Consultation paper – A changed approach for top 100 high assurance GST reporters

Provide your feedback

We are seeking your feedback on the ATO's changed approach for eligible top 100 high assurance GST reporters following the introduction of the Supplementary annual GST return (SAGR).

To submit your feedback:

• review the information about our changed approach for top 100 high assurance GST reporters below
• provide feedback to Top100@ato.gov.au
• submissions close 29 September 2025.

Feedback may be made available to the public on the ATO website unless you indicate that you would like all or part of your response to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Confidential elements should be marked or provided in a separate document.

Purpose of consultation

This consultation is being undertaken to seek feedback on proposed changes to our top 100 GST program for high assurance GST reporters following the introduction of the SAGR.

Background

As a result of the assurance obtained over GST in the top 100 population to date and with the introduction of the SAGR, we consider that there is scope to further reduce our engagement and resource investment with overall high assurance GST reporters in GST refresh reviews.

We intend to transition our GST refresh reviews for high assurance reporters who prepare their own GST analytical tool (GAT) prior to lodgment of the SAGR to an assurance check-in every 4 years.

Under this approach we will predominantly rely on independent tax control testing results and the alignment between accounting and tax to evidence and maintain assurance, supported by annual profiling.

We undertook targeted consultation with the Large Business Stewardship Group top 100 members in June and July 2025. Feedback has been captured, collated and considered in refining our changed approach.

Overview

Public and multinational businesses are the largest GST remitters in Australia with the top 100 population a significant contributor to GST collections. In 2022–23 the top 100 population contributed about $10.2 billion in GST collections, or 13.2% of total GST collections.^Footnote1 Oversight of the top 100 GST population is important and under the top 100 GST assurance program we engage with top 100 reporters and seek assurance that they are reporting the right amount of GST.

As at 30 June 2024, 93% of top 100 reporters have attained a high or medium level of assurance.

As a result of the assurance attained over GST in the top 100 population to date^Footnote2 and with the introduction of the SAGR,^Footnote3 we consider that there is scope to further reduce our engagement and resource investment with overall high assurance GST reporters.

The SAGR can help us more readily identify changes in business and GST positions without having to conduct one on one engagements for all taxpayers across all issues. For highly compliant taxpayers that maintain a consistent standard and lodge the SAGR with high quality responses, it will reduce the likelihood of intensive justified trust reviews.

As a result, we intend to transition our GST refresh reviews for overall high assurance reporters who prepare their own GAT^Footnote4 prior to lodgment of the SAGR to an assurance check-in every 4 years. Under this approach we will predominantly rely on independent tax control testing results and the alignment between accounting and tax (that is, the GAT) to evidence and maintain assurance, supported by annual profiling.

Eligibility

A high, or provisional high assurance reporter will be eligible for an assurance check-in from the first refresh period in which a SAGR is required to be lodged.

The assurance check-in is premised on the following factors which provide us with a high level of confidence that we can leverage from prior assurances and engagements:

• we have assessed that the reporter has an effectively designed or operating tax governance framework for GST – overall Stage 2 or Stage 3 governance rating
• we completed a comprehensive initial or refresh review, not a streamlined or top 1,000 review, where the reporter achieved overall high or provisional high assurance
• the SAGR is lodged with high quality responses
• the reporter has undertaken the GAT for the relevant review period, as advised in the SAGR (or a similar reconciliation if previously reviewed and assured by the ATO)
• any matters required to resolve the provisional high assurance rating have been actioned prior to lodgment of the SAGR for the relevant review period
• we have not identified any material business changes, or changes in positions previously assured which materially impacts on our assurance levels including through our monitoring of the SAGR and top 100 disclosures.

Scope of an assurance check-in

Our focus will be on reviewing:

• completed independent tax control testing reports to assess whether the reporter has an operationally effective tax governance framework for GST, to the extent these have not been reviewed previously in the intervening monitoring and maintenance (M&M) period
• actions taken to address recommendations, including to enhance governance controls, in relation to a specific risk identified in the earlier assurance reviews
• the completed GAT and supporting workbook.

We will also consider whether we need to assure any new significant transactions or risks not assessed in prior assurance reviews. Our consideration will have regard to:

• prior assurance levels, and the extent to which we can leverage from assurance attained by the reporter for the same or similar transactions or risks
• the nature of the transaction or risk having regard to the business profile and circumstances of the reporter and its impact on the overall assurance rating
• changes in the business informed by the reporter’s disclosures and our internal profiling.

We will typically not perform the below activities in the assurance check-in:

• data and transaction testing
• review of BAS and working papers
• systems walk-throughs
• review of GST tax governance framework to check for design effectiveness
• request information in relation to previously assured tax risks flagged to market, significant on-going transactions and specific risks.

If no significant issues or risks are identified that would cause our high assurance rating to be undermined, we will not ask for further information or evidence.

If we do identify significant concerns that could cause our high assurance rating to be undermined, we will seek to resolve these in the assurance check-in.

To the extent that we cannot fully leverage prior assurances due to significant business or systems changes, a tailored refresh review may be required. Refer to the top 100 GST refresh review guide.

In the 3-year M&M period following an assurance check-in, we will continue to monitor GST compliance using data and analytics and take a monitoring stance which will be informed by the SAGR, the top 100 disclosures framework and our income tax pre-lodgment compliance reviews (PCRs). We will continue to engage on material business changes and new transactions in real time as appropriate and will review tax governance operational effectiveness testing results as they are provided to us. This means that we will necessarily have more frequent engagement with some taxpayers.

