Super contributions “work test” and COVID-19 disaster payments: APRA view

APRA has published new frequently asked questions (FAQ) on the interaction between COVID-19 disaster payments and satisfying the “work test” for the purposes of personal superannuation contributions.

APRA FAQ No 15 warns superannuation trustees not to assume members aged 67 to 74 in receipt of the Pandemic Leave Disaster Payment or COVID-19 Disaster Payment are automatically “gainfully employed” for the purposes of the contributions work test in reg 7.04 of the SIS Regulations.

According to APRA, an individual receiving the Pandemic Leave Disaster Payment cannot count the 14 days in which they receive the payment towards the work test “gainfully employed” period due to the fact that the individual must not be working to be eligible for the payment. While the COVID-19 Disaster Payment could potentially supplement a person’s wages where they are working reduced hours, APRA believes that the payment is a personal income supplement (or replacement) rather than an employer-based wage subsidy (such as the former JobKeeper payment).