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Compliance
October 4, 20269 min read

Routine tax compliance versus a designated accounting service

A routine tax return is not, by itself, a designated accounting service. The designated-service test looks at the service, not at the fact that you are an accountant.

Quick answer

Preparing a return or a BAS for a local client is a different question from forming a company, acting in a transaction, or moving value, so split the engagement. This page does not reproduce the designated-service list, and the decision tree is the other page. The firm suite is A$0. The client pays only where the program requires a check.

People search “tax return AML designated service” when a regional tax practice hears that accountants are covered and starts a check on every tax return. Checked against AUSTRAC’s professional designated services page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The service list people mean by table 6 is table 6 designated services. A yes-or-no path is the designated services decision tree. The sector map is /tranche-2.

The letterhead is not the service

A regional practice can spend most of March on returns and activity statements, and that workload does not convert each return into a designated service. The professional designated services are specific activities. AUSTRAC describes them. This page does not copy the description, and it does not rule that your return is out.

The same client can have two files. The return stays on the tax list. A company formation, a transaction you assist, or client money you are asked to hold is tested on its own. Staff need a way to mark which file they opened.

  • Start from the engagement letter. If the job is the return, say so. If someone has added “and help them settle the purchase”, that second job is a new test.
  • Do not use fear as the test. “Accountants are in Tranche 2” is not a finding that this return is a designated service. Use the decision tree for the finding.
  • Do not use habit as the excuse. A client you have known for years can still ask for a service that is in scope. The relationship is not the test.
  • Bookkeepers are adjacent, not identical. A bookkeeping-only file is discussed on its own page. Do not fold it into the return rule to save time.

Return, or something else on the same client

Sort the job before you talk about documents. The job decides whether the program’s customer steps apply.

A sorting aid for a tax practice. This table does not reproduce AUSTRAC’s professional designated services.

Job on the clockHow to treat it hereWhere the real test lives
Prepare the income tax returnNot a designated service merely because it is taxYour program, if the engagement is wider than the return
Prepare a BASSame principle: routine compliance is its own questionThe decision tree if the work changes
Form a company or provide an officeA different serviceThe formation page and the service list
Touch the purchase money or the contractDo not call it a returnTable 6 and the decision tree

Where the tax-return page stops

This page keeps the return separate from a designated service. It is not the table and it is not the decision tree. Those are table 6 designated services and the designated services decision tree.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Classifying a tax return as out of scope is program work, and that classification is not a check inside the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a tax return is a designated service.

Frequently Asked Questions

Test the service. Do not check every return by default.

The firm suite is A$0. The client pays a check only where the approved program says the service is in scope.

Open the Tranche 2 guide

Questions: team@freeaml.com.au