Over the past year, APRA has sharpened its attention on how superannuation funds oversee their outsourced service providers, with particular concern around valuation governance, unit pricing accuracy and data integrity. Recent reviews and communications make one point very clear. While outsourcing remains a core operating model for the industry, trustees retain full accountability for the accuracy of member outcomes.
This shift places a spotlight on functions that are often delegated to administrators or custodians, such as NAV calculation, valuations, reconciliation and asset register maintenance. These activities are typically handled outside the trustee’s walls, but under the prudential framework, the responsibility for their quality and accuracy stays firmly with the trustee.
With CPS 230 taking effect in 2025 and APRA continuing to raise the bar on third party oversight, now is the right time for super funds to strengthen how they oversee outsourced NAV and valuation processes.
Outsourcing Does Not Remove Trustee Accountability
Under SPS 231, outsourcing a material business activity does not reduce the trustee’s obligations. Even where NAV and valuation tasks are performed by an external administrator, the trustee must be able to evidence effective oversight. This includes understanding how NAV components are produced, how data is transformed, how valuations are supported and how issues are escalated, tracked and resolved. Fund Recs sees this every day across administrators, asset managers and trustees globally. Service providers perform the calculation, but trustees are still responsible for ensuring the results are accurate, complete and appropriately validated.
APRA’s Scrutiny Is Increasing, Especially on Valuation and Unit Pricing Controls
APRA’s recent reviews highlight a number of recurring gaps across the industry:
- Limited evidence of trustees challenging administrator-produced NAVs or valuations
- Weak audit trails and documentation around valuation assumptions
- Insufficient monitoring of reconciliation issues and exceptions
- Underdeveloped contingency and exit plans for material outsourced providers
- Reliance on manual spreadsheets to validate NAV components
- Lack of holistic reporting to the board or investment committee
These findings point to a core theme. Super funds need stronger, more transparent and better documented oversight of third parties. This is precisely where modern oversight technology can make a significant difference.
Why NAV Oversight Matters for Super Funds
NAV calculation touches every aspect of member value. If it is wrong, delayed or based on inaccurate inputs, the consequences are immediate.
- Incorrect unit pricing
- Misstated performance
- Inaccurate fee and cost disclosures
- Regulatory risk and remediation
- Member detriment
- Loss of trust in the fund’s governance
As asset allocations become more complex and reliance on external administrators grows, the importance of a robust oversight layer increases significantly. Fund Recs’ experience with super funds and global asset managers shows that the biggest NAV risks often stem from inconsistent data, slow exception resolution, undocumented adjustments and reliance on manual spreadsheets for oversight.
What Trustees Must Strengthen Now
- A Clear Oversight Governance Framework
Trustees need defined roles, responsibilities and reporting lines for NAV and valuation oversight. Board and committee visibility is essential. Under SPS 231 this includes a formal outsourcing policy, documented oversight responsibilities and alignment to the fund’s broader risk framework. Fund Recs enables trustees to centralise and report on oversight processes so boards receive consistent, evidence-based insights.
- Stronger Due Diligence on Service Providers
Trustees must understand how an administrator calculates the NAV, how their data pipeline works, how reconciliations are handled and what controls support valuation processes. This is especially important for unlisted assets. Fund Recs provides transparency across data sources and transformation logic, helping trustees assess the strength of provider controls.
- Contracts That Specify Data and Oversight Standards
Contracts with NAV or valuation providers should clearly define reconciliation expectations, data quality requirements, audit rights, error management and reporting obligations. Fund Recs creates an independent audit trail that supports these contractual standards.
- Ongoing Monitoring, Not Annual Reviews
Oversight must be continuous, not periodic.Fund Recs offers daily oversight workflows, exception management, variance analysis and full audit trails, giving trustees a real-time understanding of third party performance.
- Data Integrity and Automated Reconciliation
Manual spreadsheets are not sufficient. NAV oversight requires automated reconciliation of cash, positions, transactions and valuations, with full transparency. Fund Recs automates these checks and presents results through intuitive dashboards and exception workflows.
- Contingency Planning and Transition Readiness
APRA expects trustees to plan for provider failure or transition. This requires visibility of all data flows, processes and dependencies. Fund Recs helps trustees maintain continuity by centralising oversight data and making NAV validation processes portable across providers.
The Advantage of Modern Oversight
Strengthening NAV oversight is not only a regulatory expectation. It also delivers commercial and governance benefits.
- Faster issue detection and resolution
- Reduced risk of NAV errors and member remediation
- Transparent reporting for boards and investment committees
- Improved confidence during market volatility
- Better assurance for internal and external auditors
- Stronger relationships with administrators through clearer accountability
Fund Recs helps super funds shift from manual oversight to an automated, data driven model that aligns with the standards APRA expects.
Conclusion
Super funds operate in an environment where regulatory expectations around outsourcing and valuation governance are rising. Trustees cannot assume that third party controls are always sufficient or that outsourcing reduces their responsibility. NAV oversight is no longer a technical operational detail. It is a key governance discipline that directly affects member outcomes, regulatory confidence and the fund’s reputation.
Fund Recs provides the oversight layer that empowers trustees to meet these expectations with confidence. With automated reconciliation, transparent audit trails and a single view of third party performance, super funds can demonstrate strong governance across their outsourced NAV and valuation ecosystem.
