Introduction

The second quarter super guarantee deadline for the 2025-26 financial year falls on 28 January 2026. For many businesses, this will feel like a routine compliance date. But this particular deadline carries greater significance than those that came before it.

From 1 July 2026, the way Australian employers pay superannuation will fundamentally change. Payday Super will replace the quarterly deadline payment cycle that has been in place for decades, requiring employers to pay super contributions at the same time as wages, with funds reaching employees’ accounts within seven business days. The upcoming Q2 deadline represents one of the last opportunities to ensure your current quarterly processes are operating smoothly before this more demanding regime takes effect.

The current superannuation contribution payment cycle

Superannuation guarantee contributions for the October to December 2025 quarter must be received by employees’ nominated super funds by 28 January 2026. It is worth emphasising that this is a receipt date, not a payment date. Employers need to allow sufficient time for contributions to be processed through their clearing house or payment system and reach the fund before the deadline.

The current super guarantee rate is 12% of an employee’s ordinary time earnings (OTE).

Consequences of missing the deadline

Missing the super guarantee deadline triggers a series of consequences that extend well beyond simply paying late. Employers who fail to make contributions on time become liable for the Super Guarantee Charge (SGC), which includes:

  • the original shortfall amount calculated on salary and wages (rather than the potentially lower OTE figure)
  • 10% interest per annum on the shortfall from the start of the quarter
  • $20 administrative fee for each employee affected.

Perhaps most significantly for business cash flow planning, late super contributions may also lose their tax deductibility. This means employers could effectively pay double: once in the form of the SGC, and again through the lost tax benefit that would otherwise have reduced the net cost of the contribution, not including the interest and penalties that apply.

Employers who miss the deadline must lodge a Superannuation Guarantee Charge statement with the ATO by 28 February 2026 for the Q2 period. Voluntary disclosure before the ATO identifies the shortfall may result in reduced penalties, but the underlying SGC liability remains.

Why this deadline matters more than usual

The Treasury Laws Amendment (Payday Superannuation) Act 2025 and the Superannuation Guarantee Charge Amendment Act 2025 received Royal Assent in late 2025, confirming that Payday Super will commence on 1 July 2026. This represents the most significant change to employer superannuation obligations since the introduction of the super guarantee itself.

Under the new rules, employers will need to pay super contributions at the same time as salary and wages, with contributions received by the employee’s fund within seven business days of each pay event. For a business that pays staff fortnightly, this means super contributions will need to be processed 26 times per year rather than four. Monthly payroll cycles will require 12 super payment runs instead of four.

The shift from quarterly to payday-aligned contributions will place new demands on payroll systems, cash flow management and administrative processes. Businesses that are currently struggling to meet quarterly deadlines will find the more frequent payment cycle significantly more challenging. Conversely, businesses that have established reliable quarterly processes have a solid foundation on which to build.

Key actions for employers now

With less than six months until Payday Super commences, now is the time for employers to begin preparing. The following areas warrant particular attention.

Review payroll systems and processes

Your payroll software will need to support real-time, or near-real-time, super payments aligned with each pay run. Speak with your payroll software provider about their readiness for Payday Super and when relevant system updates will be rolled out. Consider whether your current approval workflows and payment processes can accommodate more frequent super transactions without creating bottlenecks.

Select and test a new clearing house

The ATO’s Small Business Superannuation Clearing House (SBSCH) will close on 1 July 2026. Businesses currently using the SBSCH will need to transition to a commercial clearing house or payroll-integrated solution. The SBSCH stopped accepting new business registrations from 1 October 2025, and existing businesses should be researching alternatives now to allow time for testing and transition.

When evaluating clearing house options, consider whether the solution supports real-time payments through the New Payments Platform (NPP), which can help ensure contributions reach funds within the seven-day window. Also assess the provider’s capacity to handle the higher transaction volumes that will come with more frequent payments.

Understand the new qualifying earnings definition

Payday Super introduces a new term: qualifying earnings (QE). This replaces ordinary time earnings as the basis for calculating super guarantee contributions. Qualifying earnings generally include ordinary time earnings, salary sacrifice amounts that would otherwise count as qualifying earnings, commissions, and certain payments to contractors who are deemed employees for super purposes.

Employers should review their pay codes and payroll configurations to ensure all relevant payment types are correctly classified. This is also an opportune time to conduct an SG audit to confirm that super is being calculated on all applicable earnings under the current rules.

Consider cash flow implications

For businesses accustomed to quarterly super payments, this represents a significant change to cash flow timing. It is worth modelling the impact on your operating cash position and considering whether adjustments to working capital arrangements may be needed.

Under the current quarterly system, employers have up to 28 days after the end of each quarter to make super payments. This provides a cash flow buffer that many businesses factor into their working capital management. Payday Super will eliminate this buffer, requiring funds to be available for super contributions at the same time as each wage payment.

The ATO’s risk-based compliance approach

The ATO has released Draft Practical Compliance Guideline PCG 2025/D5, which outlines the compliance approach it intends to take during Payday Super’s first year of operation (1 July 2026 to 30 June 2027).

Under this risk-based approach, the ATO will differentiate between employers who are making genuine efforts to comply with the new requirements and those who are not. Employers categorised as low risk will generally be those who pay super on time for each pay event (or shortly thereafter), quickly identify and rectify any shortfalls, engage with the ATO constructively when issues arise, and can demonstrate they have taken reasonable steps to prepare their systems and processes for the transition.

High-risk employers, by contrast, are likely to be those with a history of late or non-payment, those who show no evidence of attempting to meet the new requirements, and those who fail to engage with the ATO when compliance issues are identified.

The message from this compliance approach is clear: employers who invest in preparation and demonstrate good faith efforts to comply will receive a more sympathetic response to any teething issues during the transition period. Those who ignore the changes or make no attempt to adapt will face the full weight of the new penalty regime.

Taking Action Now

The Q2 2025-26 super guarantee deadline on 28 January 2026 is an immediate compliance priority. Beyond that, it serves as a useful prompt to assess your organisation’s readiness for the changes ahead.

If your business experiences any difficulty meeting quarterly super deadlines, those challenges will be amplified under Payday Super. Now is the time to identify and address process weaknesses, upgrade systems where necessary, and establish the disciplines that will be essential from 1 July 2026 onwards.

Moore Australia’s team of payroll specialists and business advisors can assist with reviewing your current super compliance processes, identifying areas of risk, and developing a transition plan for Payday Super. Whether you need help understanding the new qualifying earnings definition, evaluating clearing house options, how to activate this within your current payroll software or conducting a broader payroll health check, we are here to support you through this period of regulatory change.

For further information

To discuss your super guarantee compliance or Payday Super preparation, please contact your local Moore Australia advisor today.