Bookkeeper vs BAS Agent vs Accountant: Who Can Do What

The short answer: the legal line follows the registration, not the job title

A bookkeeper keeps the day-to-day records. A registered BAS agent can work out and lodge business activity statements (BAS) for a fee. A registered tax agent can do that work as well, and can also prepare and lodge tax returns for a fee. In the bookkeeper vs accountant question, the difference is registration, not title. The Tax Practitioners Board (TPB) registers tax agents and BAS agents, and accountants who charge for tax agent services must be registered as tax agents.

The business.gov.au checklist for setting up finances describes the three roles by the work they do. A bookkeeper keeps track of day-to-day transactions, looks after banking, chases overdue payments, pays wages and prepares some financial statements. An accountant helps with preparing financial statements, managing tax, and financial and business advice. A BAS agent helps prepare and lodge the BAS.

Those descriptions overlap, so a title alone does not tell an owner who may do what. The rest of this guide sorts the work task by task. It is general information only. A decision about your own tax affairs depends on your circumstances and is one for a registered tax agent.

Who may do what for a fee

The table below sets out common tasks using the TPB's published examples of BAS services and tax agent services. The TPB says its lists are non-exhaustive, and the facts of a job can change the answer. In the table, "Yes" means the role may do the task for a fee, assuming no condition on a practitioner's registration limits that work, and "No" means the role may not. "Yes, for BAS services" means the role may do the task only where it is a BAS service, and "May need tax agent registration" means a BAS agent may need to be a registered tax agent in relevant circumstances.

The table above describes people selling services to clients. According to the TPB, unregistered entities providing tax agent or BAS services for a fee or other reward, advertising those services, or representing that they are registered face civil penalties and, since 1 October 2026, criminal penalties of up to 40 months imprisonment or 200 penalty units, or both, for each offence. The TPB says maximum civil penalties have also increased.

The penalties have exemptions. The TPB says exceptions apply to certain services provided by legal practitioners, customs brokers and voluntary services. It also says the civil penalty provisions do not apply to an employee providing tax agent or BAS services to their own employer for a salary, wage or other benefit, and that employees of a registered tax or BAS agent are not necessarily required to be registered themselves.

The TPB's table of tax agent services also marks some services as not being tax agent services. They include general tax advice that is not applied to a client's personal circumstances, and advice on state or territory taxes and duties.

The test behind the table: can the client reasonably rely on the work?

Whether a task is a BAS service is a question of fact, and reliance is one of the required elements, so the name of the task does not settle it. Under the Tax Agent Services Act definition set out by the TPB, a BAS service involves working out or advising on obligations under a BAS provision, or representing a client to the Commissioner of Taxation, where the client can reasonably be expected to rely on the service. The Act also treats some other services as BAS services, including applying for an ABN and lodging the Taxable payments annual report.

The TPB's guidance statement on BAS services lists factors for judging reliance. They include whether the provider has to interpret or apply a BAS provision, and whether the client or someone else checks the work before relying on it.

Coding shows the reliance test in practice, which is why the task table lists it twice. Coding that requires a BAS provision to be interpreted is a BAS service. Coding done under the instruction and supervision of a registered tax or BAS agent is not. An unregistered bookkeeper can therefore do coding work for a business when a registered agent is instructing and supervising it.

A registered BAS agent can lodge BAS, but not income tax returns

A registered BAS agent can provide the BAS-related services in the table for a fee, but the TPB says these agents can only provide some of the services that tax agents can. Its tax time guidance is direct: only registered tax agents can legally prepare and lodge tax returns on behalf of clients. The TPB also notes that a BAS agent's authority to act is limited to dealing with the Commissioner in relation to a BAS provision.

Are BAS agents accountants? Not necessarily. For individuals, the TPB's BAS agent pathway starts at a Certificate IV Financial Services, or a higher award, in bookkeeping or accounting. Applicants also need a board approved GST/BAS course and relevant experience: 1,400 hours in the past 4 years, or 1,000 hours for a voting member of a recognised BAS or tax agent association.

Applicants must also be a fit and proper person and maintain, or be able to maintain, professional indemnity insurance that meets TPB requirements. A job title says little about whether a person has met those requirements, which is why checking the TPB Register matters.

An accountant gets no extra tax rights from the title alone

The TPB says accountants belonging to a professional association must still be registered to provide tax agent services legally if they charge a fee or receive a reward for those services.

