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30 Aug 2026

Shares or property in an SMSF: the paperwork, side by side

By SMSF Core · 6 min read
Clay render on navy: a neat stack of paper statements and a price tag on the left, a miniature house with a lease, clipboard and folder on the right.

Every comparison of shares and property in an SMSF you have ever read argues about which one performs. This article does not. Which asset suits your fund is a question for you and, if you use one, your licensed adviser. What we can compare, line by line from the ATO's published rules, is the other half of the decision that almost nobody writes about: what each asset asks of you as a record keeper. The two paper trails are genuinely different, and knowing the difference before you hold the asset is cheaper than discovering it in June.

First, the lie of the land. The ATO's March 2026 quarterly statistical report puts total SMSF assets at an estimated $1,057.6 billion. Of that, listed shares are the largest single slice at $273.3 billion, about 26%. Non-residential real property holds $120.1 billion and residential real property $62.7 billion, together about 17%, with a further $80.4 billion sitting in limited recourse borrowing arrangements, the structure most property purchases inside super use. Cash and term deposits hold $165.9 billion, about 16%. Both asset types are mainstream; hundreds of thousands of funds run each paper trail every year. Those are the ATO's numbers, read on 30 August 2026, and they describe what funds hold, not what any fund ought to hold.

The rule both assets share

Everything below hangs off one obligation. The ATO's valuation guide requires every fund asset to be recorded at market value, every year, for the fund's accounts and statements. The difference between shares and property is not whether you value them. It is how much work the valuation takes and how much paper it generates.

Shares: many small documents, one easy valuation

A parcel of listed shares is the easiest asset in the fund to value and one of the busiest to document.

The valuation itself takes a minute. The ATO's guide says listed securities are valued at their closing price on 30 June. The price is public, objective and free. No appraiser, no comparable sales, no judgement call. Your auditor can verify it as fast as you can look it up.

The documents are where the volume lives. Each holding produces a contract note when you buy and another when you sell. Each dividend arrives with a statement carrying the franked amount, the franking credit and the payment date, and a fund holding a dozen dividend payers collects several dozen of these a year. Dividend reinvestment plans add a new parcel with its own cost base at every payment. And because franking credits attach to parcels, not to the holding as a whole, the 45 day holding rule means your records need to show when each parcel was acquired and disposed of, at the parcel level, not just the ticker level. None of these documents is hard to obtain. The work is keeping all of them, matched to the right holding and the right year, until the return and the audit need them.

So the share paper trail is wide and shallow: many routine documents, each simple, arriving all year at the registry's pace rather than yours.

Property: few documents, but heavier ones

A property produces far fewer pieces of paper in a year than a share portfolio. Almost every piece asks more of you.

Start with the valuation, because this is the sharpest contrast. There is no closing price for a house. The ATO's guide asks trustees to support the valuation with objective and supportable data, and it lists the kinds of evidence that qualify: recent comparable sales, an independent appraisal from a real estate agent, or an online property report that sets out the data it relied on. The guide is explicit that a single item of evidence is generally not sufficient on its own. An agent's one line letter saying what the property is worth, with nothing behind it, is the classic example of evidence that does not stand up. So where the share valuation is a lookup, the property valuation is a small evidence gathering exercise, repeated every year the fund holds the asset.

One clarification the guide makes that surprises many trustees: a qualified independent valuer is legally required only in one situation, the disposal of collectables and personal use assets to a related party. For ordinary real property the trustees may determine the value themselves, provided the evidence behind it is objective and supportable. The obligation is not to hire a professional. It is to hold a file that would satisfy one.

Then the running records. A tenanted property carries a lease, rent statements from the managing agent, insurance renewals, council rates, repair invoices, and the paperwork proving any dealing with related parties sits on arm's length terms. If the property was bought with borrowing, the limited recourse borrowing arrangement adds its own permanent layer: the bare trust deed, the loan documents and the repayment records. Fewer documents than a share portfolio, but each one is bespoke, and several of them exist nowhere else if you lose them.

So the property paper trail is narrow and deep: a handful of documents a year, several of them requiring judgement, evidence gathering or third parties to produce.

Where both trails end up

The destination is the same. The ATO's record keeping requirements apply identically to both: accounting records, statements and benefit payment documents kept a minimum of 5 years, and the fund's foundation documents, minutes, investment strategy and consents kept a minimum of 10. And both trails get read by the same person, your auditor, who under the valuation guide checks the evidence behind every asset value as part of the annual audit before your return is lodged.

The practical difference shows up in June. A share heavy fund's June problem is volume: reconciling a year of contract notes, dividend statements and reinvestment parcels against the registry. A property fund's June problem is evidence: assembling this year's comparable sales or appraisal, confirming the file supports the number in the accounts, and finding the rent statements the agent sent in September. Different work, same deadline.

The one-line version

Shares generate many simple documents and a valuation you can look up. Property generates few documents, several of them heavy, and a valuation you have to prove. Neither trail is better, and this article has no view on which asset belongs in your fund. But if you know which trail you are on, you can file as you go instead of reconstructing in June, and the annual valuation stops being a surprise and becomes a calendar entry.

Every figure above comes from the ATO pages and the March 2026 statistical report cited below, read on 30 August 2026. The rules change; the read date matters.

SMSF Core is record keeping software, not a licensed financial service. Nothing here is a statement about which assets suit any fund.

Sources

  • ATO, Guide to valuing SMSF assets (QC 26343, last updated 15 May 2026): assets at market value every year for accounts and statements; listed securities valued at their closing price on 30 June; real property supported by objective and supportable data such as comparable sales, an independent appraisal or an online report listing the data relied on, with a single item of evidence generally not sufficient on its own; a qualified independent valuer legally required only for collectables and personal use assets disposed of to a related party; the auditor checks valuation evidence as part of the annual audit (ato.gov.au, read 30 Aug 2026)
  • ATO, SMSF quarterly statistical report March 2026 (Table 2, data extracted 15 April 2026): listed shares $273.3 billion, cash and term deposits $165.9 billion, non-residential real property $120.1 billion, residential real property $62.7 billion, limited recourse borrowing arrangements $80.4 billion, total estimated assets $1,057.6 billion; highlights page (QC 107527) rounds listed shares to 26% and cash to 16% of total assets (data.gov.au and ato.gov.au, read 30 Aug 2026)
  • ATO, SMSF record-keeping requirements (QC 23333): accounting records, operating statements, annual returns and benefit payment documentation kept a minimum of 5 years; trust deed, minutes, investment strategy, trustee changes, consents and member reports kept a minimum of 10 years (ato.gov.au, read 29 Aug 2026)
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