Issued: 11 June 2025
Last modified: 11 July 2025
It’s important for new tax practitioners to understand their ongoing registration obligations. Join this webinar if you are a newly registered tax agent or BAS agent or are returning to the profession after a break and need a refresher.
Resources
Webinar recording
Questions and answers
We have compiled some of the questions we received during our webinar.
Professional indemnity (PI) insurance
I am a registered BAS agent employed by a company. Is the PI insurance the company has sufficient to cover me?
If you do not charge a fee or receive a reward (for example, you are an employee or contractor), you will not need to have your own PI insurance policy in order to meet our requirements. However, you will be required to provide us with the name of your employer or principal and their registration number.
For further information on our PI insurance requirements, refer to professional indemnity insurance for more information.
Do I need to provide a certificate of currency when filling out the PI insurance information on my registration form?
No, you do not need to provide a certificate of currency when filling out your registration form. However, you may be asked to provide further evidence of your PI insurance details which could include a certificate of currency.
Personal tax obligations
If I am on a payment arrangement with the Australian Taxation Office (ATO) for a personal liability, do I have to report that to the TPB?
Yes, when you have a payment arrangement in place with the ATO, you need to disclose this to us when you next lodge your application renewal form. This is to provide assurance to us that you are complying with your personal tax obligations.
Does meeting your personal tax obligations on time also include your business tax debts and lodgements i.e. trust, company or partnership?
Yes, the tax obligations of any associated entities that you have direct, or indirect, control over are included as your personal tax obligations. Learn more about complying with your personal tax obligations.
Continuing professional education (CPE)
Are CPE hours the same as CPD hours?
Yes, continuing professional education (CPE) and continuing professional development (CPD) are the same thing for our purposes.
Where can I find a logbook to record my CPE hours?
We have developed a CPE log which you can download to assist with your record keeping requirements.
What is structured and unstructured CPE?
Structured CPE includes formal activities, such as conferences, tertiary courses, webinars and structured training. These activities generally have a clear set of learning objectives.
Unstructured CPE activities include relevant technical or professional reading, self-paced audio, visual and computer aided instruction, or group discussions on technical topics.
Learn more about CPE activities.
Why is the CPE period 3 years, when my registration is for one year?
The 3-year CPE period allows for flexibility to complete your CPE requirements and manage any extenuating circumstances that could impact compliance with the requirements of registration. Learn more about extenuating circumstances by reading our CPE information.
What are the CPE requirements for one year of registration?
The amount of CPE hours within a 3-year period for a tax agent registration is 120 hours and 90 hours for BAS agent registration.
The minimum amount of CPE that must be completed in one year is 20 hours for both tax and BAS agents. Refer to continuing professional education for more information.
Does the CPE period start from the date of registration? Does the 20-hour rule run from the anniversary of that date?
Yes, your CPE period is 3-years beginning on the date you first register with us. The minimum amount of CPE required to be completed in one year is 20 hours from the anniversary of that date.
I have an individual registration and a company registration - can I use the same CPE hours for both registrations?
Our CPE requirements only apply to individual tax practitioners.
If I run a part-time business as a BAS agent, is there any way my CPE hours can be pro-rated?
Generally, there is no relief from CPE on the basis of part-time arrangements. Registered BAS agents that work part-time are still required to complete a minimum of 90 hours of CPE over a 3-year period. However, if you have extenuating circumstances, you can request some relief from the minimum level of CPE required.
For more information on extenuating circumstances, refer to our guidance, in particular paragraphs 59 to 62.
In relation to CPE, how many hours are allocated for personal research?
Under our CPE policy, no more than 25% of CPE activities may be undertaken through relevant technical or professional reading. You must also maintain a CPE log detailing the activities undertaken.
Does the 120 hours of CPE include reading tax journals?
Yes, tax journals would be included as relevant technical or professional reading as long as they are relevant to the tax agent services you provide. It’s also important to remember that this cannot make up more than 25% of the of the total amount of CPE completed. You must also maintain a CPE log detailing the activities undertaken.
Can a short course on using artificial intelligence (AI) for work count towards CPE?
A CPE activity needs to be relevant to the tax agent or BAS agent services you provide and help you maintain, develop or promote your skills, knowledge or attributes. So, if the AI course is relevant to the tax agent or BAS services you provide, it can count towards your CPE. You need to use your professional judgment about whether a particular course meets these requirements. Refer to CPE activities for more information.
My boss has registered me for an online course, can that count towards my CPE?
Yes, if the online course is relevant to the tax agent services you provide.
Am I able to claim CPE by watching a recording of a TPB webinar?
Yes, you can claim CPE by watching a recording of our webinars on our YouTube channel
How do I claim CPE for watching a recording of a webinar?
You should include sufficient details about the topics discussed in the webinar, when it was completed, and the relevance to the tax agent or BAS services you provide. You can use our CPE log to record the details.
Where can I find the details for CPE requirements or concessions for tax agents on maternity leave?
