BAS Agent Services and What a Bookkeeper Can Do

BAS agent services include deciding a client’s BAS obligations, advising on them and preparing the figures the client relies on. Before accepting paid BAS work, confirm the registered provider, agree who handles each task and separate that work from routine bookkeeping.

Define the BAS Service Engagement

Define the engagement by the decisions your client expects you to make, not by calling the package bookkeeping. Ask whether they want transaction entry, advice on GST treatment or a completed activity statement. Those are different deliverables.

Under section 90-10 of the Tax Agent Services Act 2009, the BAS-service test includes client reliance on advice or work concerning a BAS provision. Apply that test to each requested task. A client asking you which GST figure to report is asking for more than entry of supplied records.

The Tax Practitioners Board’s BAS-service examples distinguish ordinary bank reconciliation from reconciling data to determine activity-statement figures. Entering supplied figures without tax interpretation is another bookkeeping example. Choosing GST codes for that client or confirming their BAS figures involves the regulated work.

Payroll also needs a task-by-task scope. Interpreting withholding rules or applying BAS provisions through Single Touch Payroll can be BAS services. Superannuation guarantee work related to payroll or contractor payments can fall within the statutory scope. State whether your engagement includes that work or sends it to another practitioner.

For an ordinary paid client engagement, the BAS service provider must have the relevant registration. Sections 50-5(2), 50-10(2) and 50-15 address unregistered paid services, advertising and false registration claims. Calling the package bookkeeping does not remove that boundary.

Use the BAS agent role guide for the wider permitted-service boundary. If you intend to provide BAS services in your own right, the BAS agent registration requirements address that separate decision.

Divide Work With the Client’s Accountant

Assign each task to the practitioner engaged to handle it and confirm the division with the client’s accountant. A job title alone does not establish who can provide paid tax or BAS services.

Use the following as an engagement example, then replace the proposed owners with the actual agreed roles.

Client work	Proposed owner	Handover or decision to record
Enter invoices and match bank transactions	Bookkeeper	Follow documented coding instructions and flag transactions needing tax interpretation.
Decide GST or payroll withholding treatment	Registered BAS or tax practitioner within scope	Give the bookkeeper the treatment and retain the basis for it.
Resolve accounting questions outside the agreed BAS work	Client’s accountant	Return the accounting treatment and identify any tax decision needing a registered tax agent.
Prepare and review activity-statement figures	Engaged registered BAS or tax practitioner	Record reconciliations and unresolved questions before seeking approval.
Handle income-tax advice and returns	Engaged registered tax agent	Receive the records and questions referred from the BAS work.
Approve the BAS and arrange payment	Authorised client representative	Approve the completed statement and retain payment responsibility unless separately agreed.
Lodge the approved BAS	Authorised registered practitioner engaged to lodge	Give the client the statement and lodgment confirmation.

For example, an invented company engagement can assign transaction entry to a bookkeeper and BAS preparation to a registered BAS agent. The client’s tax agent handles income-tax questions. If a purchase raises both GST and income-tax questions, record each question and its owner. Do not treat a reply about one tax as approval for the other.

Unregistered staff can work within a registered provider’s supervision arrangements. The TPB’s supervision guidance requires direction and oversight appropriate to the work. Name the supervisor and agree how instructions and work reviews happen. Give staff a route for questions they cannot resolve. Sending a finished file to an agent for a signature does not establish adequate supervision by itself.

Check the Provider Before Subcontracting

Check the proposed subcontractor’s current TPB registration before assigning client BAS work. A registration number on an email signature is only the starting point.

1. Open the TPB public register and select the search for an existing practitioner.
2. Enter the provider’s legal or registration name, registered business name or TPB registration number. For a tax agent number lookup, use the number the provider supplies.
3. Match the returned identity to the person or entity you will engage. A similar name is insufficient.
4. Open the information icon for the full record. Check the registration type and status, then read any conditions restricting the proposed work.
5. Review published sanctions and relevant decisions. The register includes suspended practitioners and some unregistered entities, so appearing in results is not proof of active registration.
6. Save your check with the proposed scope and the decision to engage. If a company or partnership provides the service, identify its registered supervisor as well.

The TPB register instructions explain the search fields and the details shown. Check the provider’s registration record again if their status changes or you expand their work.

If the returned status or conditions prevent the proposed work, assign it to a suitable registered provider before proceeding. Resolve an identity mismatch with the provider instead of relying on the closest search result.

Scope BAS Work at Onboarding

Record the service scope and reporting cycle before the first job starts. Use the client’s actual entity details and existing reporting obligations, then agree how records will reach the responsible practitioner.

Your engagement record needs distinct decisions:

• The entity receiving each service and the person authorised to instruct you.
• Included work, such as bookkeeping, BAS preparation, payroll or lodgment, with exclusions stated separately.
• The reporting cycle, first period covered and treatment of earlier unfinished work.
• The records the client supplies and the agreed delivery timetable.
• Who answers client questions, reviews figures and obtains approval.
• The registered practitioner responsible for BAS work and any subcontracting arrangements.
• The fee basis and how additional work is agreed.
• The client’s authority for the service, information sharing and lodgment where included.

Use an engagement letter that sets the bookkeeping and BAS scope to turn those decisions into the client’s agreement. Keep preparation and lodgment as separate deliverables if different providers handle them.

Tax Genie collects guided client details and generates your engagement letter from the client’s answers. Adjust the letter for the agreed BAS scope and send it for online signature. The registered practitioner named in the engagement handles the BAS preparation and authorised lodgment.

Registration also brings ongoing professional duties. Use the TPB Code obligations when setting your practice’s review and recordkeeping arrangements.

Confirm Deliverables Before the First BAS

Confirm the first BAS handover by following the job from records to client approval and lodgment. Agree the output at each stage so missing information cannot look like completed work.

1. Collect the records for the agreed entity and period. Record missing invoices or incomplete bank and payroll information.
2. Reconcile the source records. Have the responsible practitioner resolve differences affecting BAS figures.
3. Send the client specific queries and record their answers. Refer income-tax or other excluded questions to the client’s tax agent.
4. Prepare the statement and supporting work within the agreed scope. Record the review and any issues preventing completion.
5. Send the completed statement to the authorised client representative for approval. Obtain the required declaration or authority before lodgment.
6. Lodge through the authorised practitioner where lodgment is included. Give the client their statement, confirmation and payment details applicable to the completed job.

Keep a referral record naming the question, documents sent, receiving practitioner and response needed. Mark whether the issue prevents BAS completion or belongs to later tax work. A referral remains open until the receiving practitioner’s response or another agreed action resolves it.

Use the period-by-period BAS preparation checklist for the recurring execution work. Before accepting the first handover as complete, confirm the client has the agreed outputs and every unresolved question has an owner.