In this month’s BK Pod, we cover two key developments affecting the bookkeeping profession. First, we provide an update on the proposed Tranche 2 Anti-Money Laundering (AML) reforms and what they may mean for BAS agents and bookkeepers. A practical decision-tree approach is discussed to help practitioners determine whether their services may trigger a requirement to register with AUSTRAC. The discussion focuses on three potential “hotspots”: acting as a director or trustee for a client, providing a registered office or business address, or receiving, holding or controlling a client’s money as part of executing transactions. Importantly, it is clarified that simply preparing ABA payment files or having limited authority where the client still approves payments will not generally constitute control of client funds.

The episode also explores recent developments following the Tax Ombudsman’s report into ATO agent services. The report identified several areas where the ATO’s engagement with tax and BAS agents could be improved, particularly in relation to digital services, phone support and overall interaction with the agent community. In response, the ATO has acknowledged many of the concerns raised and committed to addressing the issues through a structured consultation process.

As part of this response, a new consultation forum known as the Tax Practitioners Implementation Consultation (TPIC) group has been established. The group brings together ATO representatives, professional associations and practitioners to work through the report’s recommendations and develop practical improvements. While meaningful reform will take time, the early meetings indicate a clear commitment to improving systems and strengthening the relationship between the ATO and the agent community.

Key Takeaways

• AML Tranche 2 reforms may require some BAS agents or bookkeepers to register with AUSTRAC, depending on the services they provide.
• Three key AML “hotspots” include acting as a director/trustee, providing a registered business address, or controlling client funds during transactions.
• Preparing ABA files or payment batches alone does not constitute control of client funds, meaning AUSTRAC registration is generally not required in those cases.
• The Tax Ombudsman’s report identified major issues in ATO agent services, particularly digital systems and phone support.
• The ATO has established the TPIC consultation group to work with industry bodies and agents to implement improvements and address the report’s recommendations.

The latest episode of the BK Pod is out now—bringing you practical insights and updates to support your practice as we move into 2026.

Kelvin Deer (ABN Director) steps through a suite of new and upcoming tools for BAS agents, including the BAS Agent Readiness Checklist, AML/CTF Kit, Supervision & Review Playbook, Breach Reporting Guide, and the soon-to-be-released Payday Super Kit.

Then Peter Thorp and Kerrie Jarius unpack the ATO’s recent changes to the General Interest Charge (GIC) remission process. They explain what’s new, how to lodge remission requests using the new form, and what bookkeepers can expect when dealing with debts under—and over—$2,500.

In this episode:

• Your 2026 Toolkit for AML, Payday Super, QMS, plus staff/contractor supervision, and the updated breach reporting rules
• How to use the new ATO remission form and where to lodge it
• Why small debt cases under $2,500 may now be faster and easier to resolve
• What the new written outcomes mean for you and your clients
• Which remission claims still rely on individual case officer discretion

In this episode of the BK Pod, we cover three key developments impacting bookkeepers and their clients: the evolving legal tests distinguishing contractors from employees, the upcoming closure of the ATO’s Small Business Super Clearing House (SBSCH), and important reminders around cyber security heading into the new year.

The episode focuses on the recent Dickerson v Kagura Games case, which examined whether a remote Australian worker—contracted by a US gaming company—was an employee under the Fair Work Act. Despite the contract being labelled “independent contractor,” the Fair Work Commission applied the new section 15AA test, introduced in August 2024. This test looks beyond the contract to the true nature and substance of the working relationship. In this case, the Commission found that Ms Dickerson was, in fact, an employee, due to the control and direction imposed on her by the company.

We also discuss the closure of the SBSCH, which will be permanently decommissioned at 11.59 pm on 30 June 2026. Bookkeepers should begin preparing clients now for this transition. The ATO has confirmed that access to the system and its stored information will cease at that time, with no guarantee of post-closure access. However, SG payments can still be made using previously generated payment references until 28 July 2026—as long as the submission was made before the June deadline.

The final segment focuses on cyber security risks, particularly around ATO systems and client portals. While the ATO will usually cover fraudulent activity when a breach occurs without agent or client fault, the administrative burden and reputational risk remain significant. The key message here is that proactive cyber hygiene—including strong passwords, multi-factor authentication, and client education—is essential heading into the new year.

Key Takeaways

• The section 15AA test under the Fair Work Act looks at the real working relationship, not just the contract terms.
• Even if someone is labelled a contractor, they may still be an employee for Fair Work purposes—bringing super, leave, and unfair dismissal rights into play.
• The ATO’s SBSCH will close permanently on 30 June 2026—ensure clients extract reports and transition to a new clearing house well before then.
• SG payments submitted before 30 June can still be paid up to 28 July 2026 using existing PRNs.
• Cyber attacks on tax and BAS agents are rising—now’s the time to review and reinforce your digital security systems.