Australia / Guides / Who can legally do your books and your BAS in Australia: the gate map
Australia · guideWho can legally do your books and your BAS in Australia: the gate map
The short answer
Three tiers, three different legal requirements. Anyone can record transactions, reconcile accounts, and run payroll for a fee — no licence needed. Ascertaining, advising on, or lodging a BAS-related liability (GST, PAYG withholding, PAYG instalments, and related BAS provisions) for a fee requires registration as a BAS agent with the Tax Practitioners Board (TPB) under s.90-10 of the Tax Agent Services Act 2009 (TASA). Doing the same for income tax requires the broader tax agent registration under s.90-5. The gate is on what activity is performed and whether a fee is charged for it, not on the job title on the invoice — and it is checkable in a few minutes on the TPB's public register.
Key facts — verified dates on each
The three tiers, at a glance
TASA 2009 does not license "bookkeeping" as a profession, and it does not require a business to hire anyone to keep its own records. What it licenses is two specific categories of paid work — BAS services and tax agent services — each requiring registration with the Tax Practitioners Board (TPB) before anyone can charge a fee for them. Everything else — data entry, reconciliation, payroll processing, coding transactions to instructions already given — sits outside both categories and can be done by anyone, registered or not, including the business itself.
The three tiers map onto three questions a business actually asks. "Can I do this myself?" is almost always yes, because the Act regulates providers, not businesses. "Can my bookkeeper do this?" depends entirely on what "this" is. "Is this person actually allowed to charge me for BAS or tax advice?" is answered by one check: their name against the TPB's public register.
- Tier 1 — Unregistered bookkeeping: recording transactions, bank reconciliation, coding to instructions already given, payroll processing. No TPB registration required. Anyone, including the business itself, can do this for a fee.
- Tier 2 — BAS agent services: ascertaining or advising on a BAS-related liability (GST, PAYG withholding, PAYG instalments, FBT instalments, fuel tax credits, super guarantee matters), or lodging a BAS, for a fee. Requires TPB registration as a BAS agent under TASA s.90-10.
- Tier 3 — Tax agent services: the same ascertaining/advising/lodging activity, extended to income tax and taxation law generally. Requires the broader TPB registration as a tax agent under TASA s.90-5.
Which guide answers your question
The line between the tiers is drawn by the activity performed and whether a fee is charged for it — never by job title, business card, or years of experience. The section-by-section statutory breakdown of exactly where that line sits lives in the bookkeeper-vs-BAS-agent-vs-tax-agent guide; this page stays at the map level.
A business asking "who can do this for me" is really asking where one specific task sits on the map above. Each scenario below routes to the guide with the full answer.
- Doing your own books and BAS yourself — always available; no tier applies, since TASA regulates the provider side of a paid transaction, not a business acting for itself. See DIY bookkeeping in Australia.
- Engaging someone just to record transactions and reconcile accounts — Tier 1, no registration check required. See outsourced bookkeeping in Australia.
- Engaging someone to ascertain, advise on, or lodge a BAS-related liability — Tier 2; confirm TPB BAS-agent registration before the work starts, not after. See do I need a BAS agent, can I lodge my own BAS, can a bookkeeper lodge a BAS, and who can charge for BAS services.
- Engaging someone for income tax preparation, lodgment, or advice — Tier 3; confirm a tax-agent registration specifically, since BAS-agent registration alone doesn't cover it. See do I need a tax agent or accountant.
Confirming registration — and what's at stake
Because the tier someone operates in is determined by what they do rather than what they call themselves, the only reliable way to confirm Tier 2 or Tier 3 authorisation is the TPB's public register, searchable by legal name, registered business name, or TPB registration number — it shows current status, expiry date, and any conditions or sanctions on record.
One consequence worth keeping separate from the registration question itself: the ATO's "safe harbour" protection from penalties for a preparer's genuine error is only available if the client engaged a registered tax or BAS practitioner for the work in question. A business that relies on an unregistered person for Tier 2 or Tier 3 work forfeits that protection even if it never intended to break the registration rule itself.
Where CapEasy sits on the map
CapEasy's Australian service sits entirely in Tier 1.
- Coding transactions, reconciling accounts, and processing payroll — done by a named team member using CapEasy's AI-assisted systems, not an AI system acting on its own.
- CapEasy does not ascertain or advise on a GST, BAS, or income tax liability, and does not lodge a BAS, IAS, or income tax return.
- Tier 2 or Tier 3 work needs a TPB-registered BAS agent or tax agent, engaged separately — the same firm if it holds the relevant registration, or a different one; either is legal as long as the person doing that specific work is actually registered for it.
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
What are the three legal tiers of bookkeeping and BAS work in Australia?
Unregistered bookkeeping (recording, reconciling, coding to instructions given, payroll — no registration needed); BAS agent services (ascertaining, advising on, or lodging a BAS-related liability for a fee — needs TPB registration as a BAS agent); and tax agent services (the same for income tax — needs the broader TPB tax-agent registration).
Does a business need to hire anyone to do its own books or BAS?
No. The Tax Agent Services Act 2009 regulates people providing BAS or tax agent services to someone else for a fee — it does not require a business to outsource any of that work. A business can always record its own transactions and lodge its own BAS.
Which guide explains exactly where a bookkeeper's job ends and a BAS agent's job begins?
The bookkeeper vs BAS agent vs tax agent guide — it walks through the TASA s.90-5 and s.90-10 definitions section by section, with examples of where routine coding tips over into ascertaining or advising on a liability.
Which guide tells me whether my business actually needs a BAS agent?
Do I need a BAS agent — it covers when a business can stay entirely on the DIY or Tier 1 side of the map, and when the work in front of it has already crossed into BAS-service territory.
Can I lodge my own BAS instead of engaging a BAS agent?
Yes — self-lodging is always available to a business acting for itself, since TASA regulates providers, not the business. See can I lodge my own BAS in Australia for what that involves in practice.
Can my bookkeeper lodge my BAS if they aren't a registered BAS agent?
No. Lodging a BAS for a fee is Tier 2 work under s.90-10, so it requires TPB BAS-agent registration regardless of how much of the surrounding bookkeeping the same person already does. See can a bookkeeper lodge a BAS for the detail.
Do I need a registered tax agent, or would an accountant do?
It depends on whether the work is a "tax agent service" under s.90-5 — see do I need a tax agent or accountant for how that distinction plays out for a typical small business.
Where does CapEasy sit across these three tiers?
Tier 1 only — coding transactions, reconciling accounts, and processing payroll for Australian clients. CapEasy does not ascertain or advise on a BAS or income tax liability and does not lodge a BAS, IAS, or tax return; that Tier 2 or Tier 3 work sits with the client's registered BAS agent or tax agent.
Primary sources
- Federal Register of Legislation — Tax Agent Services Act 2009, s.90-5 (Meaning of tax agent service), s.90-10 (Meaning of BAS service), s.50-5 (Civil penalty)
- Tax Practitioners Board — BAS services (what is and is not a BAS service)
- Tax Practitioners Board — Public Register
- Tax Practitioners Board — Risks of using unregistered preparers
Last reviewed 2026-08-16. Statutes and schedules change — the sources above are authoritative, this page is orientation.
Want this handled rather than read about?
A scoping call decides what fits. We are a consulting firm — lodgments and agent work run through registered BAS and tax agents. Whoever signs and files stays yours.