TPB quality management system requirements for Australian tax agents

When did the TPB quality management requirements commence?

The additional Code obligations commenced on 1 January 2025 for larger registered tax practitioner firms that had more than 100 employees at the relevant measurement date.

For registered tax practitioners with 100 or fewer employees, the obligations commenced on 1 July 2025.

All registered tax practitioners are now required to comply with the applicable quality management obligations.

The requirements are not limited to CPA or CA practices. They apply because the person or entity is registered with the Tax Practitioners Board and provides tax agent or BAS services.

What is a tax agent quality management system?

A quality management system is the collection of policies, procedures, responsibilities and controls used to support compliance with the Code of Professional Conduct.

The system should reflect the size, structure, services, clients and operating risks of the practice. A sole practitioner will not require the same level of documentation as a national firm, but both must have a system that is suitable for their circumstances and operating in practice.

The TPB identifies a range of matters that may be addressed within the system, including:

• Governance and leadership
• Monitoring performance
• Compliance with the Code of Professional Conduct
• Client engagement and acceptance
• Proper recordkeeping
• Protection of confidential information
• Management of conflicts of interest
• Recruitment, training and management of employees
• Competence and supervision of people providing services on the practitioner's behalf

The system should not be treated as a policy manual that is prepared once and then forgotten. It should operate across real engagements and be updated when the practice, its services or its risks change.

The difference between documenting and enforcing the system

The quality management obligation has two important parts.

First, the practice must document its policies and procedures. This creates a clear record of how the firm intends to manage quality and comply with the Code.

Second, the practice must enforce those policies and procedures. The firm should be able to demonstrate that its documented processes are actually followed by partners, managers, employees and contractors.

For example, a policy may require every company tax return to be reviewed before lodgement. Evidence should show that the review occurred, what matters were identified, how those matters were resolved and who completed the final sign-off.

Taxpartna can support this evidence by providing a structured review output for the practitioner's consideration. The firm should also document the practitioner's decisions, follow-up work and final approval.

Quality management and competent tax agent services

Registered tax practitioners must ensure that tax agent services provided on their behalf are provided competently.

This includes work performed by employees, contractors, offshore teams and other people engaged by the practice. The required level of supervision will depend on the person's knowledge and skills, the nature and complexity of the work and the controls operating within the firm.

A quality management system should explain:

• Which work may be delegated
• The experience required for different tasks
• How work is allocated
• What supervision is provided
• When technical consultation is required
• Which engagements require manager or partner review
• How review points are communicated and resolved
• Who is authorised to approve the final output

Technology can support these arrangements, but it does not remove the need for appropriately qualified people and professional oversight.

How Taxpartna supports tax return review procedures

Reviewing tax return preparation work is an important control within many tax practices.

A reviewer may need to compare a tax return with financial statements, tax reconciliations, workpapers, elections, resolutions, agreements and other supporting documents. Important issues can be missed when each document is reviewed separately or when the reviewer is under time pressure.

Taxpartna reviews the documents relating to the tax engagement as a connected set and identifies matters that may require further attention. Depending on the entity and documents supplied, the platform can assist with checks involving:

• Taxable income reconciliations
• Division 7A loans and minimum yearly repayments
• Trust distributions and beneficiary information
• Section 100A risk indicators
• Base rate entity eligibility
• Capital gains tax calculations
• Franking accounts and dividend information
• Personal services income
• Carried-forward tax losses
• Related-party balances and transactions
• Repairs and capital expenditure
• Financial statement and tax return consistency
• Missing or incomplete supporting documents

The platform flags matters for the registered tax practitioner to assess. It does not determine the final tax position, provide tax advice to the client or lodge the tax return.

How Taxpartna supports supervision

Supervision is more effective when the reviewer can see what was checked, what was identified and what still requires attention.

Taxpartna provides a consistent review format across tax engagements and team members. This can assist managers and partners supervising work prepared by junior accountants, remote staff, contractors or offshore teams.

The review output can help the supervisor:

• Direct attention to exceptions and higher-risk matters
• Identify missing workpapers or supporting documents
• Give clearer review feedback to the preparer
• Confirm that required follow-up work has been completed
• Recognise recurring errors or training needs
• Retain evidence of the review process

The responsible tax practitioner must still consider the client's circumstances, apply the taxation law and complete the professional sign-off.

How Taxpartna supports recordkeeping

Proper recordkeeping is part of an effective quality management system and a separate professional obligation for tax practitioners.

The tax engagement documentation should provide sufficient information to understand the work performed, the significant matters considered and the basis for the final output.

