Changes to PDS Cost Disclosure


In 2019, ASIC released a significant update to Regulator Guide 97 Disclosing Fees and Costs in PDS and Periodic Statements. This was aimed at achieving better outcomes for consumers by providing greater clarity on disclosure obligations for product issuers of superannuation and managed investment products.

Since then, ASIC made further minor changes to RG 97, including the relaxing of implementation of the changes until 30 September 2022.

What are the changes?

The most significant changes were made to the presentation of fees and costs information by:

  • Re-grouping values in the re-named “Fees and Costs Summary” to more clearly show fees and costs that are ongoing and those that are member-activity related
  • Simplification of ongoing fees and costs into three groups:
    • Administration
    • Investment
    • Transactions
  • Inclusion of a single “Cost of Product” figure in the PDS, and
  • Simplification of how fees and costs are presented in periodic statements.

Other changes include:

  • Requiring costs met using reserves to be included in the calculation of fees and costs disclosed in a PDS
  • Confirming that fees and costs in PDS’s are still required to be disclosed gross of any tax benefit being passed on to the member, and
  • Removing the distinction between performance and performance-related fees so the disclosed performance fee will include the performance fees at the product and underlying investment vehicle levels.

Why has ASIC introduced these changes?

ASIC advocates for effective fees and costs disclosure to support better decision-making by consumers and the advisers who assist them. These changes promote greater transparency and achieve better consumer outcomes by setting standards for the clear presentation of fees and cost information.

Fee disclosure on its own was not sufficient to ensure consumers achieved the right outcomes, consistent and comparable disclosure will help consumers and their financial advisers to better understand the fees and costs involved in financial products, compare products more easily, and make more informed assessments of whether the product is suitable.

In Practice

These changes were introduced in 2019 with an initial opt-in window from 30 September 2020 for PDS’s and 1 July 2020 for periodic and exit statements. Therefore, some product issuers may have already implemented these changes to the fees and costs section of the PDS, but all issuers MUST apply the new requirements to a PDS by 30 September 2022.

These changes make the fees and costs information more usable and comparable when researching products and having conversations with your clients.   

GRC Essentials can help

If you have any questions or concerns about these changes or anything compliance related, contact us at