The obligations contained in the existing Code of Conduct governing tax and BAS agents:

• are generally underpinned by clear, broad, flexible, and actionable principles; and
• have been developed after extensive consideration through consultation with stakeholders.

Agents are sensitive to the burdens of highly prescriptive regulation, especially where tied to serious consequences which include termination of registration.

The Joint Bodies say that any modifications or additions to the Code should reflect best practice regulation, embody clear, broad, flexible and actionable principles, and should be supported by detailed guidance.

The draft Instrument should be amended to ensure that it meets this standard.