Australia / Guides / Bookkeeper vs BAS agent vs tax agent in Australia: who is legally allowed to do what
Australia · guideBookkeeper vs BAS agent vs tax agent in Australia: who is legally allowed to do what
The short answer
A bookkeeper can record transactions, reconcile accounts, run payroll, and code GST on a chart of accounts without any licence or registration — that work is not restricted under Australian law. A BAS agent must be registered with the Tax Practitioners Board (TPB) before doing anything the Tax Agent Services Act 2009 defines as a "BAS service": ascertaining or advising on liabilities, obligations or entitlements under a BAS provision (GST, PAYG withholding, PAYG instalments, fuel tax credits and similar), or lodging a Business Activity Statement, for a fee. A tax agent holds a separate, broader TPB registration that additionally covers ascertaining and advising on income tax liabilities and lodging income tax returns. Providing a BAS or tax agent service for a fee while unregistered is a breach of the Act with civil penalties attached — which is why the practical question is never "does this person seem competent" but "is this person on the TPB register for the specific service being provided."
Key facts — verified dates on each
The statute that draws the line: TASA 2009
The Tax Agent Services Act 2009 (TASA) is the Commonwealth law that created the Tax Practitioners Board and defines exactly which activities require registration. Section 90-5 defines a "tax agent service" broadly: any service that ascertains, or advises an entity about, liabilities, obligations or entitlements arising under a taxation law, or that represents an entity in dealings with the Commissioner of Taxation — provided in each case that the entity can reasonably be expected to rely on it to satisfy a liability or obligation or to claim an entitlement, done for a fee or reward.
Section 90-10 carves out a narrower category, a "BAS service," covering the same ascertaining-or-advising-or-representing activity but limited to "BAS provisions" — the GST law, PAYG withholding, PAYG instalments, the fringe benefits tax collection provisions, luxury car tax, wine equalisation tax and fuel tax credits. Superannuation guarantee and superannuation guarantee charge matters were added to BAS agents' scope separately, by a Tax Practitioners Board legislative instrument made under section 90-10, not because they sit in the core "BAS provision" list. Lodging a Business Activity Statement, or otherwise dealing with the Commissioner about a BAS provision, on someone else's behalf for a fee is also a BAS service.
Both definitions turn on the same two verbs: ascertaining and advising. A person who calculates what GST a business owes, or tells them what to do about it, is providing a BAS service whether or not they call themselves a bookkeeper. A person who does the same for income tax is providing a tax agent service. Neither definition turns on job title, business card, or years of experience — it turns on the activity performed and whether a fee changed hands for it.
Bookkeeper: unregistered, and legally allowed to be
Bookkeeping itself is not a regulated profession in Australia. Recording transactions, reconciling bank and credit card accounts, coding expenses to a chart of accounts, running payroll, managing accounts payable and receivable, and closing the books each period are all activities anyone can perform for a fee without TPB registration, because none of them involves ascertaining or advising on a tax liability.
The line a bookkeeper cannot cross without becoming a BAS agent is advice or determination, not data entry. Coding a transaction as GST-free because the invoice says so, or because a registered agent instructed it, is bookkeeping. Deciding whether a transaction should be GST-free, or telling a client what their net GST position will be, is ascertaining or advising — a BAS service under section 90-10, and off-limits to an unregistered bookkeeper for a fee.
In practice, most bookkeeping engagements sit entirely on the unregistered side of that line: recording what happened, applying tax codes a client or their registered agent has already determined, and producing clean records for a BAS or tax agent to work from. That division is not a limitation particular to any one firm — it is where the statute puts the boundary for anyone doing bookkeeping work in Australia.
BAS agent: registered, scoped to BAS provisions
A BAS agent is a person or firm registered with the TPB specifically to provide BAS services for a fee. Registration requires meeting the Board's qualification and experience standards — broadly, a Certificate IV in Financial Services (Bookkeeping or Accounting) or equivalent plus a Board-approved GST/BAS taxation principles course, together with a set number of hours of relevant supervised experience — being a fit and proper person, and holding professional indemnity insurance that meets TPB requirements.
