What the rules actually require
Regulation 8.02B of the SIS Regulations requires fund assets to be valued at market value when preparing accounts and statements. The ATO expects trustees to use objective and supportable data. The auditor, separately, must obtain sufficient appropriate evidence that the reported value is reasonable — and it is the auditor, not the trustee, who decides whether what they have been given is enough.
Note what the rule does not say: it does not mandate a full independent valuation by an external valuer every single year. It mandates market value supported by objective and supportable evidence, and s35B(2) of the SIS Act requires the accounts to reflect it. For a straightforward residential property an auditor may accept other evidence in some years; for commercial property, related-party arrangements or anything unusual, a current independent valuation is the only reliably safe position.
What is no longer safe is leaving a figure unchanged. In 2024 the ATO wrote to more than 16,500 SMSFs that had reported property at the same value for three or more consecutive years, and to the auditors of those funds. An unchanged value is now itself a flag, whether or not it happens to be correct.
Eight events that require a valuation
Some are annual; others are one-off events an auditor will look for specifically.
What makes an auditor qualify the report
These are the reasons we are asked to prepare a valuation after an audit has already begun — the expensive way to do it.
Audit red flags and their remedy
Getting the timing right
The effective date must be 30 June of the relevant financial year, and the valuation should be commissioned close to it rather than long afterwards. A report effective 30 June but prepared in September is entirely normal and acceptable; a report effective in March and used for the June accounts is not.
Practically: instruct in May or June, so inspection and the report both land inside a sensible window. We send the signed PDF to the trustee and, on request, directly to the accountant and the auditor, so the audit file is complete without anyone forwarding attachments.