A client onboarding checklist for Australian accountants and bookkeepers
Since 1 July 2026, some of what Australian accountants do for clients falls under the AML/CTF Act. This client onboarding checklist separates those services from ordinary tax and BAS work, and covers what the TPB and APES 305 expect of both.
Onboarding in an Australian practice now has three layers. The TPB expects proof of identity before you provide tax agent or BAS services to a new client. APES 305 expects the terms documented and communicated, preferably before the work starts. And if you provide a designated service under the reformed AML/CTF regime, customer due diligence comes first as well.
Last reviewed against 10 primary sources.
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Client onboarding checklist
The Australian checklist as a printable PDF, as an Excel workbook, and as a CSV you can load into your own task list or send as a request list.
Download the PDF Download for Excel Download the CSVNo email required.
Next step: send this list to the client as a request list in FirmHello. They upload against each line, and reminders chase whatever is still open.
Get startedThe list works as an accounting client onboarding checklist for tax and advisory clients and as a bookkeeping client onboarding checklist for BAS clients. Groups 1 to 4 are the practice's; groups 5 to 8 go to the client. Strike what does not apply.
The checklist
Work through the groups in order. Replace [bracketed] items with your own. Group 2's AML/CTF items apply only to a designated service.
1. Before you accept
- Run a conflict check on the client, its directors, trustees and related entities
- Write down the scope you are quoting for, and what is excluded
- Agree the fee, how it is billed and what triggers a change
- The client's permission to contact the previous accountant
- Decide whether any service you will provide is an AML/CTF designated service Holding or disbursing client money, setting up companies or trusts, and acting as a director or trustee are on the list.
2. Identity and due diligence
- Proof of identity for each individual client before providing tax or BAS services Sight original or certified photo ID, in person or through a secure electronic method. The ATO's client-to-agent linking does not replace this check.
- For an entity, the identity of the person acting for it and their authority
- For a designated service, initial customer due diligence before you provide it
- The entity's beneficial owners, where AML/CTF due diligence applies
- A record of the documents sighted, kept five years after the engagement ends The TPB expects the record to confirm the IDs were legible and gave no reason for doubt.
3. Terms of engagement
- A letter of engagement for each entity, trust and individual
- Terms documented and communicated under APES 305 before work begins
- Any outsourced service, with the provider, its location and what it does
- Where cloud providers will store the client's information
- The TPB register, complaints process and client rights, in writing
- The client's signature on the letter, in your own signing tool or wet ink
4. Authorisation with the ATO
- For an entity with an ABN, the client nominates you in Online services for business Sole traders and individuals follow a separate linking process for individuals.
- Give the client your registered agent number for the nomination
- Add the client to your client list within 28 days of the nomination After 28 days the nomination expires, though the client can extend it by another 28.
- The principal authority's myID, linked to the ABN in RAM
5. Access to systems
- Adviser access to the accounting software, not the owner's login
- Bank feeds, or monthly statements for every account
- Access to the payroll software used for Single Touch Payroll
- A record of every login the client has granted you, to revoke when you part
6. The prior-year file and opening documents
- The last two years of income tax returns and notices of assessment
- The last four BAS lodged and any amendments
- The depreciation schedule and asset register
- Trust deed, company constitution and any partnership agreement
- Tax losses carried forward and Division 7A loan agreements
7. Communication and portal set-up
- A client portal login for each person who will send or receive documents
- Agree how documents will travel, and that ID will not go by email
- One named contact on each side, and a backup
- Where the client's documents will be stored, and who at your practice can see them
8. The first deadlines
- The next BAS, monthly on the 21st or quarterly on the 28th
- Add new income tax clients to your client list by 31 October A client added after that date may not get the later due date the lodgment program allows.
- Single Touch Payroll pay events on or before each payday
- Superannuation guarantee payments, within seven business days of payday
Before you use this
Supplied as-is, with no guarantee. These templates are general information, not legal advice, and not a substitute for it. Have your own legal adviser review and adapt one to your practice and your jurisdiction before you put it in front of a client. FirmHello accepts no responsibility or liability for any use made of them.
How to run onboarding without it running you
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1
Decide before you collect
Finish groups 1 to 3 before you ask for a single bank statement. A client who has uploaded two years of records feels engaged whether or not the letter is signed.
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2
Send the client's half as one list
Authorizations, logins and opening documents go out together, with a date. Five separate emails over three weeks are how items get lost.
