From that date, transitional relief will continue subject to conduct, governance, and disclosure conditions. These include holding scheme assets on trust and separately from other property, having internal dispute resolution arrangements, and publishing key scheme information on the operator’s website, such as how contributions and income are used, member rights, significant risks, fees, and complaint processes. Operators must notify ASIC within 14 days of first relying on the new relief and, if they do not apply for a licence by Sept. 1, 2026, or have an application refused or withdrawn, they will be required to cease operating the scheme. For insurance professionals, the developments around the Shield and First Guardian collapse, CSLR design, and the regulation of employee entitlement schemes indicate an evolving framework linking AFCA, ASIC, and the CSLR, with implications for product structures, advice processes, professional indemnity arrangements, and dispute resolution strategies.
