What a BAS agent does, and how to become one
A BAS agent is registered with the Tax Practitioners Board (TPB) to handle a client's GST, PAYG and other BAS obligations for a fee. That means working them out, advising on them and dealing with the ATO. To register you need at least a Certificate IV in bookkeeping or accounting, a Board-approved GST/BAS course and 1,400 hours of relevant experience in the past four years. A BAS agent can't prepare income tax returns. That takes a tax agent.
Below: how a bookkeeper, a BAS agent and a tax agent differ, what registration takes and costs, and what it means for firms with offshore bookkeepers.
Serkan Honeine, Co-founder, CoSauce
Published · Last updated
What counts as a BAS service
The Tax Agent Services Act 2009 defines a BAS service in section 90-10. It is working out or advising on a client's obligations or entitlements under a BAS provision, or representing the client to the Commissioner about one. It only counts where the client can reasonably be expected to rely on it (TPB, BAS services). The BAS provisions include the GST law, the fuel tax law and the PAYG parts of the Taxation Administration Act. FBT is in only for collection and recovery.
Anyone who provides BAS services for a fee must be registered unless an exemption applies. The Federal Court can impose penalties of up to 250 penalty units for an individual and 1,250 for a body corporate for doing it unregistered. Advertising BAS services while unregistered carries up to 50 and 250 penalty units (TPB, who needs to register). A penalty unit has been $364 since 1 July 2026 (Crimes Act penalty unit instrument), so that's up to $91,000 and $455,000, or $18,200 and $91,000 for advertising. The TPB's pages still show the old $330 unit, which gives $82,500 and $412,500.
Tax agent vs BAS agent vs bookkeeper
The TPB publishes two lists of examples, one for BAS services and one for tax agent services (TPB, tax agent services). Every BAS service is also a tax agent service, so a tax agent can do all of it. An unregistered bookkeeper can do the work that doesn't apply a BAS provision. This table pulls a few rows from each list.
| Work done for a fee | Unregistered bookkeeper | BAS agent | Tax agent |
|---|---|---|---|
| Bank reconciliations | Yes | Yes | Yes |
| Coding invoices under the instruction and supervision of a registered agent | Yes | Yes | Yes |
| Setting up default GST codes for a client in their software | No | Yes | Yes |
| Completing an activity statement, or confirming its figures | No | Yes | Yes |
| Payroll that applies tax law, including Single Touch Payroll | No | Yes | Yes |
| Super guarantee charge statements, TPAR, GST registration | No | Yes | Yes |
| Income tax returns, objections, FBT advice, depreciation schedules | No | No | Yes |
One row trips people up. Bank reconciliations are fine for anyone. Using them to work out the figures that go on an activity statement is a BAS service.
The two registrations also differ in what it takes to get in. Most tax agent routes need a diploma or a degree plus 12 months to two years of experience. The others need eight years of experience in the past ten (TPB, tax agent requirements).
How to become a BAS agent
To register as an individual BAS agent you must (TPB, BAS agent registration; TPB, qualifications and experience):
- Be at least 18.
- Hold a Certificate IV Financial Services in bookkeeping or accounting, or a higher award, from a registered training organisation or equivalent.
- Complete a Board-approved course in basic GST/BAS taxation principles. It must cover the Tax Agent Services Act and the Code of Professional Conduct, or you take a separate unit that does. The course can sit inside your Certificate IV.
- Show 1,400 hours of relevant experience in the past four years, or 1,000 hours if you're a voting member of a recognised BAS or tax agent association.
- Be a fit and proper person.
- Hold, or be able to hold, professional indemnity insurance that meets the TPB requirements.
Relevant experience means substantial involvement in BAS services. Work as a registered agent counts, and so does work under the supervision and control of one. Most work preparing a business's books for its BAS, including PAYG withholding and instalments, counts. Payroll tax returns don't, because payroll tax is a state tax. Simulated work programs can make up no more than 15% of the hours (TPB, relevant experience). You prove the hours on a statement of relevant experience, and a supervising agent has to verify it and comment on your competence.
