SMSF administration

SMSF investment strategy template (2026–27)

A plain-English guide to a compliant SMSF investment strategy in 2026–27 — the covenants in SIS s52B and reg 4.09, concentration and liquidity evidence, the insurance step, and a template.

By easySMSFPublished Reviewed 8 min read

Every SMSF in Australia must have a written investment strategy, and every audit checks it. Most trustees write one at setup, file it, and never look at it again — which is exactly how funds end up with an auditor contravention report. This guide covers what the law requires in 2026–27 and how to structure a strategy that passes audit first time.

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01The factors your strategy must cover

Regulation 4.09 factors and the evidence auditors look for
FactorWhat the strategy should show
RiskThe risks of making, holding and realising each asset class the fund uses, in the fund's own terms.
ReturnTarget return linked to member objectives, time horizon and expected cash flow.
DiversificationEither genuine spread across asset classes, or a documented justification for concentration.
LiquidityHow the fund meets pension payments, tax, ASIC and audit costs, and any LRBA repayments as they fall due.
Ability to discharge liabilitiesCash-flow analysis covering benefit payments and known assessments.
InsuranceA recorded decision for each member on whether the fund holds cover, and why.

SIS Regulations 1994, reg 4.09(2). The strategy must be specific to the fund; generic templates without member detail are routinely queried.

02The insurance factor most trustees forget

Since 2012 the strategy must explicitly consider insurance for each member. You do not have to hold cover — you have to consider it and document the decision either way. A single line recording that members hold personal cover outside super is enough. Silence is not.

03Concentrated portfolios — property

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If your SMSF holds a single asset representing most of the fund — direct property is the common case — the ATO expects the strategy to explain why that concentration is acceptable. Reference the investment horizon, rental yield, member contributions and other liquidity sources. A strategy that lists diversification as a goal while the fund holds 90% in one property is a red flag every auditor will raise.

04How often to review

The Act says 'regularly'. Accepted practice is at least annually, and whenever something material changes — a new member, a large rollover, a new asset class, a pension commencement, or a change in member circumstances. Document the review in trustee minutes rather than silently editing the strategy.

05A structure that passes audit

  1. 1Fund details, members, current balances and phases.
  2. 2Investment objectives and target return.
  3. 3Risk tolerance and time horizon for each member cohort.
  4. 4Asset allocation ranges (for example Australian equities 30–60%).
  5. 5Diversification analysis, or a fund-specific concentration justification.
  6. 6Liquidity and cash-flow analysis, including known liabilities for the coming year.
  7. 7Insurance consideration recorded for each member.
  8. 8Review schedule, date and trustee signatures.

easySMSF includes a current strategy template tailored to your members in every setup, and runs the annual review as part of fixed-fee administration.

Sources and legislation

  1. 01Superannuation Industry (Supervision) Act 1993 (Cth), section 52B
  2. 02Superannuation Industry (Supervision) Regulations 1994 (Cth), regulation 4.09
  3. 03Australian Taxation Office — Your SMSF investment strategy

Frequently asked questions

Reviewed by easySMSF

SMSF Specialist Team. easySMSF specialises in Australian self-managed super fund setup and administration. All articles are reviewed against current ATO guidance and the Superannuation Industry (Supervision) Act 1993 before publishing.

General information only. Not personal financial advice. easySMSF does not hold an AFSL.

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