Are your superannuation investment options consistent and ‘true to label’?

12 min read
12 min read

While compulsory contributions and default MySuper products are important features of the Australian superannuation system, Australians can also choose their super fund and the investment option within that fund. In the retirement phase, there are no default super products, and all retired members must make choices about their product and investments. To make a choice that is appropriate for their financial situation, needs and objectives, members need to select options with expected returns and volatility that align with their individual risk profile. Such choices can have lasting impacts on their retirement income, so the disclosures made by trustees about their investment options are very important.

The investment option label is the highest level of disclosure about an option. It is the name by which the investment option is identified and to which all other meaning imparted by more detailed disclosures is attached. Option labels feature in product disclosure statements, member communications, on fund websites, and in tables of product information published by APRA and private ratings agencies. A label represents a short-hand description of the option. To be helpful to consumers, it is critical that a label aligns with the relevant option’s underlying asset allocation and associated risks.

ASIC recently examined investment option labelling by superannuation trustees as part of a broader focus on investment product labelling practices. Over the last two years, ASIC has been undertaking a series of surveillances on the product labelling and marketing practices of responsible entities of managed funds. As a result, 13 responsible entities rectified inappropriate labelling practices. ASIC also took enforcement action against the Mayfair 101 Group, La Trobe Financial Asset Management and Skyring Fixed Income Fund for misleading or deceptive conduct.

In keeping with our communications in recent years, ASIC is asking superannuation trustees to carefully consider whether their investment options are ‘true to label’, and consistent with common use market usage, noting that superannuation investment options are not offered in a vacuum. Investment option labels should contribute to consumers’ understanding of an option’s key features and risks, and be useful when comparing an option to others offered by the trustee, as well as other options in the market.

Analysis of investment option labels

ASIC’s analysis was prompted by recently introduced policies and regulatory initiatives focusing on Choice options and products, such as the design and distribution obligations, APRA’s Choice Heatmap and APRA’s Super Data Transformation initiatives.

Investment option labels are used for both Choice options and MySuper products. MySuper products are separately authorised by APRA, but they are also typically presented as investment options within accumulation product investment menus. For this analysis, ASIC looked at data relating to both Choice and My Super options.

ASIC analysed unpublished data collected by APRA under SRF 550.0 (Asset Allocation)1, SRF 605.0 (RSE Structure) and SRF 001.0 (Profile and Structure), to compare the label of an option to its asset allocation. The full dataset contains over 2,000 investment options, which is itself a subset of all options available to members within super.

Our analysis focused mainly on multi-asset class options. The full dataset was reduced to 898 options after excluding defined benefit products, options with single-asset class labels, options labelled only as MySuper products or MySuper lifecycle stages, options designed by third parties, and other options without an explicit or implicit risk profile. We have outlined our observations and the main areas to focus on here.

Observations

Meaningful components in labels: We observed that most option labels have at least one, and sometimes two, meaningful components. These components relate to:

1. Asset allocation, framed in terms of either:

a. risk profile (for example Balanced, Growth, Conservative); or
b. asset class (such as Equities, Fixed interest, Property); and (optionally)

2. Portfolio management style (such as Passive, ESG, Hedged, Leveraged)

Asset allocation – Risk profile labels

Risk profile labels describe an option’s strategic weighting towards either growing or protecting the portfolio’s value over time. They are commonly used on multi-asset class options – those that invest in a mix of asset classes. In a near universal practice, the assets which make up such options are categorised by trustees, asset consultants and fund managers, as either ‘Growth’ or ‘Defensive’.

Investment options with a higher allocation to growth assets are expected to deliver higher returns and are exposed to higher risk (volatility in returns) than those with lower allocation to growth assets.

It is notable that while APRA applies a ‘Growth/Defensive’ categorisation at the asset class level in its heat map publications, there is no standard method for trustees to apply the ‘Growth/Defensive’ categorisation to their investment options to facilitate consistent reporting in product disclosures. ASIC notes and sees benefit in the efforts of think-tank Conexus to promote a consistent industry approach to growth/defensive asset categorisation.

