Key deadlines for complaints

Making a complaint to the Australian Financial Complaints Authority (AFCA) is a free way to get your money back from a financial business that broke the law. Most people who invested in the Shield or First Guardian Master Funds dealt with a financial adviser or a super fund (or both). If your financial adviser or super fund did something wrong, you can complain to AFCA and ask for them to pay you back. But, there are deadlines to make complaints that you don’t want to miss. You should make a complaint as soon as you can.

What are the deadlines?

Complaints about lost investment earnings

The new deadline to make a complaint to AFCA about lost investment earnings is 30 June 2027.

Lost investment earnings is the money you would have earnt on your super if you had kept your super in your old fund and not switched into Shield and First Guardian. You can ask AFCA to award you lost earnings on top of the amount you originally invested. If AFCA awards you money, but the financial firm doesn’t pay you, you can ask the Compensation Scheme of Last Resort (CSLR) to pay you instead (up to $150,000). 

The Government has announced that after 30 June 2027, you will still be able to ask the CSLR to pay you the money you originally invested, but you won’t be able to ask the CSLR to pay you the investment earnings you lost out on.

Example

Mary switched her super and invested $100,000 in First Guardian for one year. 

Before she switched, Mary was in a MySuper product. Her old MySuper product earned a net return of 8% per year over the one year Mary was invested in First Guardian. 

If Mary had stayed in her old fund, after one year, she would have had $108,000: the $100,000 she initially invested plus the $8,000 interest she would have earnt. 

Before 30 June 2027, Mary can make a complaint to AFCA about her financial adviser and she can ask for her initial investment back ($100,000) plus the investment earnings she would have made ($8,000). If the financial advice business doesn’t pay her, she can ask the CSLR to pay her $108,000.

After 30 June 2027, Mary can still make a complaint to AFCA asking for $108,000, but if the financial advice business doesn’t pay her, she can only ask the CSLR to pay her $100,000: the amount she originally invested. 

There may be other things that Mary can ask for. Find out more about making a complaint to AFCA and other money you can ask for.

On 19 August 2026, the Government announced that it will make changes to remove lost investment earnings from the money people can claim from the CSLR. The proposed changes will affect people who make complaints to AFCA after 30 June 2027. 

The changes require legislation to be passed in Parliament. Until that happens, we won’t know for sure exactly what the new rules will be. 

To make sure you don’t miss out, if you want to claim lost investment earnings from your financial adviser, you should make a complaint to AFCA by 30 June 2027.

We will update this page when we have more information about the Government’s plans.

Complaints about other losses

For complaints about other types of money from your financial adviser (e.g. money you invested or fees you paid), you should make your complaint before:

• 6 years from when you first became aware of the loss, or 
• 2 years after receiving a final response from the advice business if you complained to them directly first

whichever is earlier.

This is the normal deadline that applies to all financial advice complaints.

Are there other deadlines?

Not right now. All other deadlines are paused.

You can only make a complaint against a business that is a member of AFCA. All but one (Interprac) of the advice businesses who were involved in selling the Shield and First Guardian Master Funds have shut down. Usually, AFCA will cancel a business’ membership after a period of time from when it shuts down (often 1-2 years). If AFCA cancels a business’ membership, you will need to get your complaint to AFCA before the membership expires in order for AFCA to be able to deal with it. 

On 3 March 2026, AFCA announced that it will not be cancelling the membership of any financial advice business involved in selling Shield or First Guardian Master Funds in the near future. This means that the deadlines to make a complaint to AFCA have been paused to give people more time to make complaints. 

It is likely that AFCA will eventually cancel the membership of these businesses, so it is important that you make your complaint to AFCA as soon as you can.

Are the deadlines paused forever?

No. AFCA has said that it will consider whether to cancel the memberships of the advice businesses that have shut down at a later date. However, AFCA has also said that it will give people notice before making any more changes to complaint deadlines or cancelling the advice businesses’ memberships.

What if I miss the deadline?

If you miss the deadline, AFCA may not be able to award you the money you are asking for, so it’s important to get your complaint in before the deadline. If you’re not sure about a deadline, you should call AFCA at 1800 931 678. 

What about super funds?

All of the super funds are still in business, so the deadline is 2 years after receiving a final response from your super fund if you complained to them directly.