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Work out if you need to report

Find out if your organisation needs to report transactions in a 'Business transactions through payment systems' report.

Last updated 21 November 2021

If you are an administrator of an electronic payment system, you need to report the transactions you process for your business clients.

An administrator is any entity that manages and/or controls the processing of payments in a payment system or part of a payment system. This includes any entity that manages and/or controls any instruments and procedures related to the payment system.

Administrators of an electronic payment system can be:

  • card schemes
  • acquirers
  • specialised payment providers
  • third party processors.

These organisations may have a reporting obligation if they enable payments for businesses including:

  • payments in the merchant acquiring system
  • BPAY payments
  • direct debit payments
  • payments from foreign payment systems.

A payment system is defined by the Payment Systems (Regulation) Act 1998.

Third party arrangements

There are situations where both an acquirer and a third party processor will participate in the processing of a transaction.

The reporting obligation will be with the third party processor as they have:

  • a direct relationship with the business client
  • full visibility of the identity and transactional data that is to be reported.

An acquirer is not required to report transactions initiated and reported by a third party processor.

Start of example


Learn to Sing engages a third party processor to process the direct debit agreements for their clients.

The third party processor collects the information needed by their financial institution, and Learn to Sing is issued with a unique reference ID. This reference ID identifies the Learn to Sing payments processed under their direct debit authority.

The third party processor has the reporting obligation as they have full visibility of both the identity and transactional data of Learn to Sing.


Align Building opens a merchant account directly with an acquirer. The builder is issued with a merchant ID along with a hand-held card reading machine.

The acquirer has the reporting obligation as they initiated the transaction and have full visibility of both the identity and transactional data of Align Building.


Sarah sets up a direct debit agreement with a family member to whom she has loaned money through a third party processor. The loan is private in nature and not related to a business transaction so the third party processor does not have to report.

End of example

Transactions processed by a payment gateway

An organisation that provides a business with software to enable the sale of goods or services but does not process the payment transaction does not need to report. The reporting obligation is held by the organisation that processes the payments.

Start of example


Sarah operates a website to sell her paintings. She has purchased software from Payment Plus that enables her to accept sales that are processed through her merchant account issued directly from her bank.

The reporting obligation is with her bank as Payment Plus is a payment gateway and does not issue a merchant account or process the payment.

If an organisation provides payment gateway and third party processor services, it should not include the payment gateway transactions in their report.

End of example

Advising us of third party arrangements

Acquirers providing merchant and/or BPAY facilities to third party payment processors will be asked to provide their client list annually.

We use this information to contact third party payment processors who do not currently report to us. We then provide them with information on their potential reporting obligations. This aims to ensure a level playing field for all participants in the payment systems industry.