The fit and proper test looks at your character. The TPB must also weigh certain events in the past five years. These include a conviction for a serious taxation offence or for fraud, undischarged bankruptcy and a prison sentence (TPB, fit and proper).
You apply online through the TPB's My Profile, with Australian identity documents, your transcripts and your experience statements.
What it costs, and how long it takes
The TPB lists the application fee for an individual BAS agent at $58, not subject to GST, with a CPI adjustment each 1 July. A tax agent's fee is $290. The fee isn't refunded if the application is invalid, unless you withdraw within 30 days and before a decision. The TPB aims to process a complete application within 30 days, and says it can take up to 60 when volumes are high (TPB, BAS agent registration).
The bigger cost is insurance. If you charge for BAS services you need your own PI cover: at least $250,000 for turnover up to $75,000, $500,000 up to $500,000, and $1 million above that. The excess shouldn't be more than 4% of turnover. An employee or contractor who doesn't charge a fee needs no policy of their own, but must name their employer and its registration number (TPB, PI insurance). The TPB doesn't publish premiums, so ask a broker.
Registration lasts at least one year, and you apply to renew between 90 and 30 days before it expires (TPB, renewing). On a standard registration you need 90 hours of continuing professional education over three years, with at least 20 in each year. If your registration runs for a period other than three years, the hours are pro rata. No more than 25% can be reading (TPB, CPE).
A worked example
Say your bookkeeper already holds a Certificate IV that includes the GST/BAS course, and spends two days a week on BAS work under your registered agent. At 7.6 hours a day that's 15.2 hours a week, so 1,400 hours takes about 92 weeks, or a little under two years. If they join a recognised association as a voting member, the 1,000-hour route takes about 66 weeks. Add the $58 fee, up to 60 days for a decision, and PI cover before they charge any client in their own name. These are our assumptions, and the TPB decides what counts.
How to check if a BAS agent is registered
Search the TPB register. It lists registered tax and BAS agents, and any Code breaches and sanctions on the public record. Once someone is registered, the TPB tells the ATO. The agent can then set up Online services for agents. The ATO says that system is for "registered tax and BAS agents and their authorised staff" (ATO, Online services for agents).
What it means if you use outsourced or offshore bookkeepers
Your offshore bookkeeper usually doesn't need to be a registered BAS agent, as long as your firm is the registered agent providing the service. The exemption covers an employee or contractor of a registered tax or BAS agent who doesn't provide BAS services in their own right. The TPB takes the same line on labour hire. A provider is unlikely to need registration when a registered entity provides the BAS service and directs the people (TPB, BAS services).
That puts the weight on your supervision. Signing a client declaration that wasn't prepared under your supervision and control is a civil penalty breach. The penalty is up to 250 penalty units for an individual agent and 1,250 for a company or partnership (TPB, supervision and control). At the $364 unit, that's $91,000 and $455,000. The TPB names offshoring as a remote supervisory arrangement and asks how often you're in contact, how documents are reviewed and whether you can audit the work remotely. The Code items and the client consent rules are covered in what stays onshore when you offshore accounting, and the buying options in how outsourced bookkeeping works in Australia.
In practice, our people in South Africa work on named logins inside your own software. Your registered agent reviews and lodges, and we look at the work with you in a weekly review. That review loop is set out in how we work.
Questions
Can a bookkeeper lodge a BAS without being registered?
Not for a fee. Completing an activity statement for a client, or telling them which figures to use, is a BAS service. A business can still lodge its own BAS, and an unregistered bookkeeper can do the data entry and bank reconciliations behind it.
Can a BAS agent do tax returns?
No. Preparing and lodging income tax returns is a tax agent service, and so is advice on FBT law beyond collection and recovery. A BAS agent covers GST, PAYG, super guarantee, payroll and the other BAS provisions.
Next step
If you're a BAS or tax agent and your team is stretched, book a call with me. Tell me which BAS work you'd hand over and how you review it today. We'll talk through how our outsourced bookkeeping, the Offshore finance desk, would sit under your registration. If it's not a fit, I'll tell you.