As a leading professional services firm, KPMG Australia (KPMG) is committed to meeting the requirements of all our stakeholders – not only the organisations we audit and advise, but also employees, governments, regulators and the wider community.

KPMG is pleased to provide a response to the Securing Australian’s Superannuation Consultation paper, helping deliver a more dignified retirement for Australian workers.

KPMG welcomes Treasury’s Consultation Securing Australians’ Superannuation and the opportunity to provide input on implementing payday superannuation and a redesigned compliance framework to ensure employers pay their super obligations as close as possible to payday It is very important that employees receive timely Superannuation Guarantee (SG) contributions.

KPMG’s expertise in assisting our clients with payroll and superannuation compliance over a number of years has informed us in developing this response to the Consultation. Our response is also informed by KPMG as an employer of over 10,000 people.

KPMG has also advocated for adding SG contributions to the Commonwealth Carer Payment in our paper Towards gender equity in retirement and on Paid Parental Leave as set out in A better system of paid parental leave. The paper sets out that since the Commonwealth pays Paid Parental Leave to eligible workers – and compulsory super contributions rightly form part of remuneration – then it follows logically that the Commonwealth should make Superannuation Guarantee contributions under its PPL scheme.

In relation to increasing the payment frequency of the SG, we recommend the government consider a reasonable timeframe from the date salaries and wages are paid to the date the SG is due. This will enable and allow employers sufficient time to ensure that their reporting obligations are aligned with timely payment, as well as reasonable time to process and manage administrative delays in making SG payments.

As an administrative measure, changing the SG payment frequency and consolidating payment contributions may be beneficial if moved to a monthly schedule. KPMG recommends the government undertake some additional modelling and prepare a regulatory impact statement to ensure the cost of facilitating additional SG payments (where an employer operates multiple pay-runs) does not exceed the benefit.

KPMG also recommends the government consider additional oversight from the Australian Taxation Office (ATO) to payment intermediaries (e.g. clearing houses) to ensure they apply the SG payment timely and accordingly.

We support any initiatives to align the payment of superannuation with other existing payroll and employment tax measures for those workers who are paid via overseas employers, e.g. STP reporting concessions and payroll tax exemptions.

In responding to Treasury’s Consultation paper, KPMG has not sought to answer all the questions put forward. KPMG has provided commentary in line with the general themes that these questions have covered.

KPMG looks forward to continuing to contribute to strengthening Australia’s superannuation system and helping deliver a more dignified retirement for Australian workers.

Should you wish to discuss these issues or proposals further, please do not hesitate to reach out.

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