Key messages

Opening remarks

The Tax Practitioners Board (TPB) co-chair welcomed all attendees and informed Consultation and Standards Forum (CSF) members that Andrew Orme will commence in the role of TPB Secretary in January 2026. 

CSF members discussed the changes made to the draft CSF Charter, which details how the CSF will operate, including the role, purpose and responsibilities of the CSF. This revised CSF Charter will be published on the TPB’s website once finalised.  

Environmental scan

Tax Practitioners Board

The TPB provided a number of strategic insights as to what they are observing in the broader environment, including: 

  1. Red tape reduction
    • The TPB noted its focus on supporting the Government’s priority to reduce red tape, enhance productivity, and streamlining regulation.
    • The TPB welcome suggestions and ideas from the members to inform the TPB’s areas of focus.
  2. Use artificial intelligence (AI) by tax practitioners
    • The TPB noted it has developed guidance for tax practitioners on the use of AI and is currently seeking feedback from members before public consultation commences.
  3. Demographics
    • The TPB’s shared details of tax practitioner demographics, which would inform the TPB’s services and engagement with tax practitioners.  
    • Key information and trends included:
      • As of November 2025, there are 63,847 total tax practitioners comprising of 46,887 tax agents and 16,960 BAS agents.
      • Of the individual tax agent practitioner population, 68% are male and 31% are female. 57% of tax agents are above 50 years old while 42% of tax agents are between 30 and 49 years old.
      • Of the individual BAS agent population, 17% are male and 82% are female. 65% of BAS agents are above 50 years old while 34% of BAS agents are between 30 and 49 years old.
      • Over the last 10 years, the following trends have been observed:
        • The number tax and BAS agent registrations has steadily increased over the last 10 years.
        • The majority of tax and BAS agent new entrants are between 30 to 49 years old.
        • The majority of tax and BAS agents ending registration are above 60 years old.
      • Over the last 4 years, reasons for tax practitioners surrendering their registration include retirement, no longer practising, selling their business or changes in registration.
  4. The TPB reiterated its key areas of focus:
    • Delivering a proportionate, fair and data-driven risk-based compliance program
      • The TPB has announced its 2026 compliance priorities to provide greater transparency and clarity to the tax profession and promote integrity, support voluntary compliance, and strengthen community confidence in the tax profession. These priorities complement the TPB’s enduring focus areas, which remain central to its compliance approach.  
      • The priorities target both emerging and ongoing risks, with a particular focus on tax practitioner misconduct or unethical behaviour.
    • Supporting tax practitioners and the public
      • Enhancing 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.
      • Reviewing the TPB’s communications strategy to ensure that the TPB is best placed to support the public and tax practitioners.
      • Focus on re-prioritising the TPB’s policy guidance work program.
      • Continuing to engage with all stakeholders to develop guidance on the operation of any new laws.
      • Improving services to tax practitioners (IGT’s review of Australian Taxation Office (ATO) telephony services).

Professional associations 

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 the following:      

  • Tax practitioners are overwhelmed with increasing obligations from multiple regulators and client expectations.
  • Emergence of digital service providers and artificial intelligence.
  • The impact of competing demands on tax practitioners, including sanctions reform, Anti-Money Laundering and Counter-Terrorism Financing Rules and Payday Super.
  • The importance of increased transparency from the ATO regarding the timing of messages.
  • Guidance on the practical explanations of breach reporting and false or misleading statement requirements.
  • It was proposed that the pending Anti-Money Laundering and Counter-Terrorism Financing tranche 2 regime should be developed in conjunction with TPB requirements to prevent duplicate processes.

Australian Taxation Office 

The ATO outlined its commitment to transparency, communication and collaboration with the profession, and welcomes the release of the Tax Ombudsman review into the ‘ATO’s registered agent phone line and service offer to agents’ report. The Tax Ombudsman included 4 recommendations with 14 subparts. The ATO agrees with all recommendations, except for 1 sub-part of recommendation 3. The 4 recommendations were framed around: 

  1. ATO’s engagement with agents
  2. ATO’s digital services
  3. Registered agent phone line
  4. Support for client-to-agent linking (CAL). 

Reform matters

Treasury update

Treasury provided members with an update that the 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: 

  • Prescribed disciplinary bodies
  • Statutory review of corporate and tax whistleblowers
  • Legal professional privilege in Commonwealth investigations
  • Tackling fraud against the ATO and the tax and superannuation systems
  • Enhancing the TPB’s sanctions regime.
     

Treasury sought members' input into upcoming public policy and law design papers. Members provided feedback in relation to those upcoming discussion papers which were noted by Treasury.

Policy guidance matters

The TPB provided the following update from the CSF out-of-session working group held on 17 November 2025:

  • The out-of-session working group discussed technical matters related to the TPB’s guidance on breach reporting, false or misleading statements and conflicts of interest in activities undertaken for government. The TPB advised that the suggested amendments are under consideration and revised guidance will be published on the TPB’s website.  
  • The TPB discussed proposed draft TPB website guidance for registered tax practitioners on preventing financial abuse within the tax system. The TPB’s initiative was welcomed, however, some attendees suggested additional avenues for the TPB to be further informed by work being done by other organisations. Members supported the TPB’s suggestion to convene a smaller working group to discuss ways to improve the TPB’s proposed draft website guidance for registered tax practitioners on preventing financial abuse within the tax system.
  • The TPB sought feedback on the appropriateness of extending the scope of BAS services by way of legislative instrument under the Tax Agent Services Act 2009 to cover the preparation and/or lodgement of the Not-For-Profit self-review return. Members generally supported the legislative instrument.
  • The TPB sought initial comments regarding the contents of the Exposure Draft Information sheet TPB(I) DX/2025 The use of artificial intelligence and the Code of Professional Conduct.
  • The TPB provided an overview of its intended repeal of the Tax Agent Services (Specified BAS Services No. 2) Instrument 2020 and proposed amendments to the Information sheet TPB(I) 38/2023 What is a BAS service. Members supported the repeal of the Instrument, noting that there will not be any practical impact for registered BAS agents.
  • Members provided feedback and comments in relation to the TPB’s Exposure Draft Information sheet The use of artificial intelligence and the Code of Professional Conduct which will be considered by the TPB.
     

