Australia / Guides / Outsourcing bookkeeping in Australia: rules, risks and the TASA line
Australia · guideOutsourcing bookkeeping in Australia: rules, risks and the TASA line
The short answer
Yes, a business can lawfully outsource its bookkeeping — recording transactions, reconciling bank feeds, running payroll data entry, and producing management reports are not restricted activities under Australian law, and nothing in the Tax Agent Services Act 2009 requires the person doing that work to be registered or to be based in Australia. What does require registration under section 90-10 of that Act is a narrower set of acts: ascertaining or advising on a client's liabilities, obligations or entitlements under a BAS provision, or dealing with the Commissioner of Taxation on the client's behalf. Whoever performs those specific acts — not the bookkeeper recording the underlying transactions — has to be a registered BAS or tax agent, checkable on the Tax Practitioners Board's public register, regardless of where they are physically located.
Key facts — verified dates on each
Recording is open; ascertaining and advising is not
Nothing in Australian law reserves the act of bookkeeping to a licensed or registered person. Entering transactions into a ledger, reconciling a bank feed against source documents, coding expenses to a chart of accounts, processing payroll data, and preparing management reports are ordinary commercial activities that any competent provider — in-house, local, or offshore — can perform for a fee.
The Tax Agent Services Act 2009 (TASA) draws its line somewhere else entirely. Section 90-10 defines a "BAS service" as a service that relates to ascertaining or advising an entity about their liabilities, obligations or entitlements under a BAS provision, or that represents the entity in their dealings with the Commissioner of Taxation, where the entity can reasonably be expected to rely on the service to satisfy those obligations. It is the ascertaining and the advising — working out what a business owes and telling them what to do about it — that the Act treats as a regulated service, not the transaction-level bookkeeping that produces the numbers the ascertaining is based on.
The Tax Practitioners Board's own guidance on what counts as a BAS service (TPB(I) 38/2023) draws a related but narrower line: it turns on whether the task requires interpreting or applying a BAS provision, not on the label "bookkeeping." Data entry, coding transactions based on instructions already given, processing payments and preparing bank reconciliations are described as sitting outside the BAS service definition for that reason. The same guidance is explicit that coding or reconciling crosses into a BAS service once it requires working out what should be reported — for example, reconciling data to ascertain the figures for an activity statement, or determining a GST or PAYG withholding liability.
Who has to be registered, and why it is a per-act test, not a per-provider test
A business outsourcing its books does not need to confirm that the whole provider is a registered BAS agent — it needs to know which specific tasks in the engagement are BAS services, and confirm that a registered agent (which can be the business's own accountant, a registered agent inside the provider, or a separate registered agent the business already uses) is the one performing those specific tasks. A provider can legally record every transaction, reconcile every account and hand over a complete set of numbers without a single registered agent touching the file, as long as nobody at that provider is the one ascertaining the BAS liability or lodging with the ATO.
TASA section 50-5 makes it a civil penalty offence to provide a BAS service for a fee while unregistered, and section 50-15 separately penalises representing that an unregistered entity is a registered agent. Both provisions attach to the entity actually performing or claiming to perform the regulated service — they do not attach to a bookkeeping provider that stays on the recording side of the line and leaves the ascertaining, advising and lodging to a registered agent.
This is also where "who does the lodging" becomes the practical test a business owner can apply without reading the statute. If a provider is preparing the numbers a registered BAS agent then reviews and lodges, that is bookkeeping support feeding a regulated service performed by someone else. If the provider itself is telling the business what its GST liability is and submitting the BAS, that provider needs to be on the TPB register — full stop, wherever it is located.
Location does not change the TASA line
CapEasy is an India-based provider: the bookkeeping work — transaction recording, reconciliation, payroll data entry, management reporting — is done by a team working from India, not from an Australian office. Nothing in TASA makes that arrangement different in kind from a business hiring an Australian-based bookkeeper who is not a registered agent. The Act regulates the act (ascertaining, advising, lodging) and who is registered to perform it, not where the desk the bookkeeping happens at is physically located.
What that means in practice for an outsourced engagement: CapEasy's bookkeeping work stops at the numbers. It does not ascertain what a client's BAS liability is, does not advise on what should be lodged, and does not lodge a BAS or deal with the ATO on a client's behalf. Those functions sit with the client's own registered BAS agent or tax agent — Australian-based, checkable on the TPB's public register — working from the reconciled books CapEasy provides. A client who wants a single point of contact handling both the bookkeeping and the BAS lodgment should confirm directly with their registered agent whether that agent reviews externally-prepared books before lodging, since that review step is where the ascertaining actually happens.
What offshore data handling actually has to satisfy
Moving a business's financial records to a provider outside Australia raises two separate compliance questions that outsourcing inside Australia does not: whether the records stay retrievable in the form Australian tax law requires, and whether personal information in those records is handled consistently with the Privacy Act.
On record-keeping, the ATO's rule does not require records to be physically stored in Australia — it requires that records be kept for the applicable period (generally five years), be in English or readily convertible to English, and be able to be produced within a reasonable time on request. A business using an offshore bookkeeping provider stays responsible for meeting that standard regardless of where the provider's servers or staff sit; the practical question to ask a provider is whether records are retained for the full period, backed up, and retrievable on short notice, not just whether they were entered accurately at the time.
