Tax agents and BAS agents are both registered under the Tax Agent Services Act 2009 (TASA), regulated by the Tax Practitioners Board (TPB), and subject to the Tax Agent Services Regulations. But their scope of services differs significantly — and providing services outside your registration is a breach of TASA that can result in civil penalties.
This guide clarifies the difference for bookkeepers and accountants who want to understand their registration obligations, and for clients who want to know which professional can help them with which task.
The Tax Practitioners Board and TASA
The Tax Practitioners Board (TPB) was established by TASA 2009 to regulate tax practitioners in Australia. The TPB maintains a public register of all registered tax agents and BAS agents, issues registration codes, and investigates complaints and compliance breaches.
Under TASA, it is an offence for an unregistered person to provide tax agent services or BAS agent services for a fee or reward. The penalty is up to 1,000 penalty units ($330,000 in 2026) or imprisonment in serious cases.
"For a fee or reward" is interpreted broadly — it includes any commercial arrangement, not just direct cash payment. Providing bookkeeping services under a business arrangement, even if you're a sole trader billing through an ABN, brings you within scope.
What BAS agents are authorised to do
A registered BAS agent is authorised to provide BAS services, defined in TASA as:
- Preparing and lodging activity statements (BAS, IAS)
- Ascertaining or advising about liabilities, obligations, or entitlements that arise under a BAS provision of a taxation law
- Representing clients in dealings with the ATO that relate to BAS provisions
BAS provisions include:
- GST obligations and entitlements
- PAYG withholding obligations
- PAYG instalment obligations
- Fuel tax credits
- Luxury car tax
- Wine equalisation tax
- Fringe benefits tax (only aspects included in the activity statement)
BAS agents can:
- Reconcile bank transactions and code them to GST/N-T/FRE/INP/CAP
- Prepare and lodge the BAS
- Advise on GST registration thresholds
- Advise on GST treatment of specific transactions (within the scope of their competency)
- Represent the client in ATO disputes about BAS amounts
- Process payroll and prepare the PAYG withholding summary for the activity statement
BAS agents cannot:
- Prepare income tax returns
- Advise on income tax deductions or capital gains tax
- Lodge fringe benefits tax (FBT) returns (different from the FBT amount on the activity statement)
- Act as a tax agent in income tax matters
- Advise on superannuation fund compliance (other than super guarantee amounts on the activity statement)
What tax agents are authorised to do
A registered tax agent can provide all BAS services (the BAS agent scope is a subset of the tax agent scope), plus:
- Preparing and lodging income tax returns for individuals, companies, trusts, and partnerships
- Advising on income tax deductions, CGT, FBT, and other tax liabilities
- Representing clients in ATO audits and objections for income tax matters
- Providing advice on the operation of the income tax laws
- Preparing and lodging FBT returns
- Advising on SMSF compliance and tax obligations
A registered tax agent can do everything a BAS agent can do and more. A BAS agent cannot do what requires a tax agent.
Registration requirements: BAS agent
To register as a BAS agent with the TPB, applicants must demonstrate:
Qualifications: A Certificate IV in Bookkeeping or Accounting (or equivalent), or demonstrate sufficient prior experience that the TPB accepts as equivalent.
Relevant experience: Minimum 1,400 hours of relevant experience in the five years before applying. This experience must cover activity statement services.
Continuing professional education: Minimum 45 hours of CPE every three years (including at least 5 hours in tax agent services). Most professional associations (ICB, AAT) provide compliant CPE programs.
Fit and proper person: No criminal convictions relevant to financial probity, no outstanding tax debts with the ATO, and no prior registration cancellation.
The TPB assesses applications and, if approved, issues a BAS agent registration number that must appear on all activity statements lodged by the agent.
Registration requirements: tax agent
Tax agent registration requires more extensive qualifications:
Qualifications: A degree in accounting or a related discipline (or a tax-relevant postgraduate qualification) from a registered higher education provider, or a Diploma in Financial Services (Accounting) or Diploma of Accounting with relevant experience.
Relevant experience: Minimum 1,000 hours of tax agent services experience (including income tax return preparation) under the supervision of a registered tax agent.
Professional membership: Membership of a recognised tax agent association (CPA Australia, Chartered Accountants ANZ, IPA, or the Tax Institute) is required for most applicants and provides the professional indemnity insurance component.
Continuing professional education: Minimum 60 hours CPE every three years for tax agents.
The higher qualification and experience bar reflects the broader and higher-risk scope of tax agent services.
The supervised employee exemption
A common area of confusion: employees of a registered tax agent or BAS agent are allowed to provide tax agent or BAS agent services as part of their employment without individually holding a registration — as long as:
- They are employed by (or contracted to) the registered agent
- The registered agent maintains appropriate supervision and oversight
- The services are provided under the agent's registration
This exemption covers most bookkeepers who work in accounting practices. The practice's BAS agent or tax agent registration covers the services provided by staff, provided the principal agent maintains appropriate oversight.
The exemption does not cover independent contractors running their own bookkeeping business — they must hold their own registration.
Practical guidance for bookkeepers
If you run your own bookkeeping business and provide BAS preparation services: You need a BAS agent registration. Operating without one — even as a sole trader — is a TASA breach.
If you work as an employee of an accounting practice: Check whether your employer holds the relevant registration and is maintaining appropriate supervision. You may not need your own registration while employed, but you should understand the scope of services you're delivering.
If a client asks you to prepare their income tax return: You need a tax agent registration. Refer this to a registered tax agent unless you hold that registration.
If you're unsure whether a service is within your registration scope: The TPB's website includes a "who can provide tax agent services" guidance document. When in doubt, do not provide the service and refer the client to an appropriately registered practitioner.
How Reconlink supports registered BAS agents
Reconlink is purpose-built for practices providing BAS agent services. The workflow supports every step in the BAS preparation process:
- Bank feed import (CDR or manual statement upload)
- AI-assisted transaction coding (account codes + GST codes)
- Rule-based auto-coding for recurring vendors
- BAS worksheet calculation (G1–G19, 1A, 1B)
- Excel export ready for review before lodgement
Reconlink does not lodge directly with the ATO — the registered BAS agent reviews the worksheet and lodges through the ATO's online services for agents or tax agents portal. This ensures the human professional remains responsible for every statement lodged.
For a walkthrough of the BAS preparation workflow, see How to export a BAS worksheet in Reconlink.
Frequently asked questions
Can I provide bookkeeping services without a BAS agent registration?
It depends on the services. Bookkeeping that doesn't include preparing or lodging activity statements, or advising on GST/PAYG obligations, is not covered by TASA and doesn't require registration. But if you're coding transactions with GST codes for the purpose of BAS preparation, you are providing a BAS service and registration is required.
Do I need a registration if I only do data entry?
Pure data entry under close supervision of a registered agent may fall under the supervised employee exemption. But if you're making coding decisions (assigning GST codes, deciding how a transaction is treated for GST) independently, you are providing a BAS service.
How long does registration take?
The TPB aims to process complete applications within 28 days. Allow 4–6 weeks to collect the required documentation, submit the application, and receive the registration number.
Does my registration need to be renewed?
Yes. BAS agent registrations are issued for three-year terms and must be renewed before expiry. The TPB sends renewal reminders. Late renewal results in a gap in registration — any services provided during that gap are unregistered and breach TASA.
This article was last reviewed on 27 May 2026 against current TPB guidance and TASA 2009. Registration requirements change. Always confirm current requirements at tpb.gov.au. This is general guidance, not legal advice.