“Retirees may have very valid reasons for taking the permitted minimum over extended years and should not be badgered by the government, regulators, trustees and others into thinking they are doing something wrong,” it read.

“A feature of the Retirement Income Covenant is that it allows trustees to determine in their retirement income stream what level of servicing is in their members’ best financial interests.”

The submission warned against mandating financial advice provision, and said trustees should decide what is appropriate for their members.

“Engagement metrics should be meaningful and voluntary, tailored to fund demographics. Member outcome metrics such as drawdown behaviour and product take-up are supported, but must be contextualised by age, balance, and member choice.”

“The right to take lump sums is emphasised, and success should be measured by member autonomy and financial security, not product proliferation.”

It added that the government may need to provide significant additional assistance to retirees if it would prefer a different retirement income product than account-based pensions to be the default option.

Furthermore, it added that any draw-down offerings different to government selected defaults should only be offered after a person has received personal advice from a financial adviser.

“We do not support the idea of government funded free and impartial guidance for retirees or people approaching retirement,” the submission read.

“The retirement puzzle for individuals is incredibly complex and involves much more than providing a person’s income needs, and is much more complex than this consultation paper assumes. Many of the issues that retirees must consider are interlinked.”