BAS Agent Code of Professional Conduct: What Australian Business Owners Must Know in 2026

If you use a bookkeeper or BAS agent to manage your business finances, a significant change to the professional standards governing their conduct came into full effect in 2025 — and it directly affects the service you should expect to receive. The Tax Agent Services (Code of Professional Conduct) Determination 2024 introduced eight new obligations for all registered tax and BAS agents in Australia, reshaping what it means to be a compliant and ethical bookkeeping professional.

Understanding the New Code of Professional Conduct Obligations

The Tax Practitioners Board (TPB) regulates all registered tax agents and BAS agents in Australia under the Tax Agent Services Act 2009 (TASA). The existing Code of Professional Conduct has long required practitioners to act honestly, with integrity, and in the best interests of their clients.

In July 2024, the government registered the Tax Agent Services (Code of Professional Conduct) Determination 2024, adding eight new obligations to the existing Code. These obligations apply to all registered BAS agents — including bookkeepers who provide BAS services for a fee — and came into effect on 1 January 2025 for larger practices and 1 July 2025 for practices with 100 or fewer employees.

For most small business bookkeepers and sole-practitioner BAS agents, the new obligations have been fully in force since 1 July 2025. Understanding what these obligations require — and what they mean for your relationship with your bookkeeper — is essential for Australian business owners in 2026.

The Eight New Obligations Explained

The Determination introduced obligations across five categories of the existing Code. Here is what each means in practice for bookkeepers and their clients.

Honesty and Integrity

Bookkeepers and BAS agents must actively uphold and promote the ethical standards of the tax profession. This goes beyond simply not lying — it requires practitioners to foster a culture of transparency within their practice, provide staff training on ethical conduct, and establish whistleblower policies where appropriate.

Practitioners must also address false or misleading statements. If a bookkeeper identifies that a statement they have prepared — such as a BAS lodgement — is materially false or misleading, and the client refuses to correct it, the practitioner may be required to report the matter to the TPB or the Commissioner of Taxation.

Independence

The new obligations include specific requirements for managing conflicts of interest, particularly in activities undertaken for or in dealings with government. Bookkeepers who also provide services to government entities, or who have personal interests that could conflict with their client obligations, must have documented processes for identifying and managing those conflicts.

Confidentiality

New standards govern how practitioners must maintain confidentiality in their dealings with government bodies. This is particularly relevant for bookkeepers who interact with the ATO on behalf of clients, as they must ensure that client information is not disclosed beyond what is necessary for the engagement.

Competence: Record-Keeping and Supervision

One of the most operationally significant new obligations requires bookkeepers to maintain proper client records and ensure that any BAS services provided on their behalf — for example, by junior staff or subcontractors — are delivered competently. Practices must have documented supervision processes and performance monitoring in place.

Quality Management Systems

Bookkeeping practices are now required to implement formal quality management systems. This means having documented processes for how services are delivered, how errors are identified and corrected, and how client work is reviewed before lodgement.

Keeping Clients Informed

Perhaps the most client-facing of the new obligations is the requirement to keep clients informed of any matter that could significantly influence their decision to engage or continue to engage the practitioner. This disclosure must be provided in writing, in a prominent, clear, and unambiguous manner.

Bookkeepers must also provide clients with information about the TPB register and the process for making complaints about their services. This obligation is designed to ensure clients know their rights and how to seek recourse if they are dissatisfied.

What This Means for Australian Business Owners

The new Code obligations raise the bar for what you should expect from your bookkeeper or BAS agent. As a business owner, you are entitled to a higher standard of transparency, communication, and professional conduct than was previously codified in the rules.

• Written disclosures — Your bookkeeper should proactively inform you in writing of any matter that could affect your decision to continue using their services, including conflicts of interest, changes in their practice, or issues with your accounts.
• Quality management — Your bookkeeper should be able to demonstrate that they have documented processes for reviewing work before lodgement and for managing errors when they occur.
• Supervision of staff — If your bookkeeper uses junior staff or subcontractors to handle your accounts, they are responsible for ensuring that work is performed competently and reviewed appropriately.
• TPB registration — Your bookkeeper must be registered with the TPB to legally provide BAS services for a fee. You can verify their registration on the TPB's public register at tpb.gov.au.
• Complaint rights — Your bookkeeper must inform you of your right to make a complaint to the TPB if you are dissatisfied with their conduct.

Common Mistakes and Red Flags

Not all bookkeepers have adapted smoothly to the new obligations. Business owners should be alert to the following warning signs when assessing their current or prospective bookkeeper.

• No written engagement letter or disclosure — A compliant bookkeeper should provide a written engagement letter that includes disclosure of any conflicts of interest and information about the TPB complaints process.
• Unregistered practitioners — Providing BAS services for a fee without TPB registration is illegal and carries significant civil penalties. Always verify registration before engaging a bookkeeper.
• No quality management processes — If your bookkeeper cannot describe how they review work before lodgement or how they handle errors, this is a red flag under the new Code obligations.
• Poor communication about changes — If your bookkeeper fails to inform you of changes to their practice, fee structures, or matters affecting your accounts, they may be in breach of the "keeping clients informed" obligation.
• Reluctance to provide TPB information — A registered BAS agent should readily provide their TPB registration number and information about the complaints process. Reluctance to do so is a warning sign.

Australian Regulatory Context

The TPB is the national regulator for tax and BAS agents in Australia, operating under the Tax Agent Services Act 2009. It sets registration requirements, enforces the Code of Professional Conduct, and has the power to impose administrative sanctions — including suspension or termination of registration — for breaches.

The new Code obligations introduced by the Determination 2024 are enforceable as breaches of Code item 17 of the existing Code. The TPB has stated it will take a "pragmatic and practical" approach to enforcement for practitioners making genuine efforts to comply, but it will act against those who are not.

The Australian Taxation Office (ATO) works closely with the TPB to monitor compliance among registered agents. The ATO provides digital services and lodgement program concessions specifically to registered BAS agents, reinforcing the importance of maintaining registration and complying with professional obligations.

In addition to the new Code obligations, bookkeepers must also comply with the ATO's Single Touch Payroll Phase 2 requirements and prepare for the mandatory Payday Super regime, which requires superannuation to be paid on the same day as wages from 1 July 2026. These operational changes add to the compliance burden on bookkeeping practices and underscore the importance of engaging a well-resourced, compliant professional.

Questions to Ask Your Bookkeeper

When engaging a new bookkeeper or reviewing your existing arrangement, the following questions will help you assess whether they are meeting their obligations under the new Code.

1. Are you registered with the Tax Practitioners Board as a BAS agent? What is your registration number?
2. Do you have a written engagement letter that discloses any conflicts of interest and outlines the TPB complaints process?
3. What quality management processes do you have in place to review BAS lodgements before submission?
4. How do you supervise junior staff or subcontractors who work on client accounts?
5. How will you keep me informed of any changes to your practice or matters that could affect my accounts?
6. Are you up to date with the Payday Super requirements taking effect from 1 July 2026?
7. What continuing professional education have you completed in the past 12 months?

How MyMoney® Can Help

Finding a bookkeeper who is not only TPB-registered but also fully compliant with the new Code of Professional Conduct obligations is essential for Australian businesses in 2026. The right bookkeeper will proactively communicate, maintain quality management systems, and keep your accounts accurate and compliant.

MyMoney® connects Australian businesses with qualified, registered bookkeepers who meet the highest professional standards. Post a Brief to describe your bookkeeping needs and receive competitive proposals from compliant professionals. Or Browse Bookkeepers to find a registered BAS agent who is right for your business.