Important Advice for Strata Managers Regarding New ATO Compliance Requirement

A significant change is about to be introduced by the Australian Taxation Office (ATO).  The change is called ‘Client-to-agent linking’ and its purpose is to strengthen the security of the ATO’s Online Services and protect against identity theft and fraud.  In practice, it will affect how strata managers interact with the ATO in relation to their client accounts.

Overview of the New Requirement:
From 13 November 2023, all entities with an ABN (excluding sole traders) will be required to notify the ATO prior to changing their accountants via the ATO’s Online Services for Business (Online Services). Only after this notification will the new accountant be able to add the entity as a client and access records. The person who notifies the ATO must be a listed Associate, e.g. public officer, director, office bearer, so it will become increasingly important that these positions are kept up to date on ATO records and reviewed on a regular basis.

Implications for Strata Managers:
In practice, most strata managers engage with a preferred accounting partner for managing the tax compliance work of their portfolio and act as the public officer by default for all managements. Upon a strata manager taking on a new management, the accounting partner will usually update the ATO records (including bank details, listing the new strata manager as the public officer etc). The introduction of client-to-agent linking means that this process will incur additional preliminary steps that need to be carried out by an individual already listed on the ATO’s record of the strata company. 

IMPORTANT: Without these preliminary steps being carried out, accountants will not be able to view or update any records on behalf of new managements, nor lodge tax documents on their behalf.


It therefore stands to become a rather large administrative problem if the strata company’s listed associates (per ATO records) are not known in advance of a new management commencing. Previously, they could be sourced by the accountant from the ATO but the new changes effectively prevent this workaround from being an option from 13 November.

If the listed associates are unknown (or unwilling to carry out the necessary steps on Online Services), this could lead to lengthy delays, especially if the departing manager is not proactive in assisting the incoming team.

While the ATO's Online Services registration is straightforward for most small businesses, it poses challenges for strata companies. This is primarily because the frequently changing composition of strata councils is often not kept up-to-date on ATO records. The ATO states that it is the responsibility of the strata to keep the records updated, however in practice this is rarely done.

Recommendations for Proactive Management:

1.     Consider adding the chair or treasurer of the strata company to ATO records as an associate in addition to the strata manager principal as this gives at least two, up-to-date associates who can arrange for a change of accountants.

2.     Introduce an annual check and update (if necessary) of ATO records to ensure the two positions reflect the appointees.

3.     Consider introducing charges / terms to your default management agreement to cover yourself financially for the anticipated extra administrative tasks that may be required in the event one of your clients unfortunately decides to move on from your business.