Our review of risk profile labels used in multi-asset Choice options found that the terms ‘High Growth’, ‘Growth’, ‘Balanced’, ‘Moderate’ and ‘Conservative’ are the most common labels used by trustees. Nearly 75 per cent of options with risk profile labels use labels that include these terms. To understand how these labels are used by trustees to communicate the option’s level of investment risk, we also compared each label against its calculated growth asset weight (GAW)2 in its strategic asset allocation. GAW indicates the portion of the portfolio that is invested in growth assets.

Each of these five labels (and the other less common labels we observed) had a range of GAWs in the market. Chart 1 captures the range (excluding outliers), mean and median GAW for all those labels that appeared three or more times in the dataset. We found that among the five most common risk-profile labels, High Growth has the highest average GAW followed by Growth, then Balanced, Moderate and Conservative with the lowest GAW.

While there are clear overlaps in the GAW ranges between these five labels (most obviously between options labelled ‘Moderate’ and ‘Conservative’), the general order in which they are used indicate some commonality of use of the terms.3  This is important because it provides a foundation on which super trustees can build to improve the consistency of investment option labels used in the market.

Issues to focus on

We found a number of issues with risk profile labels that warrant trustee attention.

Misalignment with level of risk: We found examples of options that use common risk profile labels, but in a manner inconsistent with the level of risk typical for that label. An example is an option labelled as ‘Defensive’ but with a GAW that is more akin to the median Balanced option. While these terms are not defined in any official regulation or industry standards, the use of labels in stark contrast to general industry practice does risk being misleading.

Too many uncommon labels: There is a proliferation of less common, even unique, risk profile labels. These make comparing options more difficult for consumers. Besides the five most common labels identified, we found more than 20 other risk profile labels for multi-asset class options. Most of these categories have GAW that overlap with one of the five most common. One of many such examples is that the GAW range of options labelled ‘Cautious’ overlaps entirely with that of options labelled ‘Moderate’.

Confusing or complex labels: We also
found some confusing combinations of terms in investment option labels, with some combining terms that, if given their standard meaning, are contradictory, such as ‘Conservative Growth’, ‘Moderately Conservative’.

Asset allocation – Single asset class labels

ASIC also considered options with labels that indicate assets are held in single asset classes, such as ‘Cash’, ‘Equities’, ‘Shares’, ‘Bonds’ or ‘Property’. In general, the asset allocations of such options were found to match the labels, though there were exceptions. It goes without saying that an option labelled ‘Cash’ that does not overwhelmingly contain cash or cash equivalents risks being misleading, even if detail about a more complicated asset allocation is published in the fine print of product disclosures. Trustees should note the relevant accounting standards and APRA reporting instructions and other guidance4 when categorising certain assets as either ‘cash’ or ‘cash equivalents’. ASIC is engaging with industry on such matters where necessary to seek corrective disclosures.

Portfolio management style

We noticed some option labels had a component related not to asset allocation but to portfolio management style. Here, we refer to terms such as ‘Passive’ or ‘Index’ to communicate an option where fund managers aim to match an index rather than select individual assets to outperform the market. We also saw the use of terms such as ‘Sustainable’ or ‘ESG’ to communicate a sustainable orientation to investment.

We observed that in most cases, the absence of terms relating to portfolio management style implied certain investment option features. For example, the absence of a term like ‘Passive’ or ‘Index’ generally implied that the option includes asset classes with active management.

It was also not uncommon for options labelled ‘Sustainable’ or similar, or ‘Passive’ or similar, to have no part of the label relating to risk profile. For options of this type, we found a GAW range that overlaps with the ‘Balanced’ range.

Marketing language: In our analysis, we noticed some labels contained extraneous marketing language or brand names. The use of product or brand names in labels for options that are not offered through investment platforms seem to add complexity without providing useful information. Some trustees also included terms that complicate labels without adding any useful information – for example, terms like ‘pooled’, ‘managed’ and ‘diversified’, all of which may be used to describe any superannuation investment option. These appear to be unnecessary marketing terms designed to impress, not inform, the consumer.

