Strengthening the superannuation performance test – Submission

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Submissions  |    |  Jun 18, 2026

Strengthening the superannuation performance test – Submission

The Climate Capital Forum welcomes the opportunity to respond to the Treasury’s consultation on Strengthening the Superannuation Performance Test. Australia’s $4.4 trillion superannuation system represents the single largest economic lever available to mobilise the productive capital required for the domestic energy transition. However, the current 10-year backward-looking test creates systemic, unintended consequences. It forces registrable superannuation entity (RSE) licensees to “hug” narrow index benchmarks, heavily penalising the highly differentiated, long-term investment strategies required to finance real-economy decarbonisation.

The superannuation sector currently only allocates an estimated 1% of capital flows directly into clean energy ($44 billion)* despite it being the critical long term infrastructure investment required for the future prosperity of all Australians. It’s estimated that Canadian pension funds invested $408m more in Australian renewable energy projects than Australia’s superfunds. (Passing the Buck, Market Forces)

Whilst estimates have investment in decarbonisation requiring between $200-$500 billion by 2035 (Australia 2035 – Maximising Our Potential, Business Council of Australia). Overall, the industry holds approximately $350 billion in infrastructure assets, the vast majority remains locked in legacy domestic infrastructure such as toll roads, airports, and ports.

To rectify these distortions, CCF strongly advocates for a targeted, high-impact reform agenda that prioritises Option 1.1 (Emerging Asset Class) and Option 3 (Routine Benchmark Review) as complementary and mutually reinforcing mechanisms.

* 1% of total savings based on https://www.climatechangeauthority.gov.au/super-funds-urged-seize-transition-opportunities

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