Who must comply with APES 110 Code of Ethics for accountants?
The applicability test for APES 110 Code of Ethics for accountants (ASIC and TPB), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Some businesses
Applies when the business has industry: Accountants & bookkeepers.
What the obligation is
APES 110 binds CA ANZ, CPA Australia and IPA members (and auditors) to five ethical principles via a threats-and-safeguards framework — who it covers and the penalties.
APES 110 (issued by the Accounting Professional & Ethical Standards Board (APESB), 2020) sets fundamental principles: integrity, objectivity, professional competence + due care, confidentiality, professional behaviour. Applies threats + safeguards framework; specific sections for audit + assurance independence.
The applicability test
Applies when the business has industry: Accountants & bookkeepers.
How the regulator frames it: Members of CA ANZ, CPA Australia, IPA + auditors generally.
What triggers it: Membership of professional accounting body.
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (1 of 35: yes; 34 of 35: no).
| Industry | Answer |
|---|---|
| Accountants & bookkeepers | Yes |
| No | 34 other industries |
Business structure and size
Structure does not change the answer in accountants & bookkeepers: for every structure the answer is "yes".
Size does not change the answer in accountants & bookkeepers: at every size band the answer is "yes".
Worked examples
Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:
- Pty Ltd company in accountants & bookkeepers with 6–19 employees, turnover $1M–$3M: applies. Industry: Accountants & bookkeepers.
- Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires industry: Accountants & bookkeepers.
What you must do, and when
- When due
- Continuous.
- Frequency
- Ongoing
- Evidence to keep
- Engagement letters with independence + scope; threats register; CPD record.
- Status
- Current
- Priority
- High
Penalty for not complying
Maximum penalty: Professional body disciplinary action; ASIC referral; civil liability.
Audit or assurance level
Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.
What usually applies alongside it
Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:
- TASA Code Determinations from 1 August 2024: applies to 100% of the same businesses (35.0× the overall rate)
- Comply with the TASA Code of Professional Conduct: applies to 100% of the same businesses (35.0× the overall rate)
- Maintain TPB registration (tax/BAS agents): applies to 100% of the same businesses (35.0× the overall rate)
- Designate an AML/CTF Compliance Officer: applies to 100% of the same businesses (4.4× the overall rate)
- Enrol with AUSTRAC as a reporting entity: applies to 100% of the same businesses (4.4× the overall rate)
- Maintain a written AML/CTF program: applies to 100% of the same businesses (4.4× the overall rate)
Where it sits in the corpus
Rules Mate tracks 1 published obligation tagged "professional ethics", 0 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated high priority, and is an ongoing duty.
Regulator, legislation and tools
Regulated by Australian Securities and Investments Commission and Tax Practitioners Board.
ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).
TPB: Federal regulator of tax + BAS agents under the Tax Agent Services Act 2009.
Free tools that help with this obligation:
Questions
- Who must comply with APES 110 Code of Ethics for accountants?
- Applies when the business has industry: Accountants & bookkeepers.
- Does APES 110 Code of Ethics for accountants apply to sole traders?
- Yes. Looking in accountants & bookkeepers and every size band, the engine's answer for a sole trader is: yes.
- Does APES 110 Code of Ethics for accountants apply to businesses with 1–5 employees?
- Yes (1–5 employees, turnover $100K–$1M).
- When is "APES 110 Code of Ethics for accountants" due?
- Continuous.
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.