Do accountants and bookkeepers need to prepare for the proposed removal of the small business exemption?
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: No
No. On the facts that define accountants and bookkeepers, this obligation does not apply. The engine's reason: Requires not app holds pi.
The obligation in brief
Prepare for the proposed removal of the small business exemption. Removing the Privacy Act's small business exemption (s 6D) — which currently exempts most businesses with annual turnover under $3M — was recommended in the Privacy Act Review and agreed in principle by the Government. It was NOT included in the first reform tranche (the Privacy and Other Legislation Amendment Act 2024).
Trigger: Commencement of a future bill removing the small business exemption (not yet introduced to Parliament).
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 "Prepare for the proposed removal of the small business exemption" is it depends on structure or size. Accountants & bookkeepers is one of the 11 where the answer is different: no.
The deciding fact for accountants and bookkeepers: Requires not app holds pi.
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 applies (Holds personal information but relies on the small business exemption (turnover under $3M)).
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 | No | No | No | No | No | No |
| Partnership | No | No | No | No | No | No |
| Trust | No | No | No | No | No | No |
| Pty Ltd company | No | No | No | No | No | No |
| Public company | No | No | No | No | No | No |
| Not-for-profit (unregistered) | No | No | No | No | No | No |
| Registered charity | No | No | No | No | No | No |
| Super fund | No | No | No | No | No | No |
| Foreign company | No | No | No | No | No | No |
What the obligation requires
- When due
- Not yet legislated — proposed for a future privacy reform tranche.
- Evidence to keep
- Privacy Policy, collection notices, breach response plan, staff training records, data inventory.
- Maximum penalty
- The standard Privacy Act penalty regime (up to $50M / 3× benefit / 30% turnover for serious or repeated interferences) would apply if and when the exemption is removed.
- 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
- Privacy Act Reform — information controllers regime (proposed Tranche 2): Yes
- Provide an APP 5 collection notice at or before collection: Yes
- Publish a Privacy Policy that meets APP 1: Yes
- All 23 answers for accountants & bookkeepers
Other industries with a non-default answer
Questions
- Do accountants and bookkeepers need to prepare for the proposed removal of the small business exemption?
- No. On the facts that define accountants and bookkeepers, this obligation does not apply. The engine's reason: Requires not app holds pi.
- 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.