Does APP 2 — anonymity + pseudonymity for individuals apply to accountants and bookkeepers?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Yes
Yes. This obligation applies to accountants and bookkeepers whatever their structure or size. The deciding fact: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)).
The obligation in brief
APP 2 — anonymity + pseudonymity for individuals. APP 2 requires APP entities to provide individuals with the option of dealing anonymously or under a pseudonym, unless impracticable or required by law. Limits the default-required identification many businesses impose unnecessarily.
Trigger: Engaging with individuals where identification not strictly required.
Why accountants & bookkeepers get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 24 of those industries the answer for "APP 2 — anonymity + pseudonymity for individuals" is it depends on structure or size. Accountants & bookkeepers is one of the 11 where the answer is different: yes.
The deciding fact for accountants and bookkeepers: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A))
About the industry: Professional accounting and bookkeeping firms. Captured by Tranche 2 when providing designated services such as managing client money or company formation.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires APP-entity status (turnover > $3M or a s 6D(4) carve-out)).
Answer by business structure and size
Each cell is the engine's outcome for a business in accountants & bookkeepers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Yes | Yes | Yes | Yes | Yes | Yes |
| Partnership | Yes | Yes | Yes | Yes | Yes | Yes |
| Trust | Yes | Yes | Yes | Yes | Yes | Yes |
| Pty Ltd company | Yes | Yes | Yes | Yes | Yes | Yes |
| Public company | Yes | Yes | Yes | Yes | Yes | Yes |
| Not-for-profit (unregistered) | Yes | Yes | Yes | Yes | Yes | Yes |
| Registered charity | Yes | Yes | Yes | Yes | Yes | Yes |
| Super fund | Yes | Yes | Yes | Yes | Yes | Yes |
| Foreign company | Yes | Yes | Yes | Yes | Yes | Yes |
What the obligation requires
- When due
- Continuous.
- Evidence to keep
- Workflow analysis; consent + opt-out options; identifiers minimised.
- Maximum penalty
- Same penalty regime as broader Privacy Act breaches
- Regulator
- OAIC
- Jurisdiction
- Commonwealth (national)
Other obligations where accountants & bookkeepers differ from the norm
- Notifiable Data Breach (NDB) scheme: Yes
- APP 12 & APP 13 access and correction requests: Yes
- APP 7 direct marketing: consent, opt-out & when you can't message (2026): Yes
- Prepare for the proposed removal of the small business exemption: No
- Privacy Act Reform — information controllers regime (proposed Tranche 2): Yes
- Provide an APP 5 collection notice at or before collection: Yes
- All 23 answers for accountants & bookkeepers
Other industries with a non-default answer
Questions
- Does APP 2 — anonymity + pseudonymity for individuals apply to accountants and bookkeepers?
- Yes. This obligation applies to accountants and bookkeepers whatever their structure or size. The deciding fact: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)).
- Is the answer the same for every industry?
- No. For 24 of the 35 industries Rules Mate maps, the answer is it depends on structure or size. Accountants & bookkeepers is one of 11 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.