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SAN misuse

SAN misuse occurs when someone incorrectly enters your SAN or audit completion date in an SMSF annual return.

Last updated 17 February 2021

Approved self-managed super fund (SMSF) auditors who register with the Australian Securities and Investment Commission (ASIC) are provided with an SMSF auditor number (SAN). Each SAN is unique and only applies to the individual who applied to be an auditor.

A SAN is included in each SMSF annual return (SAR), to identify who audited the fund prior to SAR lodgment.

There have been instances where a SAN is included in a SAR, but:

  • an audit has not been completed by the auditor with that SAN, or
  • the SAR was lodged prior to the completion of an audit.

This is referred to as SAN misuse and we are taking action to stop it. If we find that a tax agent has purposefully included an incorrect SAN in a SAR or lodged a SAR prior to completion of an audit, we may refer them to the Tax Practitioners Board (TPB).

The TPB may impose a sanction for any breach of the Tax Agent Services Act 2009 (TASA) Code of Professional Conduct. These sanctions can include:

  • a written caution
  • an order
  • suspension or termination of registration.

SMSF trustees who have deliberately misused a SAN may also be sanctioned.

SAN list

Since March 2019, the ATO has used a proactive approach to more effectively treat SAN misuse. Specifically, we now issue auditors with a list of all SMSFs that reported their SAN.

This list is sent to auditors at least once a year. When you receive this list, you should compare it to your own record of completed audits. You should contact us as soon as possible where you:

  • identify a fund on the client list that you didn't audit, or
  • audited a fund but the date is incorrect, or
  • audited a fund that doesn’t appear on the client list.

If your client list is correct and no instances of SAN misuse have been identified, you should still contact us to confirm that all the information is correct.

Auditors can reduce the number of SMSFs for which they need to confirm audits by lodging an audit complete advice (ACA).

Audit complete advice

The ATO uses ACAs to provide assurance that an SMSF has been audited and that the audit was completed prior to lodgment.

We recommend that auditors lodge an ACA immediately after completing an audit (except where a bulk lodgment form is used).

Where an ACA has been lodged and it matches the details in the SAR, we don't need to ask auditors to confirm the same details in the SMSF list. Therefore, the list will only contain funds where:

  • we find discrepancies between auditor details in the SAR and an ACA, and/or
  • no ACA has been lodged to confirm that an audit was completed.

How to lodge an ACA

To lodge an ACA in Online services for business – select these menu options: Lodgments > Reports and Forms > Audit Complete Advice.

To lodge multiple ACAs in one form – complete an Audit Complete Advice – Bulk Lodgment form.

We recommend that auditors using ACA bulk lodgment forms lodge monthly. This will help us to identify SAN misuse in a timely manner.