
The ATO’s 2026-27 compliance program includes reviews of high-volume SMSF auditors. The question is simple: do you have the processes to manage the number of audits you sign? For most practices, part of the answer is automation.
The same program also found files without sufficient appropriate evidence of ownership, existence and market value. Technology can move evidence into your file faster. It cannot decide what that evidence means.
Here is where the line sits.
Direct bank data feeds and electronic confirmation platforms replace trustee-supplied statements. Evidence obtained directly from an external source is generally more reliable under ASA 500 and ASA 505. Your job shifts from keying figures to evaluating the feed. Confirm it maps to the correct account, and record how you tested it in line with ASA 230.
Pull holding balances from registry and HIN data, and year-end closing prices from market data sources. This covers existence, ownership and regulation 8.02B market value for listed assets in one pass. Suspended, delisted or thinly traded securities should drop out as exceptions for manual review.
Configure tests that flag:
The tool flags. You assess whether the trustee returned the amount and what follows.
Standardised request lists, trustee portals and automated reminders reduce the time spent chasing. They also produce a timestamped record. That matters because trustees have 14 days to respond to a written request, and your 28-day window for the audit report runs from receipt of all relevant documents. A clean log shows exactly when that clock started.
Automate:
This is low-judgement work, and errors here are avoidable. The ATO continues to report basic reporting mistakes, including outdated IAR versions and late ACRs.
Real property, unlisted unit trusts, private company shares and collectables need your assessment. An automated valuation estimate is a data point. It is not objective evidence you can rely on without evaluating its basis. With Division 296 applying from 1 July 2026, valuation evidence now affects member tax outcomes as well as fund compliance. Your assessment of whether trustees allocated investment returns on a fair and reasonable basis under regulation 5.03 carries more weight.
A rules engine can flag a possible breach of section 66 or the in-house asset rules. Whether that breach is reportable depends on the ACR reporting criteria, including the trustee behaviour test. The ATO has confirmed that some market value matters involve professional judgement. A reporting decision made by a checkbox will not survive a review.
The following remain your conclusions and nobody else’s:
Independence deserves particular care. The ATO is reviewing arrangements where firms provide both assurance and non-assurance services to a fund, and APES 110 applies regardless of the software you use.
Automate collection, not conclusion. Every tool in your workflow is a technological resource under ASQM 1, and your quality management system should address it. For each tool, document:
An efficient file that cannot show the auditor’s reasoning is not an efficient audit.
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