The Tax Practitioners Board (TPB) Consultation and Standards Forum (CSF) is a new Forum, replacing the TPB’s two previous formal consultation mechanisms – the Tax Practitioner Governance and Standards Forum and the Consultative Forum. 

Key messages - 26 August 2025

The CSF is the primary stewardship group operated by the TPB and co-chaired by a representative from a professional association and facilitates strong engagement and collaboration between the TPB and key stakeholders, including partner government agencies, professional associations, educators and community representatives.

The CSF provides an opportunity for key stakeholders to discuss strategic and systemic matters that will improve the administration and operation of regulatory framework impacting on the tax profession. 

This engagement is intended to bring focus to the CSF to work collaboratively to identify strategic opportunities and risks, which will inform each respective organisation’s strategic planning, prioritisation of key areas of focus and coordination of treatment strategies. 

The members discussed a draft Charter which details how the CSF will operate, including the role, purpose and responsibilities of the CSF. Once finalised, this CSF Charter will be published on the TPB website.  

Environmental scan

Members discussed insights as to what they are observing in the broader environment and identified key risks and emerging issues impacting the tax profession. These included:  

  • evolving practices challenging traditional business models
  • increasing adoption of services offered by digital service providers and artificial intelligence
  • the impact of competing demands on tax practitioners, including ongoing and wider reforms impacting the tax profession
  • tax practitioner demographics and changing taxpayer needs.

Reform measures

The TPB provided an update on the status of reforms that had been implemented since 2024.

Disqualified entities

  • As at August 2025, the TPB has received 37 applications from tax practitioners seeking approval to engage a disqualified entity. While a number of applications are currently under consideration, the TPB has approved 7 applications and rejected 4 applications and 14 applications were invalid.
  • For those approved applications, the TPB considered the circumstances giving rise to being a disqualified entity (for example, circumstances beyond the disqualified entity’s control or not related to the provision of tax agent services).
  • For those rejected applications, the TPB considered, for example, the nature of the previous conduct of the disqualified entity that led to the applicant having their TPB registration removed, lack of evidence to support ongoing development.
  • Applications were invalid for a number of reasons, and included the relevant individual not meeting the definition if a disqualified entity or insufficient supporting documentation being provided.
  • Recognising member feedback, the TPB confirmed that it will update its guidance to include case studies to support tax practitioner understanding. 

Breach reporting

  • As at August 2025, the TPB has received 111 breach reports from registered tax practitioners indicating they were reporting a significant breach of the Code of Professional Conduct (Code). Of the breach reports received, 86 were reports against another registered agent and 25 were self-reported breaches.
  • While a number of matters are under initial review, the TPB has escalated 32 matters for further review, 44 matters resulted in no further action and 2 matters resulted in an educative outcome.
  • The primary breaches being reported about other practitioners predominately relate to Code 1 (honesty and integrity), Code 5 (manage conflicts of interest) and Code 7 (competence) issues.
  • Self-reports indicate Code 1 breaches, usually arising due to actions undertaken by staff in their firm. Agents are also advising of Code 2 where their personal tax obligations are not up to date and breaches of Code 6 (confidentiality), due to inadvertent sharing of personal data of their client’s information.
  • CSF members raised concerns about whether guidance products appropriately cover the requirements to make a significant breach report and expressed the need for clarification.
  • Noting member feedback, the TPB confirmed that it will update its guidance to provide clarification around the concerns raised and include case studies.

Code Determination

  • The finalisation of the Code Determination in late 2024, introduced 8 additional Code obligations that supplement the existing obligations under the Code.
  • Due to a staggered commencement date of the Determination, 1 January 2025 for larger firms and 1 July 2025 for smaller firms, the TPB advised that there is currently limited compliance activity, with the TPB’s focus being to educate and assist tax practitioners to understand these new obligations.
  • The TPB advised that they are seeing improvements in how tax practices are operating – key changes are being made in response to the new quality management system requirements and the requirement to keep clients informed. 

Annual registrations

  • From 1 July 2024 the registration period for tax practitioners moved to an annual cycle (from a 3-year period). This change applies to both new and renewal applications submitted from 1 July 2024.
  • The TPB noted that the transition to annual registration has generally been seamless, with CSF members also noting that the registration process is a relatively simple process that works well. 

Whistleblower protections

  • Since 1 July 2024, the TPB has been able to receive disclosures of information from eligible whistleblowers. This means, individuals who disclose information to the TPB about a related entity, where it assists the TPB to perform our functions or duties under the TASA, will qualify for whistleblower protection.
  • In the first 12 months of the new whistleblower protections commencing, the TPB has received approximately 11,000 complaints. However, only a small portion of these complaints are from eligible whistleblowers (approximately 10% of all complaints).
  • Members raised inconsistencies in how whistleblower protections operate when the matters involve an unrelated third party. Treasury noted this concern and noted that a wider review of the tax and corporate whistleblower laws is currently underway. The review will seek public submissions in due course.

Other comments 

External members noted their queries regarding existing TPB guidance, particularly in relation to the Code Determination (false or misleading statements, breach reporting and managing conflicts of interest). Given the strategic focus of the CSF, members agreed that a smaller working group will be convened to discuss ways to improve guidance. 