On privacy, the Privacy Act 1988 and the Australian Privacy Principles (APPs) it sets out apply based on the business's own turnover, not the location of a service provider it uses — an entity with annual turnover above $3 million is covered regardless of who it outsources to, while most businesses under that threshold are not covered unless a specific exception applies (health service providers, for example, or a business that has opted in). For an APP-covered business, APP 8 specifically addresses cross-border disclosure of personal information: before sending personal information to an overseas recipient, the business generally has to take reasonable steps to ensure the overseas recipient does not breach the APPs, and in most cases remains accountable under the Act for what that recipient then does with the information. A business below the turnover threshold is not legally required to apply the APPs, but the APP 8 standard — reasonable steps, accountability for the recipient's handling — is a reasonable benchmark to hold any offshore provider to voluntarily, since it describes what "handling client data responsibly" concretely means rather than leaving it as a vague assurance.
Diligence questions worth asking before sending records offshore
None of the questions below are unique to an offshore provider — a business should ask most of them of any bookkeeping engagement — but they matter more when the answer involves records leaving the country, because there is no local office to walk into if something goes wrong.
- Who at the provider (if anyone) is a TPB-registered BAS or tax agent, and which specific tasks does that registration cover versus which tasks are bookkeeping support for the client's own registered agent
- How long are records retained, in what format, and can they be produced within a reasonable time if the ATO or the client requests them
- Who controls login credentials to the client's accounting software, banking feeds and payroll system, and are those credentials shared logins or individually attributable
- What access controls apply internally — is access to a client's file limited to the people actually working on it, and is that access removed when someone leaves the engagement or the company
- If the business is Privacy Act-covered (turnover above $3 million, or an opted-in or otherwise-covered entity), what reasonable steps has the provider taken to align its handling of personal information with the Australian Privacy Principles
- What happens to the data, and how quickly is it returned or deleted, if the business ends the engagement
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
Is it legal to outsource bookkeeping to a provider outside Australia?
Yes. Bookkeeping — recording transactions, reconciling accounts, processing payroll data, preparing reports — is not a regulated activity under Australian law, and the Tax Agent Services Act does not require the person performing it to be registered or based in Australia. Registration requirements attach to ascertaining or advising on a BAS liability and to lodging with the ATO, not to bookkeeping itself.
What does the Tax Agent Services Act actually restrict?
Section 90-10 of the TASA defines a "BAS service" as a service involving ascertaining or advising on liabilities, obligations or entitlements under a BAS provision, or representing an entity in dealings with the Commissioner of Taxation, where the entity can reasonably be expected to rely on it. Providing a BAS service for a fee while unregistered is a civil penalty offence under section 50-5.
Does my bookkeeper need to be a registered BAS agent?
Only if they are performing BAS services as defined in section 90-10 — working out what is owed, advising on it, or lodging on your behalf. A bookkeeper who records transactions and reconciles accounts, leaving the ascertaining and lodging to your registered agent, does not need to be registered for that recording work.
How do I check if someone is a registered BAS or tax agent?
The Tax Practitioners Board maintains a public register at tpb.gov.au that lists every currently registered tax and BAS agent, searchable by name or registration number, including whether a registration is current or suspended.
Does it matter that CapEasy is based in India rather than Australia?
For the TASA registration question, no — the Act regulates the act performed (ascertaining, advising, lodging) and who is registered to perform it, not the physical location of the provider. CapEasy is an India-based provider whose bookkeeping work stops at the numbers; a client's Australian-based registered BAS or tax agent handles the BAS ascertaining, advising and lodging.
Do my business records have to stay physically in Australia?
No. The ATO's record-keeping rule requires records to be kept for the applicable period, be in English or readily convertible, and be producible within a reasonable time on request — it does not specify where the records are physically stored or which country the provider maintaining them operates in.
Does the Privacy Act apply if my bookkeeper is offshore?
Whether the Privacy Act applies to your business depends on your own turnover (generally above $3 million) or a specific exception, not on whether you use an offshore provider. If your business is covered, Australian Privacy Principle 8 requires reasonable steps before disclosing personal information to an overseas recipient, and generally holds you accountable for what that recipient does with it.
What should I ask an offshore bookkeeping provider before signing up?
Who at the provider (if anyone) is TPB-registered and for which tasks; how records are retained and for how long; who controls login credentials to your accounting, banking and payroll systems; what internal access controls apply; and what happens to your data if you end the engagement.
Can an offshore provider lodge my BAS for me?
Only if the specific individual or entity performing that lodgment is registered with the Tax Practitioners Board — location does not exempt anyone from that requirement. A provider that is not TPB-registered can prepare the numbers a registered agent then reviews and lodges, but cannot lodge the BAS itself.
Who controls access to my accounting software if I outsource bookkeeping?
That is a question to put to any provider directly, not something the law standardises. Reasonable practice is individually attributable logins rather than one shared password, access limited to people actually working on the file, and access removed promptly when someone leaves the engagement.
Primary sources
- legislation.gov.au — Tax Agent Services Act 2009, section 90-10 (What is a BAS service)
- Tax Practitioners Board — TPB(I) 38/2023 What is a BAS service?
- Tax Practitioners Board — Public Register
- OAIC — Small business and the Privacy Act
- ATO — Overview of record-keeping rules for business
Last reviewed 2026-08-14. Statutes and schedules change — the sources above are authoritative, this page is orientation.
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