What the TPB Code requires you to tell clients in writing, where it should appear, how ID checks and records fit, and how reminders keep clients on time.
Key takeaways
- Section 45 lists five things every current and prospective client must be told in writing.
- Put the information on your website and in engagement letters. The factsheet alone does not satisfy it.
- Client records and proof of identity records are kept for at least five years.
- Collect identity through a secure channel, never by email.
What must you tell new and existing clients under section 45?
The TPB Code Determination section 45 obligation, “keeping clients informed”, requires you to tell current and prospective clients in writing about:
- The TPB register, and how they can search it.
- How to make a complaint, including to the TPB.
- Their rights and obligations, and yours.
- Any prescribed events affecting you in the last five years.
- Any conditions on your registration.
Prescribed events must be disclosed to existing clients within 30 days (TPB FAQs on the Code Determination, last modified 31 March 2025).
These obligations came from the 2024 Code Determination, which started on 1 January 2025 for practices with more than 100 employees and on 1 July 2025 for practices with 100 or fewer (TPB, 19 May 2025). The TPB keeping clients informed requirements now apply to every registered practice.
Is the TPB factsheet enough on its own?
No. The TPB’s factsheet helps, but the TPB says the factsheet alone does not meet the obligation. You also need to give the information yourself (same FAQ page).
Where should this information appear: website, engagement letter, or both?
Both is the safe answer. The TPB lists publishing the information on your website and including it in engagement and re-engagement letters as ways to comply, alongside giving clients the factsheet.
Engagement letter TPB disclosures work well as a standard section, so every new engagement carries the same text. The website version gives prospective clients the information before they sign, and keeps one place to update if a condition or prescribed event changes.
A short section on your website can cover:
- A link to the TPB register and your registration number.
- How to complain to you, and how to complain to the TPB.
- A plain summary of your obligations and the client’s.
- A statement on prescribed events and registration conditions, updated if anything changes.
What has to go into client records under section 30?
Section 30 requires records showing the nature, scope and outcome of each service, and all advice given and received. Tax agent client records 5 years is the minimum retention period (TPB FAQs).
The TPB also says you should keep your record of the proof of identity check, not the identity documents themselves.
How do you collect client ID securely without email?
Proof of identity tax practitioner obligations require the check to be done before you provide services to a new client. The TPB recommends a checklist that records the date and time, the document types, how they were sighted and who did the check, kept for five years after the engagement ends. It advises against requesting identity documents by email (TPB, last modified 11 February 2025).
Email is a poor place for identity documents and tax file numbers. Tax practitioners covered by the Privacy Act must also follow the Notifiable Data Breaches scheme, and the TPB may treat reckless handling of client data as a breach of the Code’s confidentiality obligation (TPB).
Use a client portal or onboarding tool with access controls, and record the check on the client’s file.
If the engagement is also a designated service under AML/CTF tranche 2, the AUSTRAC due diligence steps apply on top. Our guide to tranche 2 client onboarding covers how the two fit together.
How do reminders keep clients on track for lodgment program dates?
Clients miss documents because nobody asked at the right time. Lodgment program reminders tied to each client group make the asking routine.
The ATO’s current program for individuals and trusts sets these key dates (ATO, updated 1 July 2026):
| Due date | Who it applies to |
|---|---|
| 31 October 2026 | Clients with prior-year returns outstanding at 30 June 2026 |
| 31 March 2027 | Clients whose latest return showed a tax liability of $20,000 or more |
| 15 May 2027 | All remaining clients |
| 5 June 2027 | Concession date, if payment is also made by then |
A reminder four to six weeks before each date, with the document checklist for that client, does most of the chasing for you. A second reminder two weeks out catches the rest.
Accounting practice software such as LYD Accrual OS covers this front office work: client onboarding, document requests and automated deadline and lodgment reminders, beside the practice management software that runs your jobs.
Who builds this for accounting practices?
Launch Your Dream, by Sharktech Global, builds LYD Accrual OS for accounting and bookkeeping practices, up and running within 7 working days of receiving your onboarding details. Open the live demo or book a free 30 minute discovery call.
General information only, not legal or professional advice. Check the TPB and ATO for current requirements and dates.
Common questions
- Is the TPB factsheet enough on its own?
- No. The TPB says the factsheet helps, but you also need to give the information yourself, for example on your website and in engagement and re-engagement letters.
- When did the new Code obligations start for small practices?
- 1 July 2025 for practices with 100 or fewer employees. Larger practices started on 1 January 2025.
- How quickly must I tell clients about a prescribed event?
- Existing clients must be told within 30 days of the event.
- Can I ask clients to email their ID?
- The TPB advises against requesting identity documents by email. Use a secure channel and keep a record of the check rather than the documents.
- How long do client records need to be kept?
- At least five years, covering the nature, scope and outcome of each service and the advice given and received.