
From 1 July 2026, the Payday Super regime will be in effect and will require employers to pay superannuation guarantee (SG) contributions at the same time as they pay salary/wages (Payday Super). Payday Super replaces the current requirement to pay SG quarterly where employers have had 28 days from the end of each quarter to pay their SG contributions.
Under Payday Super, SG contributions must not only be paid within seven business days but they must also be received by the employee’s nominated superannuation fund within seven business days (with limited exceptions). Under current superannuation transfer systems operated by third-party intermediaries, this frequently does not occur.
Naturally, if intermediaries are being relied upon, the payment being transferred to each employees’ member account within their superannuation fund is outside of the employer’s control. All that employers can do is merely make sure their payroll and superannuation contributions are approved for payment by pressing the relevant ‘button’ at their end within the seven-day time frame. They then need to rely on software and systems provided by third-party suppliers, especially software and digital service providers (DSPs), to ensure the money ends up in the relevant superannuation fund with the correct employee details.
In short, the Payday Super regime makes employers responsible for things that are entirely out of their control, including the electronic transfer of money and employee’s giving incorrect information such as their tax file number (TFN), in meeting a seven-day time frame. While many professional bodies such as the accounting bodies, the SMSF Association and The Tax Institute submission were broadly in favour of the policy objectives underpinning the Payday Super regime, they did not agree with the short time frames and the fact that employers were made responsible for the receipt of SG contributions by a fund (rather than the time of payment by the employer).
Key considerations for employers
Build and test systems now
One of the most pressing practical challenges for employers is ensuring payroll and payment systems can meet the seven-day time frame. Given the legislation was only passed on 4 November 2025, DSPs are still working on updates to support Payday Super and faster processing and transmission time frames, so don’t be surprised if you’re going to be facing trouble ahead.
While the preferable course of action would have been for the systems to have been upgraded before the new Payday Super regime commenced to ensure the timeframes were achievable, instead, the Payday Super legislation was fast tracked with a ‘go-live’ commencement date of 1 July 2026. Understandably, many DSPs did not begin upgrading their systems until after the legislation was passed.
Employers are therefore at the mercy of the DSPs and payment and related infrastructure systems which will still have to be upgraded and tested before being available for use. Despite these substantial systemic changes, heralded by some as one of the major superannuation changes in the past 30 years, there is no transition period from 1 July 2026 to ensure that the systems and time frames will be achievable if the DSPs and others do not deliver in time.
Feedback from numerous employers and members suggests that current processing times of some of the best payroll and payment systems available at the time of writing this article were on average eight days or more.
Work is also underway with changes to the SuperStream standards and Single Touch Payroll reporting that should hopefully also assist in speeding up some payments and processes.
Thus, employers should focus their time to test and validate whether their payroll and superannuation systems will cope and seek updates from their DSPs and related suppliers as soon as possible to confirm their systems and any updates ahead of 1 July 2026. Advisers should be working with employers and other relevant people to make sure they are doing their best to comply with the new regime from 1 July 2026.
Industry leaders have requested appropriate measures be made so employers are not responsible for delays that are outside their control and for further transitioning provisions given the fast-approaching start date. Unfortunately, the government has not yet confirmed whether any changes to the Payday Super regime will be made.
The estimated number of SG contributions for the first Payday Super year ending 30 June 2027 is expected to increase from the current 150 million contributions to over 500 million in FY2027. Further, around 88% of employers will need to change to their current SG arrangements. The Gateway Network Governance Body recently reported that Payday Super is one of the most complex operational reforms the superannuation system has ever faced. With the massive increase in volume and timeliness, there are likely to be considerable errors and other issues that will need to be resolved. Employers will largely be at the mercy of the infrastructure for transferring contributions and data from employers to super funds within the 7-day time frame.
Cash flow planning and timing of payments
Under Payday Super, the timing of SG payments can materially affect employer cash flow given they no longer have until 28 days after the end of each quarter to pay the SG for the prior quarter.
Late payments, even by one day beyond the seven-day deadline, can trigger superannuation guarantee charge (SGC) payments that include a new notional earnings component (NEC) and potentially a range of administrative penalties.
These penalties can include a 60% administrative uplift penalty if the employer does not lodge a voluntary disclosure statement before receiving an SGC assessment. Further, the general interest charge also applies on any outstanding amounts including the SGC, NEC and the administrative uplift penalty. The penalties can be substantial and readily result in insolvency, director penalty notices, and an employer suffering considerable reputational and employee-relationship damage by potentially being called a ‘wage thief’ under the Fair Work Act 2009 (Cth) with substantial further consequences.
Some employers are even considering, to minimise risk given the tight payment time frame, to change payday to a Friday. This way the full succeeding five business day week plus the following Monday and Tuesday count. This might provide two weekends (being four days that are not business days) plus the seven business days equalling 11 potential days for the SG to be paid to the employees’ superannuation funds. However, most employers cannot simply change their usual payday for fear of employee backlash.
Quarterly SG payments in the last quarter of FY 2026
Employers should, in particular, be planning ahead to ensure that their SG contributions for the final quarter of the 2025–26 financial year (April–June 2026) are paid before 30 June 2026. In contrast, if an employer pays the final 2025–26 financial year quarter before 28 July 2026, within the usual 28-day time frame that applies prior to 1 July 2026, this could easily result in excess contributions assessments for certain employees in the 2026–27 financial year. This might occur if the final June 2026 quarter and all of the 2026–27 financial year SG contributions are received in the 2026–27 financial year resulting in excess concessional contributions (a $32,500 cap is expected to apply for the 2026–27 financial year with indexation; a $30,000 cap applies for the 2025–26 financial year). Employers should therefore aim to pay SG contributions for the 2025–26 financial year well before 30 June 2026 to minimise this risk.
Having said that, the Government is aware of this issue and has indicated it might introduce a transitioning measure for the 2026–27 financial year where excess contributions arise from the bunching of SG contributions just alluded to.
Indeed, employers are best advised to start paying superannuation with wages and salary as soon as practical and not wait until 1 July 2026 to do so as this will commence the process of working out what other changes, resources and training are required. This will give employers the best opportunity to iron out as many issues as possible before ‘going live’ for Payday Super on 1 July 2026.
Closing comments
Employers should not delay preparation. Employers and advisers need to be planning to comply with the Payday Super regime well before it starts on 1 July 2026 to allow sufficient time to upgrade systems, test them and undertake cash-flow planning. A top priority for employers is to seek confirmation from current payroll systems on handling time frames and what else needs to be done to comply with the 1 July 2026 requirements. Otherwise, business survival may be at risk for many micro and small to medium enterprises unless they can implement Payday Super in a timely, smooth and compliant manner. Failing pre-30 June teaches the lesson — failing after 1 July teaches the cost.
Related articles/webinars:
- Payday Super – Part 1: The new law
- Payday Super – Part 2: Not quite ‘all systems go’
- Payday super and the SG system — issues for employers
- Employee or contractor — SG and the right to delegate — Part 8
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This article is for general information only and should not be relied upon without first seeking advice from an appropriately qualified professional. The above does not constitute financial product advice. Financial product advice can only be obtained from a licenced financial adviser under the Corporations Act 2001 (Cth).
Note: DBA Lawyers presents monthly online SMSF training. For more details or to register, visit www.dbanetwork.com.au or call 03 9092 9400.
For more information regarding how DBA Lawyers can assist in your SMSF practice, visit www.dbalawyers.com.au.
By Nick Walker, Lawyer ([email protected]) and Daniel Butler, Director ([email protected]).
DBA LAWYERS
26 February 2026
