First, the associations believe the $1.6 million transfer balance cap applies retrospectively to transfers already made to pension accounts.

"If the transfer balance cap were to apply only to future retirees, savers can decide to change their retirement income strategy during their working life, working longer as necessary to ensure they have the standard of living in retirement they have anticipated," the associations stated.

"However, extending the cap to those who have already transferred all their savings into a pension account is retrospective in its impact."

Further, the associations believe the $500,000 cap on non-concessional contributions also has a retrospective effect.

"The new cap on on-concessional contributions should apply prospectively and not retrospectively back to 2007. In comments to a superannuation conference in Adelaide in February this year, the treasurer seemed to agree that retrospective changes to superannuation are unsettling and unfair," the associations stated.

In addition, the associations are requesting that upon retirement, individuals may make an additional non-concessional contribution above the $500,000 cap, provided their balance does not then exceed the transfer balance cap.

"There may be individuals who for whatever reason have been unable to make adequate concessional contributions but are prepared to top up their super using after tax funds (eg, from the sale of their house)," the associations stated.

"However, the new lifetime non-concessional contributions cap may restrict them from making their desired contribution even though this would not breach the overall balance transfer cap. This appears to be an unintended consequence and unfair on those who have been unable to make adequate concessional contributions."

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