Payday Super is the biggest threat to employer compliance since Single Touch Payroll. It will expose businesses operating with thin cash buffers or slow receivables.
The headline change under Payday Super is that, from 1 July 2026, employers must ensure that an employee’s superannuation contributions are allocated (or paid) within seven business days of the payment of an employee’s qualifying earnings. Qualifying earnings include ordinary time earnings, commissions, salary sacrifice and payments to workers who fall under the expanded definition of employee, including contractors paid mainly for their labour.
There are some exceptions to the seven business day payment requirement. These include new employees where super contributions are being paid to the fund for the first time, certain cycle payments (e.g. commissions, bonuses), and exceptional circumstances (e.g. natural disasters).
For further information about the legislative changes, required obligations and a checklist, please refer to:
ATO Proactive Change and Focus on Collectable Super
The key intent of this reform is to shift the ATO from a reactionary “lodge and pay” system to a real time, proactive compliance approach to ensure employers meet their superannuation obligations.
During the 2024-2025 financial year, the ATO reported in their annual report that:
- Most employers are meeting their super obligations.
- Of 942,500 employers, 9.3% had a Super Guarantee Charge (SGC) collectable debt. Of these, 12% accounted for 60% of the total SGC collectable debt.
- $201.3 million of SGC debt is under payment plans, representing approximately 9.4% of the total SGC debt and involving approximately 7,600 employers.
- 22,550 firmer and legal actions were undertaken against employers who failed to pay their liabilities.
With the new enhanced reporting through Payday Super, the ATO will be able to make unilateral assessments on an employer’s Superannuation Guarantee (SG) shortfall, enabling earlier identification, intervention and enforcement.
The ATO’s policy is that within 28 days of a debt arising, it should either be resolved or progressed to firmer action (e.g. Director Penalty Notice, Garnishee, Credit Reporting, Court action).
The ATO has issued a Practical Compliance Guideline PCG 2025/D5 which outlines its compliance approach for the first year of operation in investigating SG shortfalls. Under this guideline, taxpayers will be categorised into three risk zones: low, medium, and high.
PCG 2025/D5 can be found here
ATO Risk Zones:
Risk Zone | Unpaid Superannuation Query and Proactive Case Selection |
|---|---|
Low | We will not have cause to review the employer's actions. |
Medium | Compliance resources may be applied to investigate whether the employer has an SG shortfall for one or more QE days. Medium-risk arrangements will be given lower priority than arrangements that are rated high risk. |
High | Compliance resources will be applied to investigate whether the employer has an SG shortfall for one or more QE days. High-risk arrangements will be given the highest priority resourcing |
ATO requirements for each zone:
Risk Zone | Requirements |
|---|---|
Low | An employer will be in the low-risk zone where all of the following have been met:
|
Medium | An employer will be in the medium-risk zone where the employer does not meet the criteria to be in the low-risk zone, but the individual final SG shortfalls for all their employees are nil by 28 days after the end of the quarter in which the qualifying earnings were paid. |
High | An employer will be in the high-risk zone where the employer does not meet the requirements to be in the low-risk or medium-risk zone. An employer will be in the high-risk zone if they have one or more individual final SG shortfalls greater than nil for their employees by 28 days after the end of the quarter in which the qualifying earnings were paid. |
Compression on Cash Flow
Payday Super significantly compresses the cash cycle for employers. The shift from quarterly to per-payday super payments means businesses must rethink cash conversion, liquidity buffers, and working capital management. These changes will expose businesses that are insolvent or experiencing compliance and cash flow issues. Businesses with slow receivables are likely to feel the greatest impact on working capital.
For example, a construction business that pays wages weekly but receives progress payments every 45 to 60 days will now have to make up to 8 super payments before receiving any funds from clients.
Below is an illustration of the SG timing pressure, mapped against the ATO’s data on disengaged taxpayers from the ATO FY25 annual report.
