Payday Super's First Quarter Closes: Why 28 October Still Matters

The line is 28 October

PCG 2026/1, the ATO's practical compliance guideline for the first year of Payday Super, covers every payday from 1 July 2026 to 30 June 2027. It does not change the law. It tells you where the ATO will spend its compliance effort, and it sorts employers by one test: whether each employee's final super guarantee shortfall is nil by the end of 28 days after the end of the quarter in which the qualifying earnings were paid.

For the July to September 2026 quarter, that is the end of Wednesday 28 October 2026. The guideline counts 28 days, not 28 business days. It is the same date the old quarterly super guarantee used, and the guideline's own examples describe quarterly payers as getting contributions to funds "by the end of the 28th day after the end of each quarter". The difference is that under Payday Super, meeting it no longer means you paid on time. It only decides how interested the ATO is in the fact that you did not.

How the 7 business day rule works, the four extensions, and what the rebuilt super guarantee charge costs are in our earlier post, Payday Super, one month in. This post is about the quarter-end check.

The three risk zones

Three details in the guideline change how you should read that table.

• Zones apply per payday, not per employer. You can be low risk for July and high risk for September. The ATO's Example 9 has an employer move from medium to low risk for paydays from 1 October 2026 after fixing its calculations and adding reconciliation checks.
• The low-risk zone is not an amnesty. The guideline states the Commissioner has no discretion over when Payday Super applies. If the ATO gets definitive information that you have a shortfall, it must apply the law, even for paydays in the low-risk zone.
• Late payment reduces the charge but never clears it. Contributions made before the ATO assesses you reduce the shortfall, but the charge includes notional earnings and an administrative uplift, so late contributions cannot bring it to nil.

Paying quarterly is not a safe harbour

Some employers read the 28-day test as permission to keep paying super once a quarter. The guideline closes that off. An employer who keeps paying by the quarterly due dates that applied before 1 July 2026 and makes no attempt to pay more regularly cannot be in the low-risk zone, and the ATO may investigate them.

Its worked examples show where that lands. Example 4 is a weekly payroll that kept paying super quarterly in full and on the old dates: medium risk. Example 5 is a fortnightly payroll paying quarterly where some contributions were rejected for data errors and not fixed by the 28th day: high risk. Example 6 is a monthly payroll paying quarterly that also treated some payments as not being qualifying earnings when they were: high risk.

So the 28 October test protects an employer who is paying each payday and has a few stragglers to fix. It does not protect one who has not changed anything since June.

What to reconcile before 28 October

The medium and high zones turn on one number per employee: the final shortfall. Getting it to nil means comparing what you owed against what the fund actually received, payday by payday, for every pay from 1 July to 30 September 2026.

1. Qualifying earnings for each payday. The super owed is 12% of qualifying earnings. A fortnightly pay of $2,000 in qualifying earnings needs $240 in the fund. Check that payments your system treats as non-qualifying really are, because the ATO's high-risk Example 6 is exactly that mistake.
2. Fund receipt, not your payment date. The ATO is explicit that a payment counts once your employee's fund receives it, not when you submit it. Match against clearing house or fund confirmations, not your bank statement.
3. Rejected and returned contributions. Funds must allocate a contribution or return it to you within 3 business days, and a rejection gives you no extension. Every returned amount from the quarter is an open shortfall until it is re-paid and received. The ATO's low-risk Example 2 covers the common cause: a successor fund transfer leaving you with old account details.
4. Partial payments. If you cannot clear the full amount, the ATO says a partial payment to the fund still reduces the charge you will be liable for. It will not keep you out of the high-risk zone, which needs the shortfall at nil.
5. High earners. Once an employee's qualifying earnings reach the maximum contribution base, $270,830 for 2026-27, no further super guarantee is needed for the rest of the year. Make sure payroll stopped at the base rather than before it.

To check the 12% figure on any single pay, the super guarantee calculator works it out from the earnings.

STP: the 1 July 2027 rejection rule

On 4 September 2026 the ATO published a myth-busting note on Payday Super. The item with a date attached: from 1 July 2027, if you do not report qualifying earnings and super liability, the ATO will reject your report and penalties may apply.

Both amounts are required now, for every payday from 1 July 2026, reported as year-to-date figures for each employee. The ATO's STP page sets out the transition:

• Until 30 June 2027 the ATO still accepts super liability and ordinary time earnings in pay events.
• Once you start reporting qualifying earnings, ordinary time earnings will no longer be accepted.
• If you have not started, begin as soon as possible, and report the correct year-to-date figure in the first lodgment. You do not need to request a deferral if you can start during 2026-27.
• Not reporting these amounts during 2026-27 increases your risk of compliance action.

The ATO also warns against over-reporting. Amounts that are not qualifying earnings, such as fringe benefits and expense reimbursements, should stay out of that field, or your STP data will not match the contributions the funds report and the ATO may contact you unnecessarily. The ATO also points out that leaving the amounts out of STP does not remove your super obligations. How pay events, finalisation and corrections work is covered in Single Touch Payroll.

What has not changed

• The rate. The super guarantee is 12% of qualifying earnings for 2026-27.
• Who you pay for. The ATO's words: Payday Super changes how often you pay super, not who you pay it for. That still means most full-time, part-time and casual employees, employees aged 18 and over, employees under 18 working more than 30 hours a week, and independent contractors paid mostly for their labour.
• STP timing. STP reports must still be lodged on or before each payday.
• 28 October on the business calendar. It is still the quarter 1 activity statement date for lodgment and payment. What is gone is the super entry: the ATO's October key dates page lists no super guarantee payment. The rest of the quarterly ladder is in BAS due dates.

Frequently asked questions

Sources

ATO pages fetched 25 September 2026. Every date, rule and quoted condition on this page traces to one of them.

• PCG 2026/1 Payday Super: first year ATO compliance approach (issued 28 January 2026). The three risk zones, the 28-day test, the quarterly payer rule and the worked examples.
• Busting Payday Super myths (QC108000, published 4 September 2026). Receipt by the fund, the 3 business day allocation rule, no extension for rejected payments, and the 1 July 2027 STP rejection.
• Single Touch Payroll reporting under Payday Super (QC107592, published 27 June 2026). Year-to-date qualifying earnings and super liability, the OTE transition, and the $270,830 maximum contribution base.
• Due dates by month: October (QC32007, last updated 23 July 2026). The 28 October quarter 1 activity statement date, with no super guarantee entry.

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