Strategic operational matters

As requested at the previous CSF, the TPB provided members with the following insights:

  1. The TPB’s engagement strategy to raise awareness amongst tax practitioners regarding their renewal requirements
     
    • The TPB provides registration renewal reminders to practitioners through direct SMS and email communications for those who opt in to receive them (99.9% of the tax practitioner population). Renewal reminders are provided 80 days, 45 days, 10 days and 5 days before registration expires.  
    • Additionally, the TPB also reminds tax practitioners to renew via other indirect communication methods such as regular TPB eNews articles, social media posts, webinar updates and through the TPB website.
    • As part of the TPB’s strategy to improve the renewal reminder process, the TPB will:
      • increase contact with renewing tax practitioners to every 3 weeks, using email, SMS, and physical letters where required, during the 90-day period the renewal form is available  
      • conduct a communications review of renewal reminders to ensure clarity and consistency
      • encourage practitioners to set up calendar reminders and keep their contact details up to date with the TPB
      • incorporate CSF feedback into the renewal strategy, including publishing guidance on avoiding missed renewals and clarifying the impacts of late renewal.
  2. Operational insights about the following TPB matters

    1. TPB’s investigation process 

      Step 1: Identifying potential breach 

      A potential breach is identified based on our analysis of data or by receiving a complaint or referral. 

      Step 2: Making preliminary enquiries

      We conduct preliminary enquiries and profiling activities with complainants, third parties or other regulators to establish relevant facts and then we then make risk-based decisions on whether to commence an investigation. 

      Step 3: Please explain letter issues

      If our enquiries identify a potential breach of the TASA, we may issue a 'please explain letter' to the practitioner providing them with an opportunity to respond and clarify any issues.

      Step 4: Notice of investigation issues

      We must notify the tax practitioner when we begin an investigation. Once we start an investigation, we must reach a final decision within 24 months unless the Board decides to extend the investigation.

      Step 5: Investigation begins

      To begin an investigation, we start to gather evidence, depending on the nature of the behaviour and we may go to third parties such as financial institutions, witnesses and co-regulators.

      Once a formal investigation has started, we have the power to require a person, including a complainant or another third party to:

      • provide us with information, documents or other items
      • appear before us and give evidence.
         

      Step 6: Outcomes of an investigation

      Possible outcomes from an investigation include:    

      • granting or rejecting an application to register with us
      • imposing one or more of the available sanctions such as a written caution, an order, suspension or termination of an entity's registration
      • applying to the Federal Court for an order for payment of a penalty and/or an injunction
      • making a decision that no further action will be taken.

      If a breach of the TASA is found, our Board Conduct Committee is required to determine an appropriate sanction for the behaviour.

      In the more serious cases, the investigation can also lead to an application being made to the Federal Court for pecuniary penalties (fines).

      Step 7: Notification of decisions

      We will notify the practitioner in writing within 30 days of the outcome of the investigation, giving reasons for the decision.

      Step 8: Review and appeal 

      Tax practitioners can apply to the:

      • Administrative Review Tribunal (ART)* for a review of most decisions following an investigation
      • Federal Court or Federal Circuit Court for review of administrative decisions under the Administrative Decisions (Judicial Review) Act 1977
      • In some cases tax practitioners and complainants may request an internal review of TPB decisions, or make a complaint to the Inspector-General of Taxation and Taxation Ombudsman (IGTO).

    2. TPB’s complaint handling processes

      The TPB complaints process involves:   

      • Complaint received – initial triage to ensure the complaint is TASA related
      • Preliminary checks – Assess whistleblower protection consideration, mandatory significant breach reporting or anonymous complaints
      • Complaint assessment – previous TPB complaints/cases, reviewed any supporting documents, open-sources/ATO data searches 
      • Contact complainant – request any further document or clarification if required and undertake proof of identity when reaching out to a complainant
      • Finalise complaint – complaint assessed as low risk (complaint will be closed and details of the complaint retained as intelligence for possible future action, moderate risk (TPB may issue a letter to practitioner indicating potential breach of the Code) or significant risk (complaint is escalated to the investigations area).

    3. Overview of tax practitioner enquiries received by the TPB  

      The majority of telephony enquiries received were regarding: 

      • renewal enquiries
      • qualifications and new applications
      • updating details
      • password resets
      • progress of applications.
         

      Examples of renewal enquiries involved agents who missed the renewal deadline and required assistance to complete their renewal, updating multi-factor authentication, updating address details on the renewal form where the practitioner’s address cannot be validated and agents mistakenly creating a new application for registration instead of a renewal application. 

      The majority of email enquiries received were regarding maintaining/ending registration and general enquiries for example:   

      • advice on registrations requirements such as qualifications, experience and eligibility
      • update on application status
      • advice on specific situation
      • requests to reopen renewal form
      • requests to update in-progress applications
      • agents reporting forms and system issues.

 

Last modified: 27 February 2026