Registering as a tax agent or BAS agent: you first, then your practice

The individual pathways, in one paragraph

We will not reproduce the TPB's tables, because they change and the TPB keeps them current. At a summary level, as at October 2026: a BAS agent needs at least a Certificate IV in accounting or bookkeeping, a Board-approved course in basic GST/BAS taxation principles, and relevant experience of 1,400 hours in the past four years, or 1,000 hours if they are a voting member of a recognised BAS agent association. A tax agent pathway depends on the qualification: a degree or postgraduate award in accounting plus Board-approved courses in Australian taxation law and commercial law, with the equivalent of 12 months' full-time relevant experience in the past five years, is the common route; a diploma needs two years; the association membership route needs eight years in the past ten. Read the TPB's qualifications and experience pages for the version that applies on the day you apply.

The practice point inside that paragraph is the word relevant. Experience counts when it involves substantial work in tax agent or BAS services, and where it was gained under a registered agent's supervision and control, that agent verifies the applicant's statement of relevant experience and comments on their competence. The TPB also asks whether the supervision was adequate. If you employ people who intend to register, the hours they log in your firm are only useful to them if your supervision would stand up to that question. That is a reason to write down who supervises whom, which the Code now expects anyway.

Sufficient number is where growing firms trip

The TPB will not give you a ratio, and that is deliberate. It looks at the size of the practice, the kind of work, and whether the registered individuals you nominate can realistically provide and supervise the services. A two partner firm with five juniors and one registered partner is a different answer from the same firm with twenty juniors and the same one partner.

Three practical consequences follow. First, the nominated people must consent in writing before you name them, so keep the signed statements on file. Second, if a nominated agent leaves, retires or loses registration, your sufficient number can fall to zero overnight, which is why a one-registered-person company should have a plan for that person's absence. Third, sufficient number is tested at renewal, and renewal is now every year, so a headcount change that would once have waited three years for scrutiny now meets it within twelve months.

Professional indemnity insurance: the TPB floor

Registered tax and BAS agents must hold PI insurance that meets the TPB's requirements for the whole period of registration, and must show it at renewal. As at October 2026 the TPB's minimum cover, inclusive of legal and defence costs, is set by the practice's turnover from tax agent or BAS services:

Two details matter for how you buy the policy. The TPB caps the excess at 4% of turnover, or $1,000 where 4% of turnover would be less than that. And it recommends run-off cover if you stop providing services, because claims about old work arrive after the policy that was in force at the time has lapsed.

The TPB figure is a floor, not a recommendation. Professional bodies set their own minimums for members in public practice, and they are usually higher: CPA Australia, for example, states a $2 million minimum for members providing public accounting services in Australia. Our guide to professional indemnity insurance for accountants covers what the policy does and does not respond to, and how claims tend to arise.

CPE: an annual habit, not a three-yearly scramble

The TPB's continuing professional education policy, as at October 2026, is 120 hours over three years for tax agents and 90 hours over three years for BAS agents, with at least 20 hours in every year. The move to annual registration left those numbers alone. What it changed is how often someone asks.

For a practice, CPE is a staff-planning item. Every registered individual in your sufficient number has to keep their own CPE current, and the activities must be relevant to the services they provide. A partner who has spent three years on advisory work and logged nothing on the tax law their juniors are applying is a supervision risk as well as a CPE risk. Most firms handle this with a simple register: who is registered, their renewal date, their CPE hours to date, and whose work they supervise.

The Code, as it lands on the way a firm runs

The Code of Professional Conduct in the Tax Agent Services Act has always covered honesty, independence, confidentiality and competence. The Tax Agent Services (Code of Professional Conduct) Determination 2024 added further obligations under Code item 17, applying from 1 January 2025 for practitioners with more than 100 employees and from 1 July 2025 for everyone else. Several of them read as practice-management rules rather than ethics:

• False or misleading statements. You must not make or prepare a statement you know, or ought reasonably to know, is false or misleading in a material particular, including by omission. That is a review standard, and it applies to work your staff prepare.
• Supervision, competency and quality management. The TPB's guidance (TPB(GS) 53/2024) expects supervisory arrangements and quality management that fit the size of the practice. A written review process is the easiest way to show one exists.
• Conflicts and confidentiality in dealings with government. Firms that also advise government bodies now need a way to identify and manage those conflicts.
• Keeping clients informed. Section 45 of the Determination requires you to tell current and prospective clients, in writing, about matters including the TPB register and how to complain to the TPB. That belongs in your engagement documents and onboarding, not in a partner's memory.

If your firm uses AI tools on client work, the false-or-misleading and supervision obligations are where that use meets the Code. Our piece on why a firm needs an AI policy covers how to write that down.

What changed under the recent reforms

The TPB regime has moved more in the last two years than in the decade before it. The changes that matter for running a practice, as at October 2026:

• Annual registration. Registrations granted or renewed from 1 July 2024 last one year, not three. Anyone who renewed before that date runs out their three years, and their next renewal moves to annual. The annual declaration has been retired.
• Breach reporting. From 1 July 2024, registered agents must report their own significant breaches of the Code to the TPB, and report another practitioner's significant breach to the TPB and that practitioner's recognised professional association, within 30 days of having reasonable grounds to believe it happened. A significant breach includes one that is an indictable offence or involves dishonesty, or one that could cause material loss.
• The new Code obligations described above.
• Bigger penalties and powers. Our coverage of the TPB's expanded penalty powers sets out what changed and who it reaches.

Breach reporting is the one that changes firm behaviour most. It needs an internal route for staff to raise a possible breach, someone who decides whether it is significant, and a clock that starts when the firm ought to have known, not when a partner gets round to it. For the dates that land on a practice over the next year, see our compliance deadlines calendar.

A one-page registration file

Everything above reduces to a short file the practice keeps current, because the TPB can now ask for it every twelve months:

• Each registered individual, their registration number, type, renewal date and CPE hours to date.
• The practice entity's registration, its nominated sufficient number and their signed consents.
• The PI policy schedule, the turnover it was based on, the excess, and who it covers.
• Who supervises whom, and how work is reviewed before it is lodged.
• The breach reporting process: who decides, and how the 30 days is tracked.

None of it is complicated. All of it is easier to keep up than to rebuild in the 30 days before a renewal closes.