What your SMSF auditor checks each year: a trustee's checklist from the ATO's own audit guidance

Every SMSF is audited each year by an approved SMSF auditor. The ATO publishes the checks it expects the auditor to make in its page "Compliance audit of an SMSF" (last updated 3 August 2026). That page is written for auditors, but it reads as a checklist for trustees. This article turns it into one, based on the page as read on 11 October 2026. It is general information and does not replace the auditor's own professional judgement or standards.

How the compliance audit works

The ATO says the auditor must be assured the trustees have met the super laws. They must consider materiality and risk, obtain sufficient and appropriate evidence, document their conclusions in working papers, and report their opinion in the approved independent auditor's report. If the auditor forms the opinion that a contravention of a matter in the auditor contravention report (ACR) may have occurred, may be occurring, or may occur in the future, they must notify the trustee in writing and report it to the ATO in the ACR. The auditor must follow the Standards on Assurance Engagements.

The Act: what is checked

Section 17A, the definition of an SMSF. The auditor looks at the trust deed, the number and names of members, the type of trustee, the relationships between members (for example, no member is an employee of another unless they are relatives), the names of trustees or directors, and details of legal personal representatives where relevant. See our article on what makes a fund an SMSF.

Section 35AE, accounting records. Records must be kept in Australia, written in English or easily translated, and kept for at least 5 years.

Section 35B, accounts and statements. The operating statement and statement of financial position must be signed by the required number of trustees or directors, and kept for at least 5 years. For 2021-22 and later years: a corporate trustee with one or two directors needs all directors; three or more needs at least half; individual trustees with two trustees need both; three or more needs at least half.

Section 35C(2), giving documents to the auditor. Trustees must respond to the auditor's written requests for documents within 14 days. The ATO tells auditors to keep a record of their requests and of reminders sent, and says failure to provide the documents in time is a reportable contravention.

Section 62, the sole purpose test. The auditor checks the trust deed and that the fund's activities were for providing retirement benefits, not a present-day benefit. They are told to make and document enquiries about activities with a risk of breaching the test, such as investments with minimal or no returns, a current or additional personal benefit to members, or an active business run by the SMSF. See the sole purpose test.

Sections 65, 66, 67 to 67B, 82 to 85, 109. Loans or financial assistance to members and relatives, acquisitions from related parties, borrowings, in-house assets and arm's-length investment dealings are each checked. Our articles cover loans to members, related-party acquisitions and the 5% in-house asset rule.

Sections 103, 104, 104A and 105, record keeping. Minutes, changes of trustees, trustee declarations and member reports; see SMSF record-keeping. The page also lists section 126K (disqualified persons).

The Regulations: what is checked

• Regulation 1.06(9A), pension payments. Evidence the fund has the pension rules and that payments are made at least annually and the minimum required payment has actually been paid, from the trust deed, bank statements, actuarial certificates and member records.
• Regulation 4.09, investment strategy. A strategy that considers the fund's whole circumstances, risk and return, diversity, liquidity, ability to pay liabilities and members' insurance needs, and that is regularly reviewed. Generally it is in writing, and evidence of review can be an updated strategy, notations, or the minutes. See the annual review duty.
• Regulation 4.09A, separation of assets. Bank statements and ownership documents showing assets held by the trustees on behalf of the fund, or alternative documents such as a valid declaration of trust, and no mixing of fund money with related parties' money. See separating SMSF and personal assets.
• Regulation 5.03, investment returns. Returns, including from reserves, must be allocated to members' accounts fairly and reasonably. See SMSF reserves.
• Regulation 5.08, minimum benefits. Member accounts show payments, any loans to members are genuine and documented, and members receiving payments met a condition of release.
• Regulation 6.17, restriction on payments. Payments went only to members eligible under the SISR and the trust deed, and rollovers to and from the SMSF followed the SuperStream rules from 1 October 2021, since a failure to comply is a contravention of regulation 6.17. See illegal early access.
• Regulation 7.04, acceptance of contributions. The trust deed, members' ages and employment status, the type, source, timing and amount of contributions, and that the member's TFN was quoted within 30 days of receiving the contribution if not already provided. If a contribution was accepted contrary to the rule, the auditor checks whether it was returned to the payer.
• Regulation 8.02B, market value. All assets valued at market value in the accounts each year, with objective, supportable evidence. See SMSF asset valuation.
• Regulations 13.12 to 13.14, assignments and charges. Written confirmation that trustees have not sanctioned an assignment of or charge over a member's super interest, and no charge over fund assets, supported by trustee representations, annual property title searches and searches of the Personal Property Securities Register.
• Regulation 13.18AA, collectables and personal use assets. See collectables and personal use assets.

A pre-audit checklist for trustees

1. Respond to the auditor's document requests within 14 days.
2. Make sure the operating statement and statement of financial position are signed by the required trustees.
3. Pull together the trust deed, member and trustee details, bank statements, asset ownership documents and valuations.
4. Check that minutes cover investment decisions and the investment strategy review, including insurance.
5. Confirm pension payments reached each member's minimum for the year, with bank evidence.
6. Check any contribution accepted during the year was permitted for that member's age and work status.
7. Keep property title searches and evidence that no charge exists over fund assets.

Worked example

Illustrative only, not personal advice.

Maria, 71, and her husband Joe, 73, are the two trustees of their SMSF. In September the auditor emails requesting the bank statements, the investment strategy review, and evidence of Joe's pension payments. Maria sends everything within a week. The auditor notes that the minimum pension for Joe for the year was paid in full from the fund's bank account, that the strategy was reviewed in the June minutes, and that the accounts were signed by both of them. One item is queried: the broker statement shows shares registered in Joe's personal name. Maria arranges for them to be re-registered as "trustees for" the fund, and gives the auditor the confirmation. Because the trustees responded promptly and fixed the issue, there is a clear record that the matter was addressed.

Sources

• ATO — Compliance audit of an SMSF
• ATO — Ownership and separation of fund assets