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3
Keep what you received and when
The identity documents, the signed letter and the predecessor's reply are the file you will want if the engagement is ever questioned. Keep them with the client, in one place such as a client portal for accounting firms, not scattered across staff inboxes.
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4
Close onboarding on a date
Pick the day onboarding ends and the first period's work starts. An onboarding that never formally ends turns into unbilled set-up work.
What changed for Australian onboarding in 2026
The reformed AML/CTF regime brought accountants in from 1 July 2026, with enrolment with AUSTRAC open from 31 March to 29 July 2026. It applies to nine professional designated services, such as helping with the sale of real estate or a business, receiving and managing a client's money, creating or restructuring companies and trusts, and acting as a director, trustee or registered office.
Preparing returns and keeping books are not on the list. A practice that does only that stays outside, though one service at the edge of it, such as setting up a trust for a client, is enough to bring the practice in.
Due diligence first
A reporting entity carries out initial customer due diligence before it provides a designated service, then ongoing due diligence for the rest of the relationship, under an AML/CTF program its senior management approves.
TPB proof of identity
Separately, the TPB expects proof of identity before tax agent or BAS services to a new client, and the record kept five years after the engagement ends. It updated that guidance on 20 July 2026 to align with the AML/CTF changes.
Client-to-agent linking
Every entity with an ABN, other than a sole trader, nominates its new agent in Online services for business. You then have 28 days to add the client, and you are not notified automatically, so ask the client to tell you when it is done.
What goes in writing
The Code of Professional Conduct Determination requires you to tell clients in writing about the TPB register and complaints process when you are engaged. APES 305 adds outsourced services and cloud storage locations.
Where onboarding goes wrong
Work before the letter
The client needs something urgently, so a junior starts on it while the letter is still with them. If they never sign, the scope of that work is whatever they remember asking for.
The predecessor nobody asked
A client moving firms in the middle of a dispute brings the dispute with them. One enquiry to the previous accountant, with the client's permission, is cheap insurance.
Logins that outlive the client
Bank, ledger and payroll access granted at onboarding is rarely revoked at the end. Keep a list of what you were given so offboarding can undo it.
The client's half, as a request list
Groups 5 to 8 are what FirmHello is for. Save them as a request list template, send it when the engagement letter is signed, and the client sees one checklist with your firm's name on it, with reminders going out until each item arrives. The signed engagement letter, the ID documents and last year's returns sit in the client's vault with everything they send later. FirmHello does not sign anything: the letter and any authorization forms are signed in your own signing tool or on paper, then kept in the vault. More on the client portal for accounting firms page.
Related templates and guides
Questions about onboarding new clients
Does the AML/CTF regime apply to a tax-only practice?
Not because of tax returns or BAS alone; they are not among the nine professional designated services. A practice that also sets up companies or trusts, holds client money or acts as a director or trustee is providing designated services.
Is TPB proof of identity the same as AML/CTF due diligence?
No. The TPB check applies to every new tax agent or BAS client. AML customer due diligence applies to designated services and goes further, into beneficial owners and ongoing monitoring. A client can need both.
What if the client never completes the agent nomination?
You cannot add them in the ATO's online services until they do. Put the nomination on their request list with a date, and remind them that it expires 28 days after they make it.
Is this checklist enough on its own?
It is a template supplied as-is. AUSTRAC's program starter kits, your professional body's guidance and your insurer's conditions may add to it. Have your own adviser review it before you rely on it.
Sources
The primary sources this page is written against, last read against it on . Check them before relying on a detail; rules and thresholds change.
- CPA Australia AML/CTF reforms for professional services
- Federal Register of Legislation Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (No. 110, 2024)
- AUSTRAC Professional designated services under the AML/CTF reforms
- Tax Practitioners Board TPB(GS) 42/2022
- Australian Taxation Office Client-to-agent linking applies to all entities with an ABN excluding sole traders when…
- Australian Taxation Office How to nominate your registered agent
- Australian Taxation Office New clients added to agent client list by 31 October to get the lodgment program due date
- Federal Register of Legislation Code of Professional Conduct Determination 2024 s45
- APESB APES 305
- Australian Taxation Office BAS due dates monthly 21st, quarterly 28th
What changed
- Added an Excel (.xlsx) copy of the checklist beside the PDF and CSV.
Send the list once, and let it chase
Each line becomes something the client uploads against. Reminders go out on your schedule until the list is complete, and every file lands in the client's vault.
No card and no sales call. If you would rather tell us about your firm first, use the longer form.