Can a Virtual Address Be Used by an SMSF Corporate Trustee?Blog

October 17, 2026
5 min read

Yes, if the address is a physical Australian street address and the occupier has given written consent. A corporate trustee is a company, so the Corporations Act 2001 applies to it. It needs a registered office [Corporations Act 2001, s142], documents can be served there [Corporations Act 2001, s109X], and it pays ASIC's annual review fee.

The Registered Office Rules

Under section 142, every company must have a registered office [Corporations Act 2001, s142]. ASIC does not accept a PO Box as a registered office. Under section 109X, a document may be served on the company by leaving it at, or posting it to, the registered office [Corporations Act 2001, s109X].

Occupier Consent

If the company does not occupy the premises, the occupier must consent in writing to the company using them as its registered office [Corporations Act 2001, s143]. Space Penguin provides a signed occupier consent letter to customers registering a company at its address [Space Penguin, spacepenguin.io].

The Special Purpose Annual Review Fee

As at September 2026, ASIC's annual review fee for 2026-27 is $342 for a proprietary company and $70 for a special purpose company.

ASIC's fee rules define a special purpose superannuation trustee company in two parts. Its constitution must prohibit distributing income or property to members. Its sole purpose must be to act as trustee of a regulated superannuation fund.

The company must tell ASIC it is a special purpose company. This can be done by ticking the box when registering, or later by lodging Form 484 with an officeholder declaration. ASIC charges no fee for the change, and it should be made before the next annual review date so the right fee is charged.

When the Fee Is Due

ASIC sends the annual statement to one address only. It uses the registered agent address first, then the company's online account, then a nominated mailing address, then the registered office. The fee is usually due two months after the annual review date.

As at September 2026, a late payment fee of $102 applies if payment arrives within one month after the due date, and $428 if it arrives later. In some cases ASIC may consider deregistering a company that has not paid.

Principal Place of Business and Officeholder Addresses

ASIC's register also records a company's principal place of business. As at September 2026, a change to the registered office or the principal place of business is lodged on Form 484 within 28 days, or a late fee applies. Both addresses appear on the public register. A home address entered in either field becomes public.

A virtual address covers those two fields. Officeholders' residential addresses are separate. Companies must give ASIC each officeholder's residential address, and it is held on the register. Since 2 February 2026, ASIC no longer shows those addresses in company extracts on its website, but they may appear in other documents the public can purchase. An officeholder can ask ASIC to hide a residential address if their or their family's safety would be at risk, and must then give an alternative address.

Individual Trustees vs Corporate Trustee

Feature

Individual trustees

Corporate trustee

Trustee is Individual members A company
Registered office required No, section 142 applies to companies [Corporations Act 2001, s142] Yes [Corporations Act 2001, s142]
ASIC annual review fee (2026-27) None $70 if special purpose status is notified to ASIC, otherwise $342

 

See AUSTRAC and Virtual Addresses: What the 2026 Rules Mean for Your Business for how the 2026 AUSTRAC rules apply to address providers. Space Penguin offers virtual addresses at 530 Little Collins St, Melbourne and 89–97 Jones St, Ultimo. See the virtual address plans.

Frequently asked questions

Does a bare trust company qualify for the $70 special purpose fee?

Possibly not. ASIC's definition requires the company's sole purpose to be acting as trustee of a regulated superannuation fund. A company that acts only as a bare trustee for a borrowing arrangement may fall outside that wording. Confirm the fee category with ASIC before relying on the $70 rate.

How do I tell ASIC my trustee company is a special purpose company?

Tick the special purpose box when registering the company. For an existing company, lodge Form 484 in the company officeholder portal, select the change to special purpose status, choose superannuation trustee and submit the officeholder declaration. There is no fee. Do this before the next annual review date.

What happens if I miss the annual review fee?

The fee is usually due two months after the review date. As at September 2026, a late payment fee of $102 applies within one month after the due date and $428 after that. In some cases ASIC may consider deregistering the company.

Do individual SMSF trustees need a registered office?

No. Section 142 applies to companies, and individual trustees are not companies [Corporations Act 2001, s142].

Related reading

About the author: Alisha Aneja is a co-founder of Space Penguin and leads technology and product. She writes about company setup, registration and compliance for Australian founders.

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