Chartered Accountants Australia and New Zealand (CA ANZ) has lodged a submission to the Tax Ombudsman’s “Systemic reviews: refresh of our FY26 work plan” (2026 workplan refresh).
The submission comments on the 2026 workplan refresh:

The ATO’s management of compromised accounts

While the ATO has made progress toward protecting taxpayers from fraud, further work is needed to reduce this risk by improving the way the ATO interacts with tax agents. This could include a mechanism that the ATO and tax agents use to identify each other in a safe and efficient manner, such as multi-factor authentication.

Family trust elections (FTEs)

Members are concerned about FTEs and family trust distributions tax, which have been a focus area for the ATO over the past year. There are significant compliance issues resulting in large tax liabilities. CA ANZ has been working with the ATO and other professional bodies to resolve various issues, from both an administrative and a legislative perspective.

Pay Day super

Members are concerned about ensuring clients are ready to comply with their Pay Day super obligations. CA ANZ, along with other stakeholders, and the ATO have been working closely for the purpose of ensuring Pay Day super operates effectively and efficiently, and the substantial penalty framework operates fairly and appropriately.

Director Penalty Notices (DPNs)

CA ANZ supports a review of DPNs, which along with general interest charge (GIC) remission, are symptoms of the ATO’s tax debt book and collection procedures.

Breach reporting

Additional guidance is required about breach reporting matters. With the government announcing that it will provide the TPB with a greater range of sanctions and higher penalties, a review is timely of the TPB’s governance processes regarding breach reporting data, investigative process and the development of guidance.

Client agent linking (CAL)

Ideally there will be alignment between the different regulatory regimes which require client identification. CA ANZ also supports a review of the current CAL procedures before it is rolled out to individuals, sole traders and entities without an ABN (i.e. the majority of taxpayers).