The rule attaches to the service, not the title. According to the TPB, a person must not charge or receive a fee or other reward for a service they know, or should reasonably know, is a tax agent service unless they are a registered tax agent.

Registered tax agents come from several backgrounds. The TPB lists 6 registration options, including routes based on tertiary qualifications in accountancy or law, each with further course and experience requirements, and a work experience route of 8 years in the past 10 that also requires Board approved courses.

Registration is also not always all or nothing. The TPB says practitioners may have a condition on their registration that limits them to certain types of services, and the register displays those conditions.

Beyond tax, business.gov.au describes accountants as helping with financial statements and with financial and business advice.

Do you need a bookkeeper if you have an accountant? The ATO treats record keeping as a choice

Nothing in the TPB and ATO guidance cited here requires a business to hire a bookkeeper as well as an accountant. The question is how the record keeping gets divided. The ATO frames it as a choice: whether you will manage your records yourself, or pay a registered tax or BAS agent to manage all or part of them.

The ATO also says that even if you use a tax professional, you will probably still need to do some basic record keeping. It suggests asking the professional what record-keeping system would be compatible with theirs.

Keeping the records is one job. Making the tax judgments on those records is another, and the task table in this guide shows where the second job needs registration. For a closer look at the activity statement itself, see the guide to business activity statements.

Which one fits depends on the task, not a revenue threshold

The TPB examples used here describe tasks, and none of them turns on revenue or hours worked. The triggers below follow that same logic. They show where the line sits rather than what any one business should do.

• The work is entering data and reconciling bank accounts. The TPB's examples do not treat these as BAS services where no tax law is interpreted and no activity statement figures are involved, so the table marks them as open to an unregistered bookkeeper.
• Someone must decide GST codes or activity statement figures. The work is a BAS service, which means a registered BAS agent or tax agent if a fee is charged.
• Payroll needs tax rules applied. A payroll service that interprets a BAS provision, including STP setup, is a BAS service.
• An annual tax return is due. Only a registered tax agent can charge for preparing and lodging it.
• Earlier years are outstanding. According to the ATO, a tax agent can prepare and lodge prior year returns. The guide to overdue tax returns covers this further.
• There is a debt with the ATO. Advising or acting on tax debts is listed as both a BAS service and a tax agent service. See the guide to ATO payment plans.
• Lodgment timing matters. The ATO says you may get extra time on a quarterly BAS if you lodge through a registered tax or BAS agent, and most registered tax agents have a lodgment program for individual returns after the usual 31 October deadline. The ATO says someone using a tax agent for the first time, or changing agents, should contact the agent before 31 October to be part of that program.

Check anyone on the TPB Register before you engage them

The TPB Register is the way to confirm a tax or BAS agent is registered, and the TPB says the check only takes a few moments.

1. Enter the person's legal or registration name, Australian Securities and Investments Commission (ASIC) registered business name or registration number, then select Find.
2. Narrow the results if needed by practitioner type, state or territory, suburb and registration status.
3. Select the information icon on the result to open the full details.
4. Read the registration type, to see whether the person is registered as a tax agent or a BAS agent.
5. Read the registration status and expiry date. Finding a name is not enough, because the register also includes practitioners whose registration has been suspended.
6. Read any conditions of registration, along with any sanctions on the public record.

Two details need a separate check. A TPB registered symbol still needs checking against its registration number on the register. Professional association details on the register are supplied by the practitioner, and the TPB encourages people to verify them independently.

Agree the scope before the work starts

A clear scope settles who is doing which task. The TPB recommends discussing the details of the work and when it needs to be done, and how much the work will cost or general information about the fee structure. Many registered practitioners will ask a client to sign a letter of engagement.

The ATO adds a further question: ask a provider what services they will provide and charge for.

Responsibility for the return stays with the taxpayer. The TPB reminds taxpayers that they are responsible for their return even if someone prepares it for them, although using a registered practitioner may protect them from penalties if the practitioner does not take reasonable care.

Where Lomandra Accounting fits

Lomandra Accounting, a CPA Practice registered with the Tax Practitioners Board, works across bookkeeping, BAS, GST, payroll, cloud accounting, tax returns and self-managed superannuation fund (SMSF) administration. The business accountant page and the Sunshine Coast accountant page outline those services. Personal advice about an SMSF is a separate matter for a licensed financial adviser.

To agree a scope for your own business, ask Lomandra Accounting about a quick scoping call, and read what an accountant costs a small business beforehand.