We note that investment option labels may include terms that signal a sustainable or ethical focus. However, the marketing of sustainable options, including any related misrepresentation (greenwashing), was not the focus of this work.

Looking ahead

Our analysis found a base of fairly consistent label usage by a range of trustees in the market, leading to a number of common terms having reasonably well-established meanings in standard practice. This includes use of the five most common labels – ‘High Growth’, ‘Growth’, ‘Balanced’, ‘Moderate’ and ‘Defensive’ – for a range of multi-asset class investment options.

However, we also saw some divergent behaviour and practices that may make it more difficult for consumers to understand and compare superannuation fund and option choices. Beyond misuse of labels for single-asset class options where the assets are not within the class, which is potentially misleading and deceptive, trustees should avoid:

• use of unusual or unique labels
• using common labels in a manner inconsistent with general market practice, and
• using common terms in odd or contradictory combinations or mixed with marketing language.

Trustees risk confusing consumers if their investment option labels use terms that are not meaningful, or worse, meaningful but misleading, such as by making the options appear more or less risky than they really are.

In the absence of explicit regulatory rules or industry standards about the use of investment option labels, ASIC expects trustees to give thought to their use of labels in investment menus, and whether the labels contribute to clear consumer understanding and sound decision making.

We strongly encourage trustees to use common terms that are consistent with market practice to provide clarity to consumers and to help direct them to investment options that match their investment and risk appetite. For the main menu of multi-asset class investment options, it would be clearer for consumers if trustees adhered to the most common labels for options in the central range of GAW, as captured in Chart 1.

 

 

When making an investment choice, members generally consider detailed disclosures, such as product disclosure statements, in addition to relying on their understanding of option labels. However, trustees should bear in mind that disclosure alone is insufficient. Investment option labels should be consistent with the key features and risks, and align with more detailed disclosures.

The design and distribution obligation, which took effect on 5 October 2021, go a step further. Trustees are required to prepare a target market determination (TMD) for each of their products as part of these obligations. For most trustees, their TMDs are due for a review this calendar year. We encourage trustees to consider the appropriateness of their investment option labels as part of this review.

Trustees undertaking their annual member outcomes assessment will also benefit from considering their option labels to determine whether the labels help consumers to make an informed investment choice about their superannuation.

 

  1. The dataset contains all investment options for which data was reported on SRF 550.0 Asset Allocation Table 1 by 1 June 2021. Due to staged implementation under SRS 550.0 Asset Allocation, RSE licensees were only required to submit data in respect of MySuper products and Trustee Directed Products as at 1 June. Reporting for other investments options was not mandatory until later in 2022.
  2. Growth Asset Weighting has been determined using the strategic sector of each asset allocation reported to APRA.  The calculation uses the ‘Growth/Defensive’ classification used in     APRA’s  Superannuation heatmaps, details of which can be found at https://www.apra.gov.au/superannuation-heatmaps.
  3. One notable overlap is between the ‘Moderate’ and ‘Conservative’ categories, attributable in our view to the ‘Moderate’ label being used for options with a very broad range of GAW.
  4. See AASB 107 Statement of cashflows (especially paragraphs 6 and 7), Reporting Standard SRS 550 Asset Allocation and APRA’s June 2018 letter to trustees.

 

Picture of By Jane Eccleston

By Jane Eccleston

Superannuation Senior Executive Leader

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As a Brand and Content Manager, Sinem has built her career working across brand campaigns, social media strategy and cross-channel storytelling.

Working at the intersection of technology and creative innovation, she’s crafted her skill of turning complex brand concepts into engaging social narratives that connect and resonate with member experiences.

Specialising in superannuation, she’s passionate about exploring how brand storytelling through social media can converge to drive meaningful audience connection.

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Gemma was appointed as Chief Risk Officer in November 2018 and leads the Enterprise Risk function which includes investment risk, operational risk, business resilience, financial crime, compliance and regulatory engagement.

