“This was a practical reform, simplifying the regulatory environment for financial advisers. What has been largely overlooked, is the review’s recommendation 7.211 which stated: ‘having recommended the regulatory burden on tax (financial) advisers is to be reduced, the review believes it is reasonable that a similar level playing field should be considered for accountants’,” the submission read.

“The review therefore recommends the government initiate a specific review of what advice accountants can and cannot give in respect of superannuation and which accountants that might apply to.”

The association said a review could be undertaken by the Productivity Commission.

“Recommendation 7.2 was referenced in the Quality of Advice Review but was largely ignored. This was in part due to the significant size of the review and complexity across a range of issues included in the terms of reference,” it said.

“For accountants, this outcome was disappointing, as the terms of reference noted that the James Review recommendation was a relevant recommendation for consideration. The initial issues paper laid the foundation for a review of the current legislative framework, providing essential scene setting with key background information, including the link to James Review.”

It continued that in the final report, issues for accountants were not adequately addressed, the report noting that many of the issues were outside of the terms of reference.

It said the report also acknowledged the review was “not unsympathetic to the concerns raised about the costs associated with providing this advice” and that “there does not appear to be much merit in holding a limited AFS licence”.

“Advice in relation to SMSFs is not only about establishing an SMSF, it is being able to advise a client not to establish one or when to exit where an SMSF is not appropriate. These types of advice all constitute financial product advice. An SMSF is not suitable for everyone, and we have a severe advice gap in the market,” the submission read.

“Financial advisers are reporting that they are at capacity, and accountants are reporting that clients who urgently need financial advice are unable to access that advice.”

Furthermore, the submission said the proposals for tranche two of the QAR reforms would see the introduction of a new class of advisers for large APRA superannuation funds.

“Their stated role is to address the advice gap for the many unadvised Australians. We support these reforms in principle, and they are urgently needed. However, this is creating a significant gap for middle Australians who have sought to take control of their financial wellbeing,” it added.

“Critically, we do not support the return of the former accountants’ exemption. What we do support is legislative certainty on what is defined as a tax agent service, and exploring the role accountants can play regarding financial literacy, education, and nudges.”

The SMSFA said it seeks to consult on an appropriate framework, for suitably qualified SMSF professionals to be able to provide limited, prescribed services to advise, assist, and educate current and future SMSF trustees.

“Any model must be consumer-centric and contain appropriate consumer protections.”