The line for bookkeepers
You are a reporting entity if you provide a designated service. For bookkeepers the services that matter are about money and entities, not ledgers:
- Receiving or holding client money in your own account, for example to pay suppliers or the ATO on the client's behalf from funds you control.
- Having authority over a client's bank account beyond viewing it, such as making payments as a signatory.
- Registering companies or trusts for clients, or acting as their registered office.
- Helping a client buy or sell a business or property.
What stays outside
Recording transactions in the client's Xero or MYOB file, reconciling accounts, preparing and lodging BAS, running payroll from the client's own bank account, and advising on GST do not trigger enrolment. Paying bills from the client's account with the client's authority is usually seen as acting on their instructions, not controlling their money, but AUSTRAC guidance should be checked for your exact arrangement.
If you do need to enrol
The obligations are the same as for accountants: enrol within 28 days of first providing the service, adopt an AML/CTF program, verify client identity, report suspicious matters and keep records for 7 years. A bookkeeper who does this for a handful of clients needs a short program and a simple client register, not an enterprise system.
Questions people ask
- I lodge BAS for 40 clients. Do I need to enrol?
- Not for BAS lodgement. Only if you also provide a designated service such as controlling client money or setting up entities.
- Does being a registered BAS agent change anything?
- No. Tax Practitioners Board registration and AUSTRAC enrolment are separate. One does not exempt you from the other.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.