Review evidence can be difficult to follow when it is spread across handwritten notes, email chains, workpaper comments and conversations between team members.

Taxpartna produces a structured record of the automated checks performed and the matters identified for review. This can support the tax engagement documentation by showing:

• The documents considered by the platform
• The checks applied to the tax return and supporting workpapers
• The inconsistencies or missing information identified
• The matters referred for professional assessment
• The areas requiring clarification or additional work

The firm should separately retain evidence of how the identified matters were resolved and who approved the final tax position.

Monitoring performance and recurring issues

A quality management system should help the firm identify whether its procedures are operating effectively.

Individual engagement reviews can reveal broader patterns within the practice. Repeated issues may indicate that a workpaper template is incomplete, a procedure is unclear or a team member requires further training.

Consistent Taxpartna reviews can assist a firm to identify patterns such as:

• Recurring tax reconciliation differences
• Incomplete Division 7A workpapers
• Missing trust distribution documents
• Inconsistent treatment of related-party balances
• Unsupported capital gains tax calculations
• Common omissions in company or trust tax engagements

The firm can use this information to improve templates, update procedures, deliver targeted training and monitor whether the changes reduce the frequency of the issue.

Protecting confidential client information

Tax returns, workpapers and supporting documents contain sensitive personal and financial information. A quality management system should address how that information is collected, accessed, processed, retained and protected.

Taxpartna uses a private self-hosted model environment developed for tax quality assurance. Client documents are not submitted to a publicly available LLM chatbot for general model training.

The firm must still assess its own privacy, confidentiality and information security obligations. Its policies should identify which systems are approved, who may submit client documents, what access controls apply and how long information is retained.

For more information, see Why Taxpartna uses a private self-hosted LLM for sensitive tax documents.

How TPB requirements interact with CPA and CA quality management obligations

The TPB quality management system requirements operate alongside the professional standards applying to CPA Australia and CA ANZ members in public practice.

Registered tax practitioners must establish, maintain, document and enforce a quality management system that provides reasonable confidence that they are complying with the Code of Professional Conduct.

CPA and CA practices may also be required to maintain a system of quality management under APES 320 Quality Management for Firms that provide Non-Assurance Services. CPA Australia and CA ANZ can review whether members have appropriate policies, procedures and supporting evidence in place.

There is considerable overlap between these requirements, including governance, engagement performance, staff competence, supervision, recordkeeping, confidentiality, monitoring and remediation. However, compliance with one framework should not automatically be treated as compliance with every other applicable obligation.

Taxpartna can support the practical operation and documentation of tax return review procedures within these frameworks. It does not replace the firm's complete quality management system or guarantee compliance with TPB, CPA Australia, CA ANZ or APESB requirements.

For further information, see CPA and CA quality assurance requirements for Australian accounting firms.

What Taxpartna does not replace

Taxpartna is a tax quality assurance assistance platform. It does not replace:

• The firm's documented quality management system
• The registered tax practitioner's professional judgment
• Appropriate supervision of staff and contractors
• Technical training and continuing professional education
• Client acceptance and continuance procedures
• Conflict-of-interest processes
• Privacy and information security controls
• Consultation on complex or contentious tax matters
• Final review and sign-off by the responsible practitioner

The firm should document how Taxpartna fits within its procedures, including when it is used, who reviews the results, how flagged matters are resolved and what evidence is retained.

Building a stronger tax quality management system

A quality management system should help the firm deliver competent and ethical tax services on every engagement.

Taxpartna gives Australian tax practices a consistent way to review tax returns, workpapers and supporting documents before final sign-off. It can help strengthen engagement review, supervision, documentation and monitoring while allowing the registered tax practitioner to remain in control.

The technology performs detailed checks. The practitioner considers the results, resolves the issues and makes the professional decision.

Related Taxpartna resources

• CPA and CA quality assurance requirements for Australian accounting firms
• Tax quality assurance software for Australian accounting firms
• Tax return review software
• Tax workpaper review software
• Taxpartna security and data protection
• Join the Taxpartna beta

See Taxpartna support your quality management procedures

Discover how Taxpartna can operate within your tax practice's quality management and supervision procedures.

Frequently asked questions

Authoritative references

• TPB: Complying with the Code Determination
• TPB: Supervision, competency and quality management
• TPB: Code of Professional Conduct
• TPB: Quality management systems factsheet

This page provides general information. Before publication, confirm the legislative and TPB references remain current. Do not represent Taxpartna as providing legal advice or guaranteeing compliance with the Tax Agent Services Act 2009, the Code of Professional Conduct or the Code Determination.