In this episode of the BK Pod, the focus is on turning two major compliance pressures facing bookkeepers and BAS agents into practical, operational frameworks. First, the discussion centres on the Code of Professional Conduct—not as a theoretical obligation, but as something that must be actively evidenced within a practice. The key message is clear: it’s no longer enough to believe you’re compliant; you need systems, controls, and measurable indicators that prove it. By translating code obligations into day-to-day processes and then into KPIs, practitioners can monitor performance, identify risks early, and confidently stand behind the declarations they make to the regulator.

Alongside this, the episode highlights the approaching reality of Payday Super (PDS) and the significant operational pressure it places on employers and their advisors. With super guarantee needing to be paid within tight timeframes—aligned with payroll and received by funds within seven business days—there is very little margin for delay or error. The conversation emphasises that while legislative delays have compressed preparation time, the expectations on employers remain high, with increased ATO visibility and enforcement, including automatic SGC assessments where obligations are not met.

Key Takeaways

• Code compliance should be measurable, not just understood
• Converting obligations → controls → KPIs creates real evidence of compliance
• Strong systems (QMS) are essential for consistent, defensible work practices
• BAS Agents must be able to support their TPB declarations with proof
• Payday Super introduces tight 7-day processing timeframes with minimal tolerance for delays
• The ATO will have increased visibility, leading to more automatic SGC assessments
• Bookkeepers play a critical role in educating clients and refining payroll processes
• Preparation before key deadlines is essential—last-minute fixes won’t work in this environment

In this month’s BK Pod, we cover two key developments affecting the bookkeeping profession. First, we provide an update on the proposed Tranche 2 Anti-Money Laundering (AML) reforms and what they may mean for BAS agents and bookkeepers. A practical decision-tree approach is discussed to help practitioners determine whether their services may trigger a requirement to register with AUSTRAC. The discussion focuses on three potential “hotspots”: acting as a director or trustee for a client, providing a registered office or business address, or receiving, holding or controlling a client’s money as part of executing transactions. Importantly, it is clarified that simply preparing ABA payment files or having limited authority where the client still approves payments will not generally constitute control of client funds.

The episode also explores recent developments following the Tax Ombudsman’s report into ATO agent services. The report identified several areas where the ATO’s engagement with tax and BAS agents could be improved, particularly in relation to digital services, phone support and overall interaction with the agent community. In response, the ATO has acknowledged many of the concerns raised and committed to addressing the issues through a structured consultation process.

As part of this response, a new consultation forum known as the Tax Practitioners Implementation Consultation (TPIC) group has been established. The group brings together ATO representatives, professional associations and practitioners to work through the report’s recommendations and develop practical improvements. While meaningful reform will take time, the early meetings indicate a clear commitment to improving systems and strengthening the relationship between the ATO and the agent community.

Key Takeaways

• AML Tranche 2 reforms may require some BAS agents or bookkeepers to register with AUSTRAC, depending on the services they provide.
• Three key AML “hotspots” include acting as a director/trustee, providing a registered business address, or controlling client funds during transactions.
• Preparing ABA files or payment batches alone does not constitute control of client funds, meaning AUSTRAC registration is generally not required in those cases.
• The Tax Ombudsman’s report identified major issues in ATO agent services, particularly digital systems and phone support.
• The ATO has established the TPIC consultation group to work with industry bodies and agents to implement improvements and address the report’s recommendations.

The latest episode of the BK Pod is out now—bringing you practical insights and updates to support your practice as we move into 2026.

Kelvin Deer (ABN Director) steps through a suite of new and upcoming tools for BAS agents, including the BAS Agent Readiness Checklist, AML/CTF Kit, Supervision & Review Playbook, Breach Reporting Guide, and the soon-to-be-released Payday Super Kit.

Then Peter Thorp and Kerrie Jarius unpack the ATO’s recent changes to the General Interest Charge (GIC) remission process. They explain what’s new, how to lodge remission requests using the new form, and what bookkeepers can expect when dealing with debts under—and over—$2,500.

In this episode:

• Your 2026 Toolkit for AML, Payday Super, QMS, plus staff/contractor supervision, and the updated breach reporting rules
• How to use the new ATO remission form and where to lodge it
• Why small debt cases under $2,500 may now be faster and easier to resolve
• What the new written outcomes mean for you and your clients
• Which remission claims still rely on individual case officer discretion