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Early Release of Super for Dental Treatment: The Rules Dental Practices Must Follow

IntelliDent Super Admin 6 min read
Superannuation Compliance Ahpra Dental Costs ATO
Early Release of Super for Dental Treatment: The Rules Dental Practices Must Follow

More Australians are using their superannuation to pay for dental treatment, and regulators have noticed. Applications for compassionate release of superannuation (CRS) have grown sharply in recent years, driven largely by dental treatment. In response, Ahpra and the Dental and Medical Boards of Australia issued guidance for practitioners in October 2025, and Ahpra and the Australian Taxation Office (ATO) have publicly warned patients about questionable "use your super for dental" offers.

If your practice ever certifies treatment for early release of super, or patients ask about it, this guide explains the rules, the risks and how to handle it properly.

This article is general information, not legal or financial advice. Read the current ATO requirements and the guidance from Ahpra and the Dental Board of Australia, and speak to your indemnity insurer.

Key takeaways

  • Compassionate release of super lets people access their super early for certain expenses, including some dental treatment, if strict conditions are met.
  • For dental treatment, the ATO requires certification from two dental practitioners, or a medical practitioner and a dental practitioner.
  • Treatment must be needed to treat a life-threatening illness or injury, alleviate acute or chronic pain, or alleviate acute or chronic mental illness.
  • In 2024–25, around 93,500 applications were made in this category, mostly for dental services, and about 30% were rejected for not meeting requirements.
  • Ahpra has warned practitioners that treatment should only be certified if it's necessary, advice must be in the patient's best interests, and encouraging patients to access super could be treated as unlicensed financial advice.

What is compassionate release of super?

Superannuation is generally preserved until retirement. Compassionate release is a limited exception that allows people to access some of their super early for specific expenses, including certain medical and dental treatment, when they can't meet the cost any other way. The ATO says it should only be considered as a last resort, once other options for paying have been exhausted.

The requirements for dental treatment

According to the ATO, applications for dental treatment need written reports from two practitioners:

  • two separate dental practitioners, or
  • a medical practitioner and a dental practitioner.

The reports must state that the treatment is necessary to:

  • treat a life-threatening illness or injury, or
  • alleviate acute or chronic pain, or
  • alleviate acute or chronic mental illness.

The treatment must not be readily available through the public health system. The ATO doesn't accept reports from allied health professionals. Check the ATO's current forms and guidance for the full requirements.

Why regulators are concerned

The ATO and Ahpra have reported:

  • Rapid growth in applications, with dental requests more than doubling in two years
  • Inaccurate statements in practitioners' reports
  • Some practitioners and third parties promoting early access to super to fund treatment, including cosmetic work
  • Cases where patients were pressured into treatment they didn't need, or into using super when other options were available

Accessing super early can significantly reduce a person's retirement savings, because the money withdrawn also loses years of investment growth.

What Ahpra and the Dental Board expect

The October 2025 guidance from Ahpra and the Dental and Medical Boards, building on a joint statement in May 2025, emphasises that:

  • Treatment should only be certified if it's necessary.
  • Advice must be based on the patient's best interests, not influenced by financial gain or incentives.
  • Certification needs a thorough assessment by an appropriately skilled practitioner.
  • Reports must be accurate and reflect the patient's actual condition and treatment needs.
  • Influencing patients to access super without an Australian financial services licence could be considered financial advice and attract penalties from ASIC.

Ahpra has said practitioners are on notice that it will take action to protect the public.

How practices should handle it

Don't promote it

Avoid marketing early release of super as a way to pay for treatment, on your website, social media, in ads or in conversations. Advertising rules also apply. See Ahpra advertising rules and cosmetic dentistry advertising.

Don't use third-party "super access" services that pressure patients

Be cautious about arrangements with companies that help patients access super for treatment, particularly where they're paid by the practice or the amount withdrawn.

Let patients raise it

If a patient asks about using super, explain that it's an option with strict ATO conditions, that it can affect their retirement savings, and that they should consider other options and get independent financial advice.

Assess and certify carefully

If you're asked to provide a report, base it on a thorough clinical assessment, describe the condition and treatment accurately, and only certify treatment that meets the criteria. Keep detailed records.

Discuss alternatives

Explore other ways to manage costs: staging treatment where clinically appropriate, health fund benefits, public dental services and payment plans, explained accurately and without pressure. See what Australians pay for dental care.

Train your team

Front desk staff should never suggest super as a way to pay, and should pass questions to the treating dentist or practice manager. Make sure any AI receptionist or chatbot follows the same rule.

Frequently asked questions

Can patients use super to pay for dental treatment?

In limited circumstances, if the ATO's compassionate release requirements are met, including certification by two practitioners that the treatment is necessary for specified reasons.

Can super be used for cosmetic dental treatment?

Treatment must meet the ATO's criteria. Regulators have specifically raised concerns about super being used for cosmetic procedures.

Can a dentist recommend that a patient use their super?

Encouraging patients to access super could be treated as financial advice requiring a licence. Dentists should focus on clinical needs and refer patients to independent financial advice.

Next steps

Review your practice's materials and scripts to make sure nothing promotes early access to super, and make sure your team knows how to respond to patient questions. For help answering cost questions consistently, book a demo of IntelliDent.