Gemma has over 25 years’ experience in risk management and governance across multiple industries including government, engineering and financial services. She is known for her ability to drive organisational change and achieve business objectives in complex and dynamic environments. Prior to joining Rest, Gemma held senior positions at MLC Life Insurance, MLC Wealth, Parsons Brinkerhoff and Federal Treasury. She is a Director on the Board of the Fund Executives Association Limited. Gemma holds a Master of Arts from the Australian National University, a Bachelor of Economics, Social Science (First Class Honours) from the University of Sydney and is a graduate of the Australian Institute of Company Directors.

Adrian C

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Adrian C works in the Australian Signals Directorate and is the Director of ASD’s Cyber Security Partnership Program.

He has worked in various roles in the National Intelligence Community for the last 16 years including geospatial intelligence, intelligence support to Australian Defence Force Military Operations and writing core components of the Comprehensive Review – legal framework of the National Intelligence Community. 

Adrian transferred to Australian Signals Directorate in 2021 and was responsible for the section that develops and publishes ASD’s technical publications and guidelines.

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Kate Farrar

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Since her appointment as CEO in April 2018, Kate has overseen the merger of LGIAsuper and Energy Super and the acquisition of Suncorp Super—the first industry fund acquisition of a retail fund. This integration, completed 18 months ahead of schedule, delivered a 40% reduction in administration fees for members while expanding services across Queensland.

Under Kate’s leadership, Brighter Super has become one of the fastest-growing industry funds in Australia, recognised for both its operational sustainability and member-first approach. In acknowledgment of these achievements, she was awarded the Fund Executive of the Year Award by the Fund Executives Association Ltd (FEAL) in 2024.

Kate brings 35 years of leadership experience across finance and energy, including senior roles at Barclays de Zoete Wedd, Suncorp Investment Management, NSW Treasury Corporation, McKinsey & Company, and Ergon Energy.

Beyond her role at Brighter Super, Kate serves as a Non-Executive Director of ASX100-listed Seven Group Holdings and is the President of the Queensland Futures Institute.

She holds a Bachelor of Music (Honours) and a Master’s Degree in Econometrics and Finance. Through a scholarship from Chief Executive Women, she is also a graduate of INSEAD’s Advanced Management Programme. In 2025, following her FEAL award education grant, Kate completed the Stanford Graduate School of Business program, People, Culture, and Performance: Strategies from Silicon Valley.

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Joseph has a Bachelor of Economics and Bachelor of Arts from Australian National University and a Graduate Certificate in Applied Finance from the University of NSW.  

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Vasyl Nair

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The Team Superannuation Fund (Team Super) is a profit-to-members, public offer pension fund dedicated to serving the retirement needs of all Australians. Team Super manages over $22 billion in funds for approximately 150,000 members.

Vasyl Nair is the Chief Executive Officer of Team Super (prior to this, Vasyl held the roles of Deputy Chief Executive Officer, Chief Risk Officer and Chief Strategy Officer).

Vasyl is a keen advocate for the ongoing development of the superannuation sector, with active participation in a number of different parts of the industry. He has served as a director of an Australian fintech organisation, specialising in superannuation and investment administration.

Vasyl was appointed to the Board of the Association of Superannuation Funds of Australia (ASFA) as Director in January 2025, the peak pension fund association in Australia.

Vasyl has a strong background in law, corporate finance and strategy, having held senior roles across at some of Australia’s largest financial services institutions. Vasyl holds a Bachelor of Laws (Hon), Bachelor of Commerce, Graduate Diploma of Legal Practice and an Executive Master of Business Administration. He is admitted to the Supreme Court of NSW as a solicitor, is a Graduate of the Australian Institute of Company Directors and has achieved a Certificate of Business Excellence from the Haas School of Business, U.C.
Berkeley.

Kristian Fok

Chief Executive Officer, Cbus Super

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Kristian Fok is the CEO of Cbus Super, Australia’s leading specialist superannuation fund for the building and construction sector. Cbus was founded 40 years ago and provides superannuation and income streams to more than 925,000 members and manages over $105 billion of members’ money (as of 30 June 2025). He is responsible for all aspects of Cbus and reports directly to the Board.

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A recognised thought leader, Kevin is known for leveraging data-driven insights to deliver sustainable value. His leadership is central to Novigi’s market positioning, helping to define the company’s growth strategy in an increasingly complex and dynamic financial landscape.  

