ASIC RG 97 fees and costs disclosure for super and managed investments
How issuers of super and managed investment products must disclose fees and costs in PDSs and periodic statements under ASIC RG 97.
Who RG 97 applies to
RG 97 is the ASIC regulatory guide concerning the disclosure of fees and costs in product disclosure statements and periodic statements. It operates in conjunction with the ASIC Corporations (Disclosure of Fees and Costs) Instrument 2019/1070.
The guide applies to issuers of most superannuation products, registered managed investment schemes, and operators of notified foreign passport funds issued to retail clients.
ASIC has indicated a broader review of RG 97 is planned for the 2026-27 financial year.
The 2020 reforms — what changed in the PDS
The current RG 97 framework was published on 28 September 2020, introducing changes to fees and costs disclosure in Product Disclosure Statements (PDSs) for superannuation and managed investments. These reforms aimed to improve clarity and comparability for consumers.
A key change is the grouping of ongoing fees and costs into three categories: Administration, Investment and Transaction. PDSs now display a single ‘Cost of Product’ figure to summarise these costs.
The format of fee tables has also been revised. A ‘Fees and costs summary’ table now replaces older tables, separating ongoing fees from fees based on member activity. These changes were accompanied by a simplification of periodic statement presentation.
Transaction costs and OTC derivative cost
Transaction costs are included in fees and costs disclosures. These costs cover expenses such as brokerage and buy-sell spreads, and other costs incurred when acquiring or disposing of underlying assets. Disclosures must reflect net transaction costs, which are calculated by subtracting any amounts recovered through buy-sell spreads from the gross transaction costs.
OTC derivative costs are also part of fees and costs disclosures. These costs are calculated using either a notional or look-through basis, depending on the specific derivative instrument involved.
Property operating costs are excluded from ongoing fees and costs disclosures. However, these costs are disclosed separately for funds with a significant allocation to property assets.
Stamp duty review and what to watch in 2026-27
ASIC has proposed a change to how stamp duty is disclosed in fees and costs summaries. Currently, it is disclosed annually. The proposal is to disclose stamp duty as an average calculated over a period of seven years. Implementing this change would necessitate amendments to ASIC Corporations (Disclosure of Fees and Costs) Instrument 2019/1070.
A broader review of RG 97 is scheduled for the 2026-27 financial year. This review will encompass a range of aspects related to fees and costs disclosure.
ASIC has indicated that the transaction cost methodology will be considered as part of this 2026-27 review. This signals a potential opportunity to revisit and possibly adjust the current approach to calculating and disclosing transaction costs.
Frequently asked
What is the difference between the Fees and costs summary and the Cost of Product?
The summary itemises fee types (Administration, Investment, Transaction, member-activity). The Cost of Product is a single aggregate dollar figure showing what a member with a $50,000 balance would pay across a year for ongoing fees and costs.
Does RG 97 apply to platforms?
Yes, RG 97 applies to most retail super and managed investment products, including investor-directed portfolio services (IDPS-like schemes) and superannuation platforms that are required to make enhanced fee disclosure.