Treasury update

Treasury provided members with an update on reform measures that have been announced by government, will be subject to consultation or have been subject to a consultation process. Reform measure updates included: 

  • Enhancing the TPB’s sanctions regime
  • TPB registration requirements review
  • Tax promoter penalties law review
  • Tax regulator secrecy laws review
  • Prescribed disciplinary bodies
  • Tackling fraud against the ATO and the tax and superannuation systems
  • Legal professional privilege in Commonwealth investigations
  • ATO and TPB investigations and information gathering powers review.

Members indicated the importance of Treasury engaging with members early to allow for meaningful contribution to the development of policy and design of enabling legislation.

Policy guidance matters

The members discussed a proposal by the TPB to enhance its policy guidance for tax practitioners. Members provided their support to: 

  • reduce the TPB’s 9 categories of information products into just 2 formal categories consisting of information sheets (which the category name to be reviewed) and legislative instruments
  • on a go forward basis, create new consultations webpage on the TPB’s website to publish submissions made, provides a high level summary of submissions received and actions taken in response to submissions. 

Members also provided their general support for the TPB’s proposed 2025-26 policy work program, which included guidance on the use of artificial intelligence by tax practitioners and ensuring that all TPB policy guidance products are accompanied with smaller ‘bite-sized’ guidance, such as a short factsheet, to assist tax practitioner understanding of the TPB and/or legislative requirements. 

Areas of focus, key strategies and priorities

Members discussed key areas of focus and priorities for 2025-26. The following key matters were identified:

Tax Practitioners Board 

The TPB’s strategic priorities and areas of focus for 2025-26 included:

  1. Delivering a proportionate, fair and data-driven risk based compliance program

    As part of this focus areas, the TPB noted its enduring compliance priorities include fraud, professional standards, integrity, leadership, culture, governance and unregistered advisers.

    Further, the TPB noted that its 2025-26 compliance priorities included the conduct of tax practitioners in relation to:

    1. facilitation of tax debt defaults
    2. multinational compliance
    3. secrecy haven schemes to conceal income/ assets
    4. tax avoidance schemes including income alienation or R&D arrangements
    5. shadow economy deception
    6. phoenix schemes undermining employee entitlements/ creditors rights
    7. individual tax compliance including overclaiming of work-related expenses
    8. schemes impacting vulnerable Australians, including inappropriately encouraging illegal early release of super and tax time loan products
    9. compliance with their own personal taxation obligations.

  2. Supporting tax practitioners and the public

    The TPB’s focus is to:

    • enhance the TPB’s engagement with key stakeholders, recognising that the TPB and co-regulatory partners are best able to support the profession and public through close collaboration and cooperation
    • review the TPB’s communications strategy to ensure that the TPB is best placed to support the public and tax practitioners
    • re-prioritise the TPB’s policy guidance work program
    • continue to engage with all stakeholders in develop guidance on the operation of any new laws.
    • create an environment of trust and transparency between the TPB and tax practitioners.

  3. Contributing to and informing the tax and regulatory system

    The TPB’s focus is to:

    • continue its commitment to supporting Government priorities, including reforms to enhance tax system and profession integrity and increasing productivity
    • work with our Government partners to design and implement changes with a Whole of Government understanding. 

  4. Enhancing capabilities

    The TPB’s focus is to: 

    • ensure that the TPB continues to modernise our internal and external application systems
    • use data driven risk engines and measurement tools to identify systemic risk and measure effectiveness
    • ensure a robust approach to data governance to promote high standards of data quality, security, privacy and ethics
    • support the wellbeing, engagement and growth of staff.

Australian Taxation Office 

The Australian Taxation Office (ATO) provided information regarding the following enterprise priorities, organisational capabilities and key activities:

  1. Key activities
    • Collect the right amount of tax in the most efficient way for government and the taxpayer.
    • Deliver fair, secure and transparent taxpayer interactions to make it easy to comply and hard not to.
    • Manage our responsibilities in the superannuation system to support the future retirement savings of the community.
    • Administer a range of payments and transfers on behalf of government.
  2. Enterprise priorities
    • Strengthening payment performance and debt collection
    • Enhancing counter fraud measures
    • Establishing Payday Super
    • Implementing a small business digitalised tax experience
    • Delivering our performance evolution.
  3. Organisational capabilities
    • Tax administration effectiveness
    • Workforce
    • Reconciliation
    • Technology
    • Data and analytics
    • Financial investment
    • APS Reform
    • Vulnerability capability.

Professional associations 

The professional associations reported that their key areas of focus included: 

  • keeping their community informed and provide guidance on reforms, including TPB related reforms, Anti-Money Laundering and Counter-Terrorism Financing Rules and payday super
  • assisting members in their dealings with the ATO and ensuring ATO services and systems are fit for purpose
  • ensuring regulations and law changes are streamlined
  • supporting members in their compliance with implemented reforms.

External members also expressed that they are seeking increased consultation opportunities to provide input into the development of the TPB’s policy and guidance products and others matters that may be raised by the associations. 

Last modified: 27 November 2025