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Navigating the New Code of Conduct Changes: A Bookkeeper's Guide

By Kelvin Deer, Director of Australian Bookkeepers Network and Australian Bookkeepers Association

As we edge closer to significant updates in the Code of Conduct, it's vital for Australian bookkeepers to stay informed and prepared. These changes, set to commence on 1 July 2025 for practitioners with fewer than 100 staff, may feel daunting. But rest assured, time is on your side, and there’s plenty of support available.

Let’s break down what you need to know and focus on actionable steps, especially for sole traders, who make up a large portion of our community.

Understanding the New Code of Conduct Determination

The Tax Practitioners Board (TPB) has released six draft information statements covering key obligations. These include:

1. False or misleading statements
2. Confidentiality and conflicts in dealings with government
3. Keeping clients informed
4. Upholding and promoting ethical standards
5. Supervision, competency and quality management
6. Keeping proper client records

While full compliance isn't required until mid-2025, now is the time to familiarise yourself with these updates. You can access detailed guidance directly on the TPB website.

Key Focus Areas for Bookkeepers

Let’s zero in on two areas causing a lot of concern: Competency & Quality Management Systems (QMS) and Record Keeping.

1. Competency & QMS

The existing competency requirements under Section 30 of Tax Agents Services Act (TASA) remain largely unchanged. You’re still expected to maintain up-to-date skills of the services you provide through continuous professional education (CPE) and ensure that your services are delivered with reasonable care in applying taxation laws. There are now additional competency requirements, however, which extends to the keeping of proper client records and also ensuring any BAS Agent service that is provided on your behalf is also provided competently —not just by you, but also by any entity working on your behalf (e.g., contractors, outsourced or offshore teams).

For sole traders and competency requirements:

• Focus on engagement letters that clearly define your scope of services.
• Document any specific advice provided as part of your service, for example GST implications on property transactions.
• If you’re already using work papers and checklists as part of your processes, you’re likely well-prepared for these changes.

QMS Considerations: When it comes to the size of the firm or business delivering BAS Services, the TPB emphasizes scalability is a factor. For sole practitioners, this means a practical QMS might include:

• Periodic reviews of your work.
• Policies addressing client engagement, confidentiality, and complaint handling.
• Robust cyber and software security protocols.

Remember, your QMS doesn’t need to mirror that of a large firm. The key is proportionality—design a system that aligns with your practice’s size and complexity of the work performed and the clients for which you serve.

2. Record Keeping

One of the most significant updates involves client record-keeping requirements. Initial drafts of the Determination suggested duplicating client records—a daunting proposition. Thankfully, after consultations, this has been amended to now require you to maintain records that correctly explain your work and the services you provided.

Here’s what you need to do:

• Keep records in English that document the nature and scope of your services and any outcome determined.
• Retain detailed notes for complex advice or transactions, including facts and assumptions, applied reasoning, and supporting materials like rulings or case law.

For most bookkeepers and BAS Agents, existing checklists, templates, and work papers should suffice. However, in specific cases that may be a bit more complex or involve a large transaction (e.g., large asset purchases), maintain copies of invoices or agreements for added clarity.

What’s Next?

The TPB is continuing to finalise these guidance statements following public consultation. Once finalised, the Australian Bookkeepers Network (ABN) will provide members with updated templates, tools, and guidance materials to ensure smooth compliance in plenty of time for the 1 July commencement date.

Final Thoughts

While the changes may seem overwhelming, the good news is that help is at hand. As bookkeepers, there is both time and resources being made available to adapt effectively. So, don’t rush into costly or time-consuming adjustments just yet. Instead, stay tuned for updates and leverage the support from professional networks like ABN along with the Tax Practitioners Board.

By focusing on practical steps and maintaining a clear, structured approach, we can meet these new standards with confidence.

Have questions or concerns? Reach out to your network or tune into resources like Bookkeeper Radio for detailed discussions.

Here’s to a smooth transition and a productive 2025 ahead!