SMSF investment strategy template: what section 52B actually requires in 2026

Every SMSF in Australia must have a written investment strategy, and every audit will check it. Most trustees write one once at setup, file it, and never look at it again — which is exactly how funds end up with auditor contravention reports. This guide covers what section 52B of the SIS Act actually requires in 2026 and how to structure a strategy that passes audit first time.

What the law actually says

Section 52B(2)(f) of the Superannuation Industry (Supervision) Act 1993 requires trustees to formulate, review regularly, and give effect to an investment strategy that has regard to the whole circumstances of the fund. The regulations then list six specific factors the strategy must address.

The six factors your strategy must cover

• Risk involved in making, holding and realising the fund's investments
• Likely return from the investments, having regard to objectives and expected cash flow
• Diversification of investments (or a documented reason for concentration)
• Liquidity — the fund's ability to discharge existing and prospective liabilities
• Ability to pay benefits as members retire and other costs as they fall due
• Whether trustees should hold a contract of insurance for one or more members

The insurance factor most trustees forget

Since 2012 the strategy must explicitly consider insurance for each member. You do not have to hold insurance — you have to consider it and document the decision either way. A one-line 'we considered insurance and decided not to hold cover because members hold personal cover outside super' is enough. Silence is not.

Concentrated portfolios — property and crypto

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

How often to review

The Act says 'regularly'. The accepted practice is at least annually, and every time 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; do not just edit the strategy silently.

A simple structure that passes audit

• Section 1 — fund details, members, current balances
• Section 2 — investment objectives and expected return
• Section 3 — risk tolerance and time horizon
• Section 4 — asset allocation ranges (e.g. Australian equities 30–60%)
• Section 5 — diversification analysis (or concentration justification)
• Section 6 — liquidity and cash-flow analysis
• Section 7 — insurance consideration for each member
• Section 8 — review schedule and trustee signatures

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

Sources: Superannuation Industry (Supervision) Act 1993, section 52B; Superannuation Industry (Supervision) Regulations 1994, regulation 4.09; Australian Taxation Office — Investment strategy (ato.gov.au).