We appreciate there may be extenuating circumstances (such as maternity leave) where you are unable to complete the minimum level of CPE hours. In such circumstances, we will consider appropriate relief, provided you can demonstrate that you have attempted to use the flexibility of your CPE period to manage any extenuating circumstances to comply with our CPE requirements. You should make sure the circumstances are documented and you provide that information when you lodge your renewal registration form.
For more information on extenuating circumstances, refer to paragraphs 59 to 62 in our guidance.
Breach reporting
With the requirement to report a significant breach of the Code to the TPB within 30 days, when does the 30 days start?
You must notify us within 30 days of the day on which you first have, or ought to have, reasonable grounds to believe that a significant breach occurred. For additional information about the 30-day timeframe, refer to our guidance
If I self-assess the breach reporting obligation and get it wrong, what protections are in place if I acted in good faith and determined it was not a reportable breach?
If you decide in good faith not to report a breach based on your own assessment, we will take a pragmatic and balanced approach when deciding what compliance action to take (if any). If we are satisfied with the explanation for not reporting, our response is likely to be a measured and educative one, with the aim of assisting you to better understand your breach reporting obligations. In these cases, it is unlikely a sanction will be applied, although this will ultimately depend on the circumstances. It is also important to have documented the decision and the reasons for not reporting a potential breach at the time.
Proof of identity (POI) and client verification
As a tax agent, do I have to complete an ID check on all new clients and how do I record the verification?
You must undertake POI before providing tax agent or BAS services to new clients and on an ongoing basis to existing clients, as appropriate.
We do not require you to keep copies or originals of IDs you used to identify a client or their representative. However, you should maintain a record, such as a checklist, with sufficient details as soon as POI checks are undertaken. Records should contain the date and time when the POI checks were done, types of IDs used, how the documents were sighted and who in the practice performed the checks including their position.
The records must also include confirmation that the IDs were clear and legible, identified the client and their representative (if any) and there was no apparent reason to question the IDs provided.
These records must be kept for up to at least 5 years after the engagement with your client ceases.
See our practice note for more information.
Do I still need to complete POI checks for long term clients?
Yes, we expect you to undertake POI checks for your existing clients throughout your engagement with them.
For long term clients, there are a range of factors to consider on whether a POI check is required. These include the extent of your relationship with the client, if any change of contact or bank account details have occurred, and if there has been any change in the relationship with the client.
If you make an assessment not to undertake POI for an existing client at that point in time, you must keep a record of the factors you considered to make the decision.
We do individual tax returns over the phone, not face-to-face. How do we verify clients' ID without seeing clients?
If you are engaging with clients remotely, you can use a webcam or videoconferencing tool to sight IDs, making sure to record a note that the identity check has been completed.
If you use solely non-visual methods to engage with clients (such as the phone) and are unable to verify and compare the client’s identity with the certified copies of identification documents that have been provided, you should refer to the ATO’s agent client verification methods.
Many of our clients live remotely and correspond with us only via email. How can I meet the proof of identity requirements?
If you engage with a client and/or their individual representative through non-visual electronic communication (for example, using teleconferencing or email only) and are unable to verify and compare the client’s identity with the certified copies of identification documents that have been provided, you should refer to the ATO’s agent client verification methods.
Additionally, we do not recommend receiving identification documents by email as this is not considered to be a secure method of transmission. We strongly recommend that you arrange any information or copies of documents provided by the client:
- via a secure website, secure online mailbox or secure messaging
- as an encrypted or password protected attachment to an email
- using another secure electronic solution that minimises the risk of interception of the sensitive information.
If you intend to receive sensitive information or copies of identity documentation electronically, we recommend that you seek independent professional advice from an information and communication technology security provider about what controls are appropriate for your business and risk circumstances.
Compliance
Would sharing an open-plan office with another firm breach the Code of Professional Conduct (Code) item 6?
No, it would not be a breach of Code item 6 as long as you have appropriate systems in place to protect client information. This would include securely storing client records, having separate IT systems in place and ensuring staff were trained on their responsibilities under the Code.
What steps can we take to ensure our clients are providing us with accurate financial information?
If you have reason to believe a client is not providing you with accurate financial information, you should take reasonable steps to ensure the information is correct. You can do this by:
- asking additional probing questions
- seeking additional documentation or evidence
- taking steps to independently verify the information provided (if possible).
When faced with reckless or unreasonable tax claims, ethical tax practitioners will decline to act in order to preserve their credibility and compliance.
Is there a list of non-complying tax practitioners so we can check before we employ someone?
Our TPB Register contains details of registered tax and BAS agents, as well as certain unregistered entities and individuals. It also includes any breaches of the Code and sanctions imposed that are on the public record.
Registration
Are registration renewals every 3 years?
From 1 July 2024, the registration period for tax practitioners changed from once every 3 years to once a year. The new annual registration period applies from your next renewal date that occurs from 1 July 2024.
Will I be notified when it is time to renew my annual registration?
Yes, as long as your contact details are up to date with us, you will receive email and text message reminders when your registration is due.
To check if your contact details are up to date, please log into My Profile.
If I move overseas and work remotely, can I maintain my tax agent registration?
Yes, provided you continue to meet the requirements for registration. Refer to maintain your registration for more information.