What that registration authorises is bounded by the BAS-provision list in section 90-10 — GST, PAYG withholding, PAYG instalments, FBT instalments, luxury car tax, wine equalisation tax and fuel tax credits — plus superannuation guarantee and superannuation guarantee charge matters, which the TPB added to a registered BAS agent's scope by legislative instrument rather than as a core BAS provision. A registered BAS agent can ascertain and advise on liabilities under those provisions and can prepare and lodge a client's Business Activity Statement directly with the ATO. Income tax — company tax returns, individual returns, tax planning outside the BAS-provision list — sits outside a BAS agent's registration; that work requires a separate tax agent registration.
- May do (once registered): ascertain and advise on GST, PAYG withholding, PAYG instalments, FBT instalments, fuel tax credits and super guarantee charge liabilities; prepare and lodge BAS on a client's behalf; deal with the ATO on BAS matters
- Requires: TPB registration (qualification + experience standards, fit-and-proper test, PI insurance)
- Does not cover: income tax return preparation or lodgment, or advice outside the listed BAS provisions — that is tax agent territory
Tax agent: the broader registration
A tax agent's TPB registration covers the full section 90-5 definition of a tax agent service — ascertaining or advising on liabilities, obligations and entitlements under any taxation law, and representing a client before the Commissioner — which includes everything a BAS agent covers plus income tax. Tax agent qualification standards are correspondingly higher: broadly a diploma or higher award in accounting (or an equivalent combination of qualification and experience) plus Board-approved courses in Australian taxation law and commercial law — one of the taxation-law units covers the TPB's regulation of agents and the Code of Professional Conduct — with a set period of supervised relevant experience.
A registered tax agent can prepare and lodge income tax returns, provide tax advice on matters outside the BAS-provision list (income tax treatment, deductions, tax planning), and represent a client in dealings with the ATO across the full range of taxation law. Many practitioners hold both BAS and tax agent registration, but the two are separate TPB registrations with separate qualification pathways — holding one does not automatically confer the other.
- May do (once registered): everything within a BAS agent's scope, plus ascertain and advise on income tax liabilities, prepare and lodge income tax returns, and represent a client before the Commissioner on tax matters generally
- Requires: TPB registration (higher qualification bar than a BAS agent, fit-and-proper test, PI insurance)
- Overlaps with a BAS agent on: GST and other BAS-provision matters, if the tax agent's registration conditions permit it
Why registration is checked, not assumed
TASA 2009 backs the registration requirement with civil penalty provisions that apply to anyone who provides a tax agent service or BAS service for a fee, or advertises that they will, while unregistered. Because the penalty attaches to the unregistered person, not the client, the practical safeguard sits with whoever is engaging the service: confirm registration before, not after, a return is lodged or a BAS advice conversation happens.
The TPB maintains a free public register at tpb.gov.au, searchable by name, business name, registration number or location, showing every currently registered tax and BAS agent (including suspended registrations). Checking a practitioner's name against that register before relying on tax or BAS advice takes a few minutes and is the direct way to confirm the "who is actually allowed to do this" question this guide answers in general terms.
What a normal month looks like across the three roles
In a typical small business engagement, the roles run in sequence rather than in competition. A bookkeeper keeps the ledger current through the month — transactions recorded, accounts reconciled, payroll run, GST coded on a chart of accounts the business (or its registered agent) has already set up. A BAS agent reviews that ledger each activity-statement period, ascertains the actual GST and PAYG position, and lodges the BAS with the ATO. A tax agent works from the same underlying records at year-end to prepare and lodge the income tax return and advise on anything outside the BAS-provision list.
