Do superannuation trustees need to comply with Design and Distribution Obligations (DDO)?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Yes
Yes. This obligation applies to superannuation trustees whatever their structure or size. The deciding fact: RSE licensee — APRA-regulated.
The obligation in brief
Comply with Design and Distribution Obligations (DDO). 8A of the Corporations Act requires issuers and distributors of retail financial products (including credit) to make a target market determination (TMD), distribute consistently with the TMD, report significant dealings inconsistent with it, and review TMDs periodically.
Trigger: Issuing or distributing in-scope products.
Why superannuation trustees get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 31 of those industries the answer for "Comply with Design and Distribution Obligations (DDO)" is no. Superannuation trustees is one of the 4 where the answer is different: yes.
The deciding fact for superannuation trustees: RSE licensee — APRA-regulated.
About the industry: Trustees of APRA-regulated super funds.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires issues products or an ACL or APRA regulation).
Answer by business structure and size
Each cell is the engine's outcome for a business in superannuation trustees with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Yes | Yes | Yes | Yes | Yes | Yes |
| Partnership | Yes | Yes | Yes | Yes | Yes | Yes |
| Trust | Yes | Yes | Yes | Yes | Yes | Yes |
| Pty Ltd company | Yes | Yes | Yes | Yes | Yes | Yes |
| Public company | Yes | Yes | Yes | Yes | Yes | Yes |
| Not-for-profit (unregistered) | Yes | Yes | Yes | Yes | Yes | Yes |
| Registered charity | Yes | Yes | Yes | Yes | Yes | Yes |
| Super fund | Yes | Yes | Yes | Yes | Yes | Yes |
| Foreign company | Yes | Yes | Yes | Yes | Yes | Yes |
What the obligation requires
- When due
- Continuous; TMDs reviewed periodically and on trigger events.
- Evidence to keep
- Documented TMD, distribution monitoring data, significant-dealings register, TMD review records.
- Maximum penalty
- Civil penalties to the maximum financial-services regime ($18.2M / 3× benefit / 10% turnover)
- Regulator
- ASIC
- Jurisdiction
- Commonwealth (national)
Other obligations where superannuation trustees differ from the norm
- Design and Distribution Obligations (DDO) — RG 274: Yes
- Annual YFYS performance test (MySuper + Choice): Yes
- Comply with APRA CPS 230 (Operational Risk Management): Yes
- Comply with APRA CPS 234 (Information Security): Yes
- Comply with Financial Accountability Regime (FAR) accountability obligations: Yes
- Comply with SIS Act trustee covenants: Yes
- All 15 answers for superannuation trustees
Other industries with a non-default answer
Questions
- Do superannuation trustees need to comply with Design and Distribution Obligations (DDO)?
- Yes. This obligation applies to superannuation trustees whatever their structure or size. The deciding fact: RSE licensee — APRA-regulated.
- Is the answer the same for every industry?
- No. For 31 of the 35 industries Rules Mate maps, the answer is no. Superannuation trustees is one of 4 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.