Chartered Accountants Australia and New Zealand (CA ANZ) and CPA are strongly supportive of a Payment Times Reporting Framework (the Framework). Small businesses form a significant segment of the Australian economy and society, and the major accounting bodies believe in the fair and equitable treatment of this segment Small businesses should be paid on time and in a timely manner.
However, the proposed Framework is overly complicated. Significant compliance costs’ savings can be made by changing the definition of small business. Currently, a small business is any business that is included the Payment Times Small Business Identification Too – which is still being developed by the Department of Industry, Science, Energy and Resources and has not been exposed to public consultation.
The regulatory impact statement for the Bill estimates that the compliance costs for reporting entities will increase by an average of $22.5 million per year, and that $10 million of government funding over four years from 2019-20 will be required. A simpler way to achieve the same policy outcome would be to require reporting entities to use an expenditure threshold as a proxy for identifying small business. – which many businesses already do. An expenditure threshold would require a large business to report all invoices for a supplier that supplies less than $X million of goods and services annually.
The use of an expenditure threshold as a proxy for small business offers a simple, effective way to assist business use existing accounting systems to identify and report, and will cover most small businesses (provided that an appropriately high threshold is set). Potentially, it will also include some medium sized businesses, which given that medium businesses are also likely to have the same problems negotiating with large business, would also be an appropriate policy outcome.