Vicki Doyle

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Vicki joined Rest as Chief Executive Officer in May 2018, bringing more than 20 years of
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Vicki’s experience includes executive leadership roles at some of Australia’s largest financial services organisations. She has an extensive background in distribution, strategic marketing, digital, fund operations and contact centres, customer strategy and design and product management.

Vicki is passionate about simplifying and demystifying superannuation to help all Australians achieve their best retirement outcomes.

Vicki holds an Executive MBA from the Australian Graduate School of Management and a diploma from the Australian Institute of Company Directors. Vicki has been a Non-executive Director of the Australian Council of Superannuation Investors since 2018 and a Director of The Association of Superannuation Funds of Australia since 2022.

Louise Davidson, AM

Chief Executive Officer, Australian Council of Superannuation Investors (ACSI)

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As CEO of the Australian Council of Superannuation Investors (ACSI) since 2015, Louise oversees ACSI’s program of company engagement, research and policy advocacy, backed by 30 years of senior experience in the financial services and ESG sectors. Her tenure as ACSI CEO has seen significant improvements in the way listed companies manage important issues including boardroom diversity, climate risk and human rights.  

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She is a director of Chief Executive Women, deputy chair of the Federated Hermes Client Advisory Board, and a former director of the Peter MacCallum Cancer Centre and the International Integrated Reporting Initiative and former chair and director of the Mother’s Day Classic Foundation. 

Peter Chun

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Peter is a qualified Actuary with a Bachelor of Economics from Macquarie University. He holds Graduate Diplomas in Applied Finance and Investments and Financial Planning from the Securities Institute of Australia; and has undertaken the Advanced Management Program at Harvard Business School (Boston, USA).

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Cath is the Chair of IFM Investors; Industry Super Holdings (ISH); and the Federal Government’s Jobs & Skills Ministerial Advisory Board.   

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Natalie is the Chief Executive Officer of NGS Super.  

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Laura Catterick

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Lt Gen Michelle McGuinness, CSC

National Cyber Security Coordinator, National Office of Cyber Security

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Lieutenant General Michelle McGuinness, CSC was appointed as Australia’s National Cyber Security Coordinator (the Coordinator) on 26 February 2024.

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LTGEN McGuinness has served in the Australian Defence Force for 30 years in a range of tactical, operational, and strategic roles in Australia and internationally.

Prior to this appointment, LTGEN McGuinness most recently served as Deputy Director Commonwealth Integration in the United States Defense Intelligence Agency. In this role, she led policy and cultural reform, and technological integration, including interoperability across information technology, systems and data.

Jamie Bonic

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Katie Miller

Deputy CEO, Regulation, AUSTRAC

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Katie Miller is the Deputy CEO, Regulation, AUSTRAC and has strategic responsibility for AUSTRAC’s regulatory, policy and legal functions. 
Katie has extensive experience exercising regulatory functions and advising regulators at state and federal levels. Katie is a published author on issues involving regulation, law and technology and supports connections between government, practitioners, communities of practice and academia. 

Derek Thompson

Via live link

Best Selling Author, Podcast Host of 'Plain English'

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Few speakers can match Derek Thompson‘s ability to synthesize mega-trends in society, labor, economics, technology, and politics. Put another way: Derek trawls the data sets and does the forecasting and deep reporting necessary to help us better understand how we live, how we vote, how we spend, and how we work.

In his paradigm-shifting #1 New York Times bestseller, Abundance (co-written with Ezra Klein), this award-winning journalist reveals how our policies and culture have pushed us into a world of scarcity (not enough housing, workers, or progress)—and offers a radical new path towards a world where housing is affordable, energy is plentiful, and innovation flourishes across industries.

He shares a compelling vision of a future where we have more than enough for everybody, and a practical, actionable roadmap for how to get there. It starts with taking more risks, building more expansively, and recognizing that we all have the power to create a world of abundance. “Everything’s utopian until it’s reality,” he says.

