Who must maintain TPB registration (tax/BAS agents)?
The applicability test for Maintain TPB registration (tax/BAS agents) (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
Tax agents and BAS agents must be registered with the TPB and comply with the Code of Professional Conduct.
Tax practitioners (tax agents, BAS agents) must be registered with the Tax Practitioners Board and meet the Code of Professional Conduct. The TASA Code includes obligations regarding honesty, confidentiality, competence, PI insurance, and (from 1 January 2025) significantly expanded breach-reporting and false-and-misleading-statement obligations.
The applicability test
Applies when the business has industry: Accountants & bookkeepers.
How the regulator frames it: Tax agents, BAS agents, tax (financial) advisers.
What triggers it: Providing tax agent or BAS services for a fee.
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
- Initial registration before providing services; annual renewal; CPE compliance.
- Frequency
- Ongoing
- Evidence to keep
- TPB registration, PI insurance certificate, CPE log, Code compliance records.
- Status
- Current
- Priority
- High
Penalty for not complying
Maximum penalty: Civil penalties for unregistered conduct + termination of registration.
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.
Enforcement examples
- TPB + Senate continued response — PwC tax leaks (2024): Tax practitioner confidentiality + governance reforms substantially tighter; firm + individual exposure.
- TPB v PwC Australia (tax leaks) (2023): Confidentiality breaches in tax practice attract individual termination AND firm-level scrutiny. Information barriers must be substantively enforced.
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:
- APES 110 Code of Ethics for accountants: applies to 100% of the same businesses (35.0× the overall rate)
- 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)
- 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 3 published obligations tagged "tax practitioners", 2 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 Tax Practitioners Board.
TPB: Federal regulator of tax + BAS agents under the Tax Agent Services Act 2009.
TASA: Establishes the Tax Practitioners Board + regulates tax agents, BAS agents + tax (financial) advisers.
Free tools that help with this obligation:
Questions
- Who must maintain TPB registration (tax/BAS agents)?
- Applies when the business has industry: Accountants & bookkeepers.
- Do sole traders need to maintain TPB registration (tax/BAS agents)?
- Yes. Looking in accountants & bookkeepers and every size band, the engine's answer for a sole trader is: yes.
- Do businesses with 1–5 employees need to maintain TPB registration (tax/BAS agents)?
- Yes (1–5 employees, turnover $100K–$1M).
- When is "Maintain TPB registration (tax/BAS agents)" due?
- Initial registration before providing services; annual renewal; CPE compliance.
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.