BAS Agent: Permitted Services and Authority

A BAS agent is a registered practitioner who provides services within the permitted BAS scope, including GST and specified payroll work. Before accepting an engagement, separate that scope from income-tax advice and confirm the client’s authority for you to act.

What a BAS Agent Does

A registered BAS agent works out BAS obligations, advises on them or deals with the ATO for a client within the permitted scope. The client must reasonably be expected to rely on the service to meet an obligation or claim an entitlement.

The Tax Practitioners Board’s BAS service guidance makes the distinction task by task. A job’s bookkeeping label does not decide whether registration is required.

Entering figures from supplied instructions is different from deciding the client’s GST treatment. Preparing a bank reconciliation is recordkeeping. Interpreting BAS provisions to calculate figures for the activity statement is a BAS service.

When a prospective client asks for bookkeeping, ask what decisions they expect you to make. A request to record transactions can expand into advice about GST credits or employee withholding before anyone calls it BAS work.

BAS Agents and Tax Agents

BAS registration covers a defined part of tax work, while tax-agent registration covers broader services under taxation law. BAS registration alone does not authorise general income-tax advice or income-tax return preparation.

The TPB’s tax-agent service definition covers advice, calculations and representation on taxation-law obligations that clients can reasonably rely on. A tax agent must also work within their competence and any registration conditions.

For example, a client asks you to reconcile purchases and claim the correct GST credits. That falls within BAS work. If they also ask whether the equipment qualifies for an income-tax deduction, refer that question to a tax agent.

A bookkeeper can enter records without interpreting tax law. Once the bookkeeper decides the client’s tax treatment, assess the actual service against the relevant registration requirements. An accounting qualification or the bookkeeper job title does not establish BAS registration.

If you are entering the profession, use the separate BAS agent registration guide for qualifications and the application route.

Check the Services You Can Offer

Check each requested service against the TPB’s permitted scope before you agree to provide it. The TPB’s service examples distinguish clerical work from applying BAS provisions to the client’s circumstances.

Client request	BAS scope decision
Decide GST coding for the client’s transactions	BAS service when you interpret or apply GST law
Calculate PAYG withholding for employees	BAS service
Set up Single Touch Payroll reporting using tax-law decisions	BAS service
Transmit payroll data without interpreting tax law	Transmission alone is not a BAS service
Calculate a superannuation guarantee charge liability and prepare its statement	Within permitted BAS services
Prepare the client’s income-tax return	Requires tax-agent scope

Payroll work needs a scope check beyond the software task. Permitted superannuation guarantee services include payroll and contractor-payment matters, with specific authority for superannuation guarantee charge work. That authority does not cover every question about superannuation or employment law.

In a fictional example, a nonprofit association employs staff and asks you to calculate withholding and report payroll. Its nonprofit status does not expand your registration. Accept the permitted payroll work if you are competent, and refer a request to determine its income-tax exemption to a tax agent.

After you confirm the boundaries, use the BAS services engagement guide to define the agreed deliverables.

Confirm Registration and Client Authority

Confirm current registration separately from the client’s permission for you to act. The TPB register guidance explains how to search by registration number or legal name and inspect the matching record.

Check the registration type and status, expiry and any conditions. An entry can remain visible while registration is suspended, so finding a name is not enough. Match the registered individual or business to the practitioner providing the service.

Then establish who is engaging you and their authority for the entity. Complete identity checks before BAS services. The TPB’s client-verification guidance separates identity checks from ATO client-to-agent linking.

For ABN entities other than sole traders, the ATO’s agent nomination route applies when appointing a new agent or changing authorisations. The client nominates the agent through Online services for business. You cannot nominate yourself for the client.

Record the client’s instructions and complete the applicable agent-linking steps before accessing their ATO records. Confirm the relevant account authorisation and the client’s approval of the figures before lodging. For a sole trader, use the applicable ATO authorisation route without directing them through the business nomination requirement.

Set Boundaries in the Client Form

Use the client form to identify the requested work and who can approve it before the engagement grows. Keep the acceptance decision separate from collecting answers.

Use this short scope checklist when reviewing a new request:

1. Name the client entity and record who instructs you on its behalf.
2. List the requested work, including decisions the client expects you to make.
3. Match each service to your permitted scope and competence.
4. Confirm identity, representative authority and the required ATO access arrangements.
5. Record excluded work and who will handle each referral.
6. Communicate the agreed scope in the engagement letter.

Tax Genie’s guided client form collects the client and entity details. It generates an engagement letter from those answers, so you can carry the agreed details into the letter without typing them again. Adjust the letter to show the services you accept and the work referred elsewhere.

For the wider acceptance steps, use the bookkeeping client onboarding checklist.

Keep the Engagement Within Your Scope

Reassess scope whenever the client requests a different service or introduces facts that change the advice required. Work can fit BAS registration but still sit outside your competence.

If a payroll client asks about the income-tax consequences of changing entities, pause that advice and identify a suitable tax agent. Record the question, the reason for referral and the client’s permission before sharing confidential information. Update the engagement letter if your own agreed work changes.

The TPB Code of Professional Conduct requires competent services and reasonable care when establishing client facts and applying tax law. It also covers conflicts and confidentiality, with further obligations for client records and quality management.

Maintain the relevant professional knowledge and required insurance as well as your registration. Use the registration and ongoing requirements guide for the detailed requirements. Accept the next job only when its permitted scope, your competence and the client’s authority all support it.