CapEasy's Australian bookkeeping support sits in the first role: recording transactions, reconciling accounts, running payroll, and keeping a chart of accounts current and audit-ready so a client's registered BAS agent or tax agent can work from accurate numbers. CapEasy does not ascertain or advise on GST, PAYG or income tax liabilities, does not lodge a BAS or tax return, and does not hold TPB registration — those functions stay with the client's registered BAS agent or tax agent, checkable on the public TPB register.
The figures, and when we checked them
These numbers change by year or by notification. Each one shows the date we last verified it against the source — if that date looks old, check the source before relying on it.
Questions on this
Does a bookkeeper need to be registered with the TPB?
Not for bookkeeping itself. Recording transactions, reconciling accounts, running payroll and maintaining a general ledger do not require TPB registration. Registration is required only once the work crosses into ascertaining or advising on a tax liability — at that point it becomes a BAS service or tax agent service under TASA 2009, regardless of the job title on the invoice.
What is the difference between a BAS agent and a tax agent?
A BAS agent's TPB registration covers "BAS provisions" specifically — GST, PAYG withholding, PAYG instalments and a short list of related taxes — plus lodging a Business Activity Statement. A tax agent's registration is broader, covering income tax and taxation law generally, with a correspondingly higher qualification bar. Every BAS service is narrower than the full tax agent scope; not every tax agent service is a BAS service.
Can my bookkeeper lodge my BAS for me?
Only if that bookkeeper is separately registered as a BAS agent with the TPB. Lodging a Business Activity Statement on someone else's behalf for a fee is expressly listed as a BAS service under section 90-10 of TASA 2009, so it requires BAS agent registration even if the same person also does the underlying bookkeeping.
Can a BAS agent do my income tax return?
Not under a BAS agent registration alone. Income tax return preparation and lodgment falls under the broader tax agent service definition in section 90-5, which requires tax agent registration. Some practitioners hold both registrations, but they are separate TPB pathways with separate qualification requirements.
What happens if someone provides BAS or tax advice without being registered?
Providing a tax agent service or BAS service for a fee or reward while unregistered — or advertising that you will — breaches the Tax Agent Services Act 2009 and carries civil penalty provisions. The obligation to check registration status sits with whoever is relying on the advice, since the penalty attaches to the unregistered provider.
How do I check whether someone is actually a registered BAS or tax agent?
The TPB maintains a free public register at tpb.gov.au, searchable by name, business name, registration number or location. It lists every currently registered tax and BAS agent, including any whose registration is suspended, and is the direct way to verify a practitioner before relying on their advice.
Is coding GST on transactions a bookkeeping task or a BAS agent task?
Applying a tax code that has already been determined — by the client or their registered agent — to a transaction is bookkeeping. Deciding whether a transaction is GST-free, input-taxed or taxable in the first place, or advising a client on their GST position, is ascertaining or advising under section 90-10 and requires BAS agent registration.
Do BAS agents and tax agents need professional indemnity insurance?
Yes. TPB registration for both BAS agents and tax agents requires maintaining professional indemnity insurance that meets the Board's requirements, alongside the qualification, experience and fit-and-proper-person standards.
What does CapEasy do, and what stays with a registered agent?
CapEasy's Australian bookkeeping support covers recording transactions, reconciling accounts, running payroll and keeping the books current — work that does not require TPB registration. CapEasy does not ascertain or advise on GST, PAYG or income tax liabilities, does not lodge a BAS or tax return, and is not a substitute for a client's registered BAS agent or tax agent, who should be checked against the public TPB register.
Primary sources
- Federal Register of Legislation — Tax Agent Services Act 2009
- Tax Practitioners Board — Public Register
- Tax Practitioners Board — Qualifications and experience for BAS agents
- Tax Practitioners Board — Tax agent registration
- Tax Practitioners Board — Civil penalty provisions
Last reviewed 2026-08-14. Statutes and schedules change — the sources above are authoritative, this page is orientation.
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