SMSF Investment Strategy - Define
A well-structured investment strategy is one of the most important foundations of a compliant and successful Self-Managed Super Fund (SMSF). Under the Superannuation Industry (Supervision) Act 1993 (SISA) and Superannuation Industry (Supervision) Regulations (SISR), SMSF trustees are required to formulate, implement and regularly review an investment strategy that is tailored to the circumstances of the fund and its members.
The purpose of an SMSF investment strategy is not simply to satisfy a compliance requirement. It is intended to help trustees make informed and disciplined investment decisions that align with the retirement objectives of fund members while balancing risk, return, liquidity and diversification. The Australian Taxation Office (ATO) expects trustees to actively consider these matters rather than relying on generic templates or broad asset allocation ranges.
A proper investment strategy should evolve with changing member circumstances, market conditions and retirement goals. Trustees must also ensure all investments comply with the sole purpose test, arm’s length requirements and other legislative obligations under the SIS Act.
1. Define the SMSF Investment Strategy
The first step in managing an SMSF investment strategy is defining the framework and objectives of the fund. This requires trustees to carefully consider the needs, goals and financial position of all members.
An SMSF investment strategy should clearly outline the purpose of the fund’s investments and how those investments are expected to assist members in achieving retirement outcomes. The strategy should not be generic or copied from standard templates. Instead, it should reflect the specific circumstances of the SMSF, including member ages, risk tolerance, retirement timeframes, contribution patterns and expected pension requirements.
Trustees are required under Regulation 4.09 of the SISR to consider several key factors when formulating an investment strategy. These include:
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The risk involved in making, holding and realising investments
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The likely return from investments, having regard to the fund’s objectives and cash flow requirements
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Diversification of investments
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Liquidity and the ability of the fund to meet liabilities
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The ability of the fund to discharge existing and prospective liabilities
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Whether insurance cover should be held for one or more members of the fund
A properly defined investment strategy should therefore establish:
Investment Objectives
Trustees should identify the primary objectives of the fund. These objectives may include:
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Long-term capital growth
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Stable income generation
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Asset protection
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Funding retirement pensions
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Wealth accumulation for younger members
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Preservation of capital for members approaching retirement
The objectives should be realistic and measurable. For example, the strategy may aim to achieve returns above inflation over a long-term investment horizon while maintaining an acceptable level of risk.
Risk Profile
Risk management is a critical part of defining an SMSF investment strategy. Trustees must assess the level of risk members are willing and able to accept. Younger members with longer investment horizons may tolerate higher exposure to growth assets such as shares and property, while older members nearing retirement may prefer lower-risk investments that preserve capital and provide stable income.
The investment strategy should document how risks will be managed, including market volatility, concentration risk, liquidity risk and borrowing risk. The ATO has specifically warned trustees about overly broad investment ranges such as “0–100% in all asset classes,” as these do not demonstrate genuine consideration of investment risks.
Diversification
Diversification is another major consideration. While SMSFs are not prohibited from investing heavily in one asset or asset class, trustees must demonstrate that they have considered the risks associated with limited diversification.
For example, many SMSFs invest heavily in direct property or business real property. Where a fund holds a significant concentration in one asset, the investment strategy should explain why this approach is appropriate and how associated risks will be managed.
This is particularly important where the SMSF has entered into a Limited Recourse Borrowing Arrangement (LRBA), as leverage increases financial risk and may affect liquidity and cash flow.
Liquidity and Cash Flow
The strategy must also consider whether the fund has sufficient liquidity to meet ongoing expenses and liabilities. Trustees need to ensure the fund can pay:
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Tax liabilities
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Audit and accounting fees
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Insurance premiums
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Pension payments
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Loan repayments, where applicable
An SMSF with substantial illiquid assets, such as property, should carefully assess how it will meet these obligations without placing the fund under financial stress.
Insurance Considerations
Trustees are also required to consider whether insurance cover should be held for members. This may include:
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Life insurance
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Total and permanent disability (TPD) insurance
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Income protection insurance
The investment strategy should record that trustees considered insurance needs, even if they decide not to hold insurance through the SMSF.
Sole Purpose Test
All investment decisions must comply with the sole purpose test under section 62 of the SIS Act. The sole purpose of the fund must be to provide retirement or death benefits to members and their beneficiaries.
The purpose behind an investment is more important than the nature of the asset itself. An investment that provides present-day benefits to members or relatives may breach the sole purpose test even if the investment appears commercially acceptable.
The “Swiss Chalet” case highlighted how investments used primarily for personal enjoyment breached the sole purpose test. Similarly, the Merchant case demonstrated that even market-value transactions may fail the test if their predominant purpose is to benefit related parties or achieve tax outcomes unrelated to retirement objectives.
Trustees should therefore ensure every investment decision can be justified as supporting retirement outcomes for members.