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  • Modernising Business Registers Business Advisory Group key messages 14 December 2022

    Key topics discussed at the Modernising Business Registers Business Advisory Group meeting 14 December 2022.

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    Welcome and introductions

    Assistant Commissioner Mary Arrowsmith opened the meeting and welcomed attendees.

    No conflicts were declared.

    Program update

    Action item update

    Mary Arrowsmith provided an action item update.

    • BAG-78 – Australian Business Registry Services (ABRS) agents’ compliance model

    In progress. An out of session discussion to be organised.

    • BAG-80 – Director ID determination – draft

    To be closed.

    Companies update

    Mary Arrowsmith provided an update on the companies implementation plan and dates.

    In addition to an out of session discussion held in early December, one-on-one consultations with key external stakeholders are continuing.

    A summary of feedback received includes:

    • broad support
    • understanding of the complexity and scale of the companies release, including the need to de-risk
    • intermediaries and ABRS agents will need to be supported and on the platform prior to go-live commencement – early onboarding help and assist material is essential
    • a need for continuing discussions around the ABRS agent model
    • considering the learnings from director ID onboarding regarding the cohort of first-time users of myGovID
      • Looking to see where these learnings can be implemented to provide support for this cohort in the companies release.
    • digital service providers (DSPs) have indicated their preference is for a full suite of application program interfaces (APIs) and sandbox environment for testing to be made available at least 12 months before the companies release go-live date
    • considering how DSPs can be used to support testing
    • considering how director ID data is being captured and used (i.e. support awareness of the need for director ID)
    • understanding the value proposition of the business inbox, from a whole of government perspective versus only the registry perspective
    • awareness of data security and need to be transparent regarding the approach to handling a data breach
    • limiting customisation of the Verne product (where possible)
    • no matter what dates are considered, there are implications of having systems off-line. An example included anyone providing accounting services that transact with the ATO are required to verify an ABN. This needs to be considered in the implementation strategy.

    Members were thanked for their feedback.

    Consultations are continuing and will be used to inform proposals. Outcomes will be shared with members in the new year.

    Handling of large documents

    Brian Shepherd presented an update on the handling and transferring of large documents. Key discussion points included:

    • a 10 MB global size limit rule for documents being lodged, and only by agreed program exception will a document over 10 MB be allowed
    • claim-check pattern for handling large files instead of splitting files
    • an example of the user experience when uploading a constitution document as part of a company registration process.

    The primary reason for the 10 MB limit is based on the ATO digital service gateway limit, which is 10 MB.

    Members expressed concerns with a 10 MB limit, in particular impacts on the end user regarding scanning in high resolution format and ability to compress large documents.

    Written feedback and examples of documents exceeding 10 MB will be requested from members to further understand issues and specific scenarios.

    Australian Securities and Investment Commission new transactions

    Yvan Dang presented an update on new transactions in the Australian Securities and Investment Commission (ASIC) regulatory portal.

    ASIC has historically received forms via different submission channels (including paper-based forms) with minimal structured data, which has limited the ability for processing and data analytics. ASIC legacy technology that supports these forms, will be decommissioned under the MBR program.

    In the future, the ASIC regulated population will access the ASIC regulatory portal to complete regulatory transactions. ASIC aims for this to provide a more streamlined experience for stakeholders.

    The ASIC regulatory portal was launched in 2018 and has:

    • 48 regulatory transactions currently available
    • 73,000 registered users
    • includes over 175,000 transactions submitted successfully.

    Agencies have collaborated to analyse existing and new functions and powers under Modernising Business Registers (MBR) law to allocate existing forms and transactions between the 2 agencies.

    ASIC are continuing to design user friendly transactions in the regulatory portal to enable better quality data and require less manual intervention. Many of the forms will be digitised as part of the MBR program. Where appropriate, ASIC are grouping similar legacy forms into a single transaction, which is made possible by question branching or logic in the transactions. New transactions will cater for functions and powers that won’t transition to the ABRS.

    In the regulatory portal, transactions have a landing page that include details on the purpose of the transaction, how to submit it, related fees, guidance, a link to the pdf paper form where relevant and legislative references. Landing pages will be updated to promote changes in the lead up to, and after the go live date.

    ASIC regulatory transactions are planned to be released in a staged approach with some transactions available before the ABRS companies release ‘go live’ date. This will only be done where the transaction is purely regulatory and does not impact the company register.

    Director ID update

    Director ID onboarding

    There are currently over 2 million director IDs issued including:

    • 87% issued through the digital channel
    • 10% telephone applications
    • 3% paper applications.

    Further information:

    • Over 700,000 director IDs issued in the month of November, with over 100,000 issued in December (as of 14 December).
    • While there were reports of difficulties experienced with telephone channel (high wait times) during the peak weeks in the lead up to the November deadline, currently wait times are under 5 minutes.
    • The Registrar announced on 30 November that ABRS will apply a pragmatic compliance approach to directors who are required to apply for a director ID by 30 November 2022, if they apply by 14 December 2022.
    • Directors who have not applied will be contacted commencing in early 2023 to support them with information on how they can apply online.

    Member’s feedback included:

    • continue promoting messaging to support community awareness of the requirement to apply
    • reports of long phone wait times in the lead up to the 30 November deadline reported. Consider communication to address this perception.

    Michael Flynn thanked members for their feedback. Messaging will continue via ATO and ASIC channels to support visibility.

    Assistant Commissioner Martin Jacobs noted peak demand on call centre was reached in November. Following the Registrar’s announcement of additional time to apply, call numbers declined significantly. This decision supported the user experience. Social media is being used to promote message that now is the right time to call, recognising people had difficulties in November.

    Director ID determination

    The director ID determinations were released for public consultation on 15 November and closed 9 December. Six formal submissions were received with feedback being positive overall.

    No significant changes are planned to be made. The director ID determinations contain a retrospective date of 1 December 2022. The determinations are expected to be registered mid-March 2023.

    Wrap and close

    Chair, Deputy Commissioner Narda Phillips thanked members, presenters, and attendees for their contributions.

    Meeting closed at 3:35pm.

      Last modified: 06 Jan 2023QC 71208