Payday Super: ATO releases further guidance ahead of 1 July 2026

In my November 2025 article, I outlined the structural shift that Payday Super represents, specifically moving from quarterly superannuation guarantee (SG) payments to a model aligned with each payroll cycle. Since then, the ATO has provided important additional guidance, finalising its compliance approach for the first year of operation. 

Practical Compliance Guideline PCG 2026/1, released on 28 January 2026, sets out how the ATO will deploy compliance resources in relation to SG shortfalls arising from “QE days” occurring between 1 July 2026 and 30 June 2027.

While the law itself has not changed since the reforms were enacted, this guidance provides greater clarity on how the ATO intends to administer the transition year which is particularly relevant for labour hire and staffing businesses managing frequent and high-volume payroll cycles.

As previously discussed, Payday Super introduces a single earnings base known as “qualifying earnings”. The day those earnings are paid is the “QE day”, and employers must ensure SG contributions are processed and received by the relevant super fund within the required timeframe to avoid a shortfall.

Recognising widespread concern that payroll systems and clearing processes may not be fully embedded by 1 July 2026, the ATO has adopted a risk-based compliance framework for the first year.

Under this framework, employers will fall into one of three following risk zones:

• Low risk applies where an employer has attempted to ensure no individual SG shortfall on each QE day by making on-time contributions equal to or exceeding the required amount, and any delayed or rejected contributions are rectified as soon as reasonably practicable, resulting in no final shortfall.
  
  
• Medium risk applies where the low-risk criteria are not met, but all individual final SG shortfalls are nil within 28 days after the end of the relevant quarter.
  
  
• High risk applies where employers fail to meet either threshold, or where SG shortfalls remain outstanding after that 28-day period.

Importantly, the ATO has emphasised that it has no discretion in applying the law. If it receives definitive information about an SG shortfall, it must administer the legislation accordingly. Even where an employer would otherwise be considered low risk.

For APSCo members, this additional guidance reinforces a key message: the ATO will focus heavily on employer behaviour. Demonstrable attempts to comply, active monitoring of rejected payments, and prompt remediation processes will materially reduce enforcement risk during the transition year.

With the commencement date fast approaching and the Small Business Superannuation Clearing House closing on 1 July 2026, the window for preparation is narrowing. Systems readiness, process testing, and governance oversight should now be front and centre.