At a glance: when a newly established SMSF must lodge
- You must lodge an SMSF annual return if your fund received any contributions (even a small ‘test’ amount) or any rollover before 30 June, or held any assets at any time during the year.
- You may not need to lodge in the first year if the fund had no assets for the entire year and received no contributions and no rollovers before 30 June.
- If you don’t lodge, you still generally need to ask the ATO to mark the fund as return not necessary (RNN) or cancel the fund’s registration.
When are SMSF annual returns not necessary
An annual return isn’t necessary where the SMSF meets all of the criteria below:
- there were no contributions made to the fund during the year,
- there were no rollovers into the fund during the year, and
- the fund did not have any assets at any time in the period to 30 June.
This is because, without any assets, the fund didn’t legally exist during the year.
For example, Joe signed the various paperwork to establish his SMSF in March 2025. He elected for his fund to be regulated by the ATO and received his fund’s ABN and TFN in April 2025. There were delays in organising Joe’s rollover into his SMSF and it wasn’t received until July 2025. Joe didn’t make any contributions to his SMSF in 2024/25 and it had no assets at all during 2024/25. This means Joe’s SMSF didn’t legally exist in 2024/25 and a return isn’t necessary for that year.
Joe’s friend, Henry, also setup an SMSF in 2024/25. As soon as Henry received his fund’s ABN and TFN, he opened a bank account in the fund’s name and transferred $10 in from his personal account just to make sure everything was working ok. This was the only transaction for the fund for 2024/25 - Henry’s rollover in from his industry fund wasn’t received by his SMSF until July 2025.
Despite there being only one small transaction for the year, Henry’s fund will still need to prepare financial statements, have them audited and lodge an annual return with the ATO for 2024/25. There will be fees payable including accounting fees, an audit fee and the ATO supervisory levy.
Tip: avoid triggering a first-year SMSF annual return.
If you don’t intend to use your newly established SMSF before 30 June, consider waiting until 1 July to make the first contribution. Any amount received before 30 June (even a small test transfer) will generally mean you must prepare accounts, arrange an audit and lodge an SMSF annual return for that year.
Return not necessary (RNN): What to do if your SMSF had no assets
If your newly established SMSF had no assets before 30 June, the ATO will still require formal notification that a “return is not necessary” (RNN) as this prevents the SMSF from being flagged as late or non-lodging in their system.
To lodge a RNN, the trustee will need to:
- Provide evidence showing the date the fund first held assets after 30 June. This evidence must be an official bank statement (screenshots and transaction lists are generally not accepted). The statement should clearly show:
- the financial institution’s name and logo,
- the period of the statement,
- the name of the account holder,
- the opening balance, and
- the date of the first deposit.
- Confirm the fund will lodge future SMSF annual returns.
Tip: a ‘test’ transfer counts as a contribution
If you transfer money into the SMSF’s bank account before 30 June to test the account, the ATO will generally treat that amount as a contribution. That means the fund won’t meet the “no contributions” requirement for an RNN, and you’ll usually need to complete accounts, arrange an audit and lodge an SMSF annual return for that year.
Learn more about what is considered a contribution to super.
Cancel your SMSF’s ABN if you’re not proceeding
If you’re not planning to place any assets into your SMSF in the near future, cancelling the fund’s ABN can be the simplest option. If you decide to proceed later, the fund can be re-registered at that time.
