provisions and record the trustees’ decision first.

  1. Stop new contributions and tell employers where future contributions must go. Confirm each member’s receiving fund or lawful benefit-payment instructions.
  2. Sell or transfer assets under the applicable rules. Calculate tax, costs and liabilities. Keep enough cash to settle them.
  3. Roll over most member benefits before lodging the final annual return. Retain the money needed for outstanding obligations.
  4. Arrange the final audit and complete outstanding reporting. Lodge the final SMSF annual return with its wind-up details.
  5. Settle final tax or receive the refund, then complete the remaining rollover promptly. Keep the bank account open until all receipts and payments finish.
  6. Retain the ATO’s letter confirming cancellation of the fund ABN and closure of its records. Address the corporate trustee’s ASIC obligations separately.

Lodging the final annual return notifies the ATO of the wind up. The ATO completes ABN cancellation, so do not cancel it yourself. Its current wind-up guidance warns that the final rollover must be completed within 28 days of lodging the final return. That is a rollover deadline, distinct from trustee-change notification rules.

Keep accounting and tax records for at least five years. Trustee minutes, decisions and member records require at least 10 years of retention. Retain signed trustee declarations for at least 10 years after wind up. Check whether a longer period applies to a particular tax or legal matter before disposing of records.

Leave a closed-fund file with final accounts, audit, return, benefit and rollover evidence, closure confirmation and the person responsible for retaining the records.

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