An overview of the assurance check-in approach is outlined in Table 1.

Table 1: Assurance check-in approach for high assurance reporters

-	Tax governance framework	Tax risks flagged to market	Significant and/or new transactions and specific issues	Alignment between accounting and tax
We will	Review completed independent tax control testing reports, (if not previously reviewed in an M&M period). If a reporter has a provisional Stage 2 rating, request agreed evidence to support unqualified Stage 2.	-	-	Review GAT workbooks.
We may	Request contemporaneous governance documents.	Request evidence where tax risks flagged to market are identified in the review period that were not previously assured.	Request evidence relating to new significant transactions or material specific risks in the review period that are not previously assured. Request evidence relating to actions taken to address recommendations from a prior assurance review.	Request supporting objective evidence of GAT adjustments.

Communicating our assurance

We will not issue an assurance report. Instead, we will issue a letter which will include, to the extent relevant:

• a summary of any information provided as part of the assurance check-in
• our findings, including whether we have maintained or increased our ratings for GST governance and the alignment between accounting and GST
• acknowledgment of any actions taken to address our recommendations from previous reviews
• any outstanding recommendations or actions
• our proposed future assurance plan, which will include a 3-year M&M period where we continue to have high assurance.

Predominantly input taxed reporters

Predominantly input taxed high assurance reporters that are exempt from the GAT will not be eligible for an assurance check-in. These reporters will continue to be subject to a tailored refresh review every 4 years.

As part of the tailored refresh review for predominately input taxed reporters, we will likely conduct targeted data and/or transaction testing in order to maintain and evidence assurance over correct reporting.

An overview of the refresh review approach for predominantly input-taxed and GAT-exempt reporters is at Table 2

Table 2: Refresh review approach for high assurance predominantly input-taxed reporters

-	Tax governance framework	Tax risks flagged to market	Significant and/or new transactions and specific issues	Alignment between accounting and tax
We will	Review completed independent tax control testing reports (if not previously reviewed in an intervening M&M period). If a reporter has a provisional Stage 2 rating, request agreed evidence to support unqualified Stage 2.	-	Conduct targeted data and/or transaction testing.	-
We may	Request contemporaneous governance documents.	Request evidence where tax risks flagged to market are identified in the review period that were not previously assured. Request evidence relating to actions taken to address recommendations from a prior assurance review.	Request evidence relating to new significant transactions or material specific risks in the review period that are not previously assured. Request evidence relating to actions taken to address recommendations from a prior assurance review.	-

Medium assurance reporters

Medium assurance reporters will not be eligible for the assurance check-in.

A medium assurance rating typically reflects design gaps in the taxpayer’s governance framework, specific GST risk or correct reporting areas that are yet to be assured to a sufficient level and/or an inability to fully reconcile amounts reported in the financial statements to amount reported in the BAS. We will continue to take a tailored approach to refresh reviews for these reporters having regard to their performance across the 4 focus areas of justified trust.

An overview of the refresh review approach for medium assurance reporters is at Table 3.

Table 3: Refresh review approach for medium assurance reporters

-	Tax governance framework	Tax risks flagged to market	Significant and/or new transactions and specific issues	Alignment between accounting and tax
We will	Review controls that are not designed effectively to ascertain whether they are now designed effectively (if not previously reviewed in an M&M period). Request completed independent tax control testing reports (if not previously reviewed in an M&M period). Request contemporaneous governance documents.	Request evidence where tax risks flagged to market are identified in the review period that were not previously assured. Request evidence to increase our assurance over any tax risks flagged to market that are low or medium assurance (with further action).	Request evidence relating to new significant transactions or material specific risks in the review period that are not previously assured. Request evidence to increase our assurance over significant transactions or specific issues that are low or medium assurance (with further action).	Review GAT workbooks and supporting objective evidence of GAT adjustments. Review a 3-month sample of BAS and working papers.
We may	Request evidence supporting actioned recommendations regarding the enhancement of controls.	Request evidence relating to actions taken to address recommendations from a prior assurance review.	Conduct targeted data and/or transaction testing. Conduct a systems walkthrough. Request evidence relating to actions taken to address recommendations from a prior assurance review.	Where insufficient information exists to complete the GAT, we may undertake further assurance work in relation to tax risks flagged to market, ongoing significant transactions, specific risks and/or correct reporting.

Low assurance reporters

Low assurance reporters will not be eligible for the assurance check-in.

We will continue to comprehensively and intensively review overall low assurance reporters through an annual comprehensive justified trust GST assurance review until at least an overall medium level of assurance has been obtained.

What happens next?

After the consultation closes, we will review all feedback and use it to guide our approach, supported by updated external guidance.

Footnote 1

Return to footnote 1 Top 100 GST assurance program (QC 60473). referrer

Footnote 2

Return to footnote 2 Findings report – Top 100 income tax and GST assurance programs provides key findings from our income tax and GST Top 100 programs for 2024 (QC 63848). referrer

Footnote 3

Return to footnote 3 About the Supplementary annual GST Return (QC 103044). referrer

Footnote 4

Return to footnote 4 Refer Section D, question 10, of the 2025 SAGR. Source: Supplementary annual GST return 2025. referrer