Industry Payment Timeframes and SG Timing Pressure map | ||||||
|---|---|---|---|---|---|---|
Industry | Disengaged Taxpayers | Collectable | Typical Payment Timeframe | Cash-In Pattern | SG | Why it Matters |
Construction | 14,674 | $4.3b | 30–90 days (progress claims) | Lumpy, milestone‑ based | Very High | SG due weekly/fortnightly long before progress payments; the industry with typically the highest insolvency rates |
Administrative & Support Services | 3,290 | $1.1b | 30–60 days | Predictable but delayed | Very High | Labour‑intensive; clients pay monthly; SG typically will be due weekly |
Professional, Scientific & Technical Services | 4,850 | $1.9b | 30–45 days | Smooth but slow | High | SG due before client invoices are paid; high level of compliance disengagement |
Accommodation & Food Services | 4,195 | $1.2b | Same‑day | Fast but thin margins | High | High payroll frequency + low cash buffers = SG payment timing failures |
Manufacturing | 2,362 | $0.8b | 30–60 days | Slow, tied to inventory | High | Cash tied in stock; SG due before revenue received |
Other Services | 3,681 | $1.0b | 14–30 days | Small‑business variability | High | Weak cash buffers; high disengagement |
Transport, Postal & Warehousing | 2,936 | $0.9b | 30–45 days | Moderate delays | High | Fuel + wages upfront; customers pay later |
Agriculture, Forestry & Fishing | 831 | $0.3b | Seasonal; 30–90 days | Highly seasonal | High | SG spikes during harvest; revenue seasonal |
Health Care & Social Assistance | 1,964 | $0.9b | 7–30 days | Medicare/ private billing delays | Medium – High | High payroll intensity; unpredictable billing |
Retail Trade | 2,429 | $0.8b | Same‑day | Fast | Medium | High staff turnover increases SG error risk |
Arts & Recreation | 785 | $0.2b | Seasonal | Variable | Medium | Small sector; moderate disengagement but low payroll intensity |
Rental, Hiring & Real Estate | 1,550 | $0.7b | Commission based | Irregular | Medium | Fixed payroll vs irregular commissions |
Wholesale Trade | 1,047 | $0.3b | 30–45 days | Moderate delays | Medium | Cash flow depends on customer terms |
Financial & Insurance Services | 1,600 | $0.8b | Monthly | Strong | Low – Medium | Strong revenue but pockets of disengagement |
Education & Training | 459 | $0.1b | Term‑based | Predictable | Low | Stable funding cycles |
Electricity, Gas, Water & Waste | 196 | $0.1b | Monthly | Strong | Low | Strong cash flow; low disengagement |
Information, Media & Telecommunication | 356 | $0.1b | Monthly | Predictable | Low | Stable revenue |
Mining | 131 | $0.1b | Monthly | Strong | Low | Strong reserves; low disengagement |
Public Administration & Safety | 307 | $0.3b | Government-funded | Strong | Low | Low risk due to funding certainty |
Insolvent Clients
Payday Super does not create new insolvency risks, it accelerates the existing ones. Issues that may have surfaced are now likely to emerge within as little as 12 weeks, as insolvency events are brought forward due to weak cash flow, poor strategic management, or ATO enforcement.
Early intervention with these taxpayers will provide more options, including both formal and informal restructuring, and can lead to better overall outcomes. A number of insolvency indicators are expected to be affected, including:
Insolvency Indicator | Impact of Payday Super |
|---|---|
Continuing Losses | SG becomes weekly/fortnightly instead of quarterly, accelerating losses and an insolvency spiral |
Liquidity Ratio Deterioration | Current liabilities increase with every pay cycle and working capital tightens. |
Overdue Commonwealth and State Taxes | Increased compliance pressure and missed SG will result in immediate ATO debt |
Creditors Paid Outside Terms | Poor cash flow planning leaves cash diverted to SG, resulting in likely suppliers being paid outside of terms. |
Special Arrangements with Selected Creditors | Increased SG compliance and poor planning leading to payment arrangements with the ATO. |
For a full list of the indicators of insolvency and the consequences of trading while insolvent, please refer to:
Indicators of Insolvency | SV Partners
Supporting Clients Before Issues Escalate
Educating businesses on Payday Super and the impact it will have on their operations will be challenging. These sweeping changes are likely to catch a large number of businesses off guard. From an advisor’s perspective, the difficulty will be reduced if the clients are triaged in a systematic manner, which could include:
- Reviewing your client list to identify those with significant ATO debt and poor payment behaviour.
- From these clients, identify issues between payroll frequency vs revenue timing.
- Refining the list by analysing wages as a percentage of revenue, where any client above 50% considered high risk and prioritised accordingly.
These clients can then be filtered into a priority list for proactive outreach who need additional assistance and scope of works to deal with:
- Rolling cash flow forecasting
- ATO engagement strategy
- Payroll and SG timing modelling
- Cash conversion cycle improvement and debtor day reduction plan
- Additional advisory with working capital
Payday super will accelerate pressure points that already exist in many businesses. For some clients, this will simply require better planning and modelling. For others, the compressed cash cycle, increased ATO visibility and real-time compliance will expose deeper structural issues that cannot be ignored.
When Early Action Is Critical
If you have identified clients who are:
- Already showing signs of insolvency or likely to become insolvent;
- Unable to meet the new compliance obligations;
- Carrying significant ATO debt, receiving DPNs, or repeatedly defaulting on payment plans; or
- Experiencing cash flow gaps that will worsen under the new Payday Super timing rules.
Then early action is critical.
The sooner these clients are supported, the more options are likely to be available. Whether that is restructuring, implementing a stabilisation plan, negotiating with the ATO, or exiting the client if problems cannot be resolved.
If you have clients who are likely to struggle under Payday Super, we are available to confidentially review their situation and outline practical pathways forward. Ensuring your clients receive the right guidance early can help prevent ATO intervention and more serious consequences later.
Please feel free to reach out at any time to discuss a client who may need insolvency or restructuring assistance.
Article by Adam Thorpe (Associate Director) - Brisbane