Carmen Beverley-Smith

Executive Director - Superannuation, Life & Private Health Insurance, APRA

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Carmen joined APRA in March 2023 and holds the role of Executive Director, Life and Private Health Insurance and Superannuation.  

She has had an esteemed career in financial services, spanning over 25 years. She has held diverse leadership roles at Westpac and Commonwealth Bank of Australia, including across risk, transformation and change, product and portfolio development, and sales and service. 

Prior to joining APRA, she held the role of General Manager, Risk Transformation Delivery Integration at Westpac. This involved leading the group-wide implementation of a suite of solutions to uplift risk management capability and develop data, analytics and reporting. 

Carmen leads with a values-driven approach and a particular interest in developing and mentoring talent. 

She holds a Bachelor of Commerce and Accounting, is a certified Chartered Accountant and a Graduate of the Australian Institute of Company Directors. 

Amy C. Edmondson

Novartis Professor of Leadership and Management, Harvard Business School

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Amy C. Edmondson is the Novartis Professor of Leadership and Management at the Harvard Business School, a chair established to support the study of human interactions that lead to the creation of successful enterprises that contribute to the betterment of society.

Edmondson has been recognized by the biannual Thinkers50 global ranking of management thinkers since 2011, and most recently was ranked #1 in 2021 and 2023; she also received that organization’s Breakthrough Idea Award in 2019, and Talent Award in 2017.  She studies teaming, psychological safety, and organisational learning, and her articles have been published in numerous academic and management outlets, including Administrative Science Quarterly, Academy of Management Journal, Harvard Business Review and California Management Review. Her 2019 book, The Fearless Organization: Creating Psychological Safety in the Workplace for Learning, Innovation and Growth (Wiley), has been translated into 15 languages. Her prior books – Teaming: How organizations learn, innovate and compete in the knowledge economy (Jossey-Bass, 2012), Teaming to Innovate (Jossey-Bass, 2013) and Extreme Teaming (Emerald, 2017) – explore teamwork in dynamic organisational environments. In Building the future: Big teaming for audacious innovation (Berrett-Koehler, 2016), she examines the challenges and opportunities of teaming across industries to build smart cities. 

Edmondson’s latest book, Right Kind of Wrong (Atria), builds on her prior work on psychological safety and teaming to provide a framework for thinking about, discussing, and practicing the science of failing well. First published in the US and the UK in September, 2023, the book is due to be translated into 24 additional languages, and was selected for the Financial Times and Schroders Best Business Book of the Year award.

Before her academic career, she was Director of Research at Pecos River Learning Centers, where she worked on transformational change in large companies. In the early 1980s, she worked as Chief Engineer for architect/inventor Buckminster Fuller, and her book A Fuller Explanation: The Synergetic Geometry of R. Buckminster Fuller (Birkauser Boston, 1987) clarifies Fuller’s mathematical contributions for a non-technical audience. Edmondson received her PhD in organisational behavior, AM in psychology, and AB in engineering and design from Harvard University.

 

Daniel Mulino MP

Assistant Treasurer and Minister for Financial Services

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Born in Brindisi, Italy, Daniel was a young child when he moved with his family to Australia. He grew up in Canberra and completed his first degrees – arts and law – at the ANU. He then completed a Master of Economics (University of Sydney) and a PhD in economics from Yale.

He lectured at Monash University, was an economic adviser in the Gillard government and was a Victorian MP from 2014 to 2018. As Parliamentary Secretary to the Treasurer of Victoria, Daniel helped deliver major infrastructure projects and developed innovative financing structures for community projects.

In 2018 he was preselected for the new federal seat of Fraser and became its first MP at the 2019 election, re-elected in 2022 and 2025. From 2022 to 2025, Daniel was chair of the House of Representatives’ Standing Economics Committee in which he chaired inquiries; economic dynamism, competition and business formation and insurers’ responses to 2022 major floods claims.

In 2025, he became the Assistant Treasurer and Minister for Financial Services.

In August 2022, Daniel published ‘Safety Net: The Future of Welfare in Australia’, which aims to explore the ways in which an insurance approach can improve the effectiveness of government service delivery.