Vulnerability capability
The ATO thanked members for their support and participation in the consultation process of the Vulnerability Framework, which was published on 21 October 2025.
It was noted 71 written submissions were received, with over 550 individual pieces of feedback recorded.
Key themes from feedback were:
- language and scope
- consultation and representation
- actions and measurement
- system design and whole of government.
The ATO is now starting to implement the principles in the Framework, along with progressing work on specific actions items, and the Inspector-General of Taxation recommendations on the Identification and Management of Financial Abuse in the Tax System. Feedback received through consultation that was more relevant to these elements, than the Framework itself, will be considered as the ATO progresses that work.
Some of the feedback received was identified as out of scope, such as items associated with policy and legislation or functions outside of the role of the ATO. It was noted referral pathways may need to be considered in line with privacy and current processes in place for sharing to relevant teams.
Further consultation will be required. Consultation topics include accessibility, staff training, evidence and identification and management of financial abuse.
Member feedback
The ATO has done a good job of acknowledging out of scope items and members asked about other plans for these items. The ATO advised that out-of-scope items would be reviewed and consideration for referral to other parts of government would be in line with existing process and privacy guidelines.
Members asked, in the context of diversity, if the ATO's approach to recruitment was included in the Vulnerability Framework? ATO members present noted that the ATO is committed to a diverse and inclusive workplace and has existing programs, policies, and networks to achieve this.
Members noted that vulnerability indicators have previously been used by other agencies, not always well, noting that when they are used well vulnerability indicators can be useful for trauma informed practice and to avoid re-traumatisation of people experiencing vulnerability.
Members asked about measurement and accountability implementation. The ATO discussed the need to identify short and long-term measures, with consideration of data we already capture. Looking at what we need to add or change for meaningful qualitative and quantitative measures, capturing what's important and useful.
Members discussed the need for security arrangements when authorised nominees are acting on a taxpayer's behalf.
The ATO's approach to taxpayer relief provisions
The ATO presented an update on its review of the ATO's approach to taxpayer relief concessions to support obligations of lodgment and payment, while ensuring the concessions framework is sustainable and supports those in need, including those experiencing vulnerability.
In scope for the review are lodgment and payment deferrals, payment plans and remission of interest and penalties. The aim is to be clear, consistent and transparent and aligned with the legislation, while making it easier for taxpayers to identify when they may be eligible for assistance. The ATO is also looking for opportunities to improve policies and processes, including work processing and how we explain our decisions.
Consultation was recently completed, where the ATO sought feedback from taxpayers and tax professionals on a set of draft principles that describe the overarching approach to concessions. Over 30 submissions were received from individuals and small businesses who shared their stories and helped to contextualise the lived experience of the ATO's concessions policies.
Common themes noted in consultation included consistency, transparency, flexibility, vulnerability, role of advisors and equity.
The next steps for the ATO will be to work through additional policies, processes, guidance material and communication strategies that will support the implementation of the refreshed approach.
Member feedback
Members raised concerns about AI and automated decision making, and next steps referencing alignment to the Vulnerability Framework.
The ATO confirmed that decisions are not automated. Decisions are governed by data ethics principles, ensuring human oversight for every decision.
Members discussed the importance of currency of information available, while acknowledging the responsibility of providing up to date information lies with the professional providing the service.
Commissioner update
Rob Heferen, Commissioner of Taxation, attended the meeting thanking members for their time and valuable contributions, noting the importance of stewardship groups and the external perspective they provide.
The Commissioner spoke about the role of the ATO, our vision and the impact of the work we do.
Attendees
|
Organisation |
Member |
|---|---|
|
ATO |
Rowan Fox (Chair), Individuals and Intermediaries |
|
ATO |
Anita Challen, Frontline Operations |
|
ATO |
Renee Jones, Superannuation and Employer Obligations |
|
ATO |
Robert Thomson, Individuals and Intermediaries |
|
ATO |
Tara Pamula, Frontline Operations |
|
Australian Securities and Investment Commission |
Andrew Dadswell |
|
Australian Shareholders Association Limited |
Eden Zanatta |
|
Consumer Action Law Centre |
Kirsty Robson |
|
Financial Counselling Australia |
Rebekah Sarkoezy |
|
Financial Counselling Victoria |
Zyl Hovenga-Wauchope |
|
People with Disability Australia |
Julian Laurens |
|
Relationships Australia |
Susan Cochrane |
|
Treasury |
Richard Maher |
Guest attendees
|
Organisation |
Attendee |
|---|---|
|
ATO |
Chanara Fraser, Individuals and Intermediaries |
|
ATO |
Katie Abela, Individuals and Intermediaries |
|
ATO |
Michelle Mathews, Individuals and Intermediaries |
|
ATO |
Rebecca Bodel, Frontline Risk and Strategy |
|
ATO |
Rob Heferen, Commissioner of Taxation |
Apologies list
|
Organisation |
Member |
|---|---|
|
Financial Counselling Australia |
Lynda Edwards |
|
National Seniors Australia |
Brendon Radford |
|
Redfern Legal Centre |
Julia McClelland |
|
Tax Clinic |
Connie Vitale |