ATO client nomination and client-to-agent linking: what changes in 2027

The short version

Client-to-agent linking (CAL) already applies to every entity with an ABN except sole traders. Companies, trusts, partnerships and SMSFs nominate their registered agent in Online services for business before the agent can add them. Individuals and sole traders do not do this today.

That changes in 2027. On 23 September 2026 the ATO published its plan to extend client-to-agent linking to individuals and sole traders. The process will be agent-initiated: you send a client nomination request, and the client confirms it in the ATO app or Online services for individuals through myGov.

Source: ATO, Client-to-agent linking for individuals and sole traders (published 23 September 2026) and ATO, Client-to-agent linking pilot (last updated 23 September 2026).

How clients are added to your client list today

Companies, trusts, partnerships, SMSFs and other ABN entities

The ATO rolled out client-to-agent linking for ABN entities in 2022 and 2023. It was a response to fraud where agents' digital credentials were compromised and used to link taxpayers without authorisation, lodge false BAS, change bank details and view taxpayer information.

An ABN entity (excluding sole traders) must nominate a registered agent when it engages a new registered agent (tax agent, BAS agent or payroll service provider) or changes the authorisations given to an existing agent, for example when the agent starts on income tax or a new entity in the group. The agent cannot complete the nomination for the client.

The client's steps, per the ATO's nomination instructions (last updated 2 October 2026):

1. Set up a Digital ID. myID is the government Digital ID app. A Strong identity strength needs an Australian passport and photo plus a citizenship certificate, driver licence or Medicare card. A Standard strength needs 2 Australian identity documents, and the client then phones the RAM support line to link the business.
2. Link the Digital ID to the ABN in Relationship Authorisation Manager (RAM). The principal authority has to be the first person to set up access.
3. Log in to Online services for business.
4. Nominate the agent under Profile, Agent details, Agent nominations, Add. The client needs your registered agent number, then completes the declaration and submits.
5. Tell the agent. The ATO does not notify you. You have 28 days from the nomination to add the client, after which it expires. The client can use Extend, available from the day after submitting, to add another 28 days from the day they extend. An expired nomination cannot be extended.

If a client cannot complete the process online, the ATO says they can phone the Business enquiries line on 13 28 66, with your registered agent number ready.

Individuals and sole traders

Individuals and sole traders are outside client-to-agent linking today. There is no client-side nomination step. The ATO has confirmed that existing agent authorisation and access arrangements remain unchanged while the new process is refined. Your existing obligations as a registered tax practitioner still apply: you need the client's authority to act, and you need to verify their identity under TPB(GS) 42/2022 (covered below).

What changes for individuals and sole traders

The ATO describes the new model in four parts:

• Agents initiate a client nomination request through Online services for agents or their practice software.
• Clients review and confirm the request in the ATO app or Online services for individuals (accessed through myGov).
• Once confirmed, the agent can add the client to their client list and access their tax record.
• Assisted and non-digital pathways are being developed for taxpayers who cannot engage digitally or need extra support.

Two differences from the ABN entity process matter for workflow. First, the request starts with you, not the client. The ATO chose this after consultation showed agents preferred it. Second, the client confirms through their personal myGov or ATO app access, not through a business Digital ID linked in RAM. The ATO has said this does not replace or change the existing CAL process for ABN entities.

When it applies

The ATO says the process will apply only when an individual or sole trader wants to appoint a new registered agent or changes the authorisations given to an existing agent. Clients already on your list are not described as needing to re-link. The ATO's small business newsroom puts it to sole traders this way: a new authorisation step "when you engage a new agent or change the authorisations given to an existing agent" (ATO, Client-to-agent linking for sole traders coming soon).

What is not yet published

As at 27 October 2026 the ATO has not published: the identity strength a client needs in myGov or the ATO app to confirm a request, how long a request stays open, the detail of the assisted and non-digital pathways, or how the process handles deceased estates, remote clients and temporary or foreign residents. The ATO has specifically invited pilot participation from agents onboarding those harder cases (ATO, Client-to-agent linking is expanding). We will not guess at these. Check the ATO page before you build anything that depends on them.

Side by side: ABN entities, individuals now, individuals from November 2027

Your TPB obligations do not change

Client-to-agent linking is an ATO access control. It sits on top of, and does not replace, what the Tax Practitioners Board expects before you act for anyone.

Proof of identity: TPB(GS) 42/2022

The TPB requires proof of identity steps for all new clients and individual representatives. For an individual engaging you in their own right, you verify their full name and either their residential address or date of birth, and sight one of:

• an original or certified copy of a primary photographic ID (for example an Australian or overseas driver licence including a digital licence, a passport, a proof of age card or an ImmiCard), or
• both a primary non-photographic ID (such as a birth or citizenship certificate or a government concession card) and a secondary ID (such as an ATO or Centrelink notice from the past 12 months, a rates notice or utility bill from the past 3 months, a Medicare card or electoral roll details).

For a non-individual client, you verify the individual representative the same way, plus the entity's existence (for example an ASIC extract or trust deed) and the representative's authority to engage you (for example a company extract showing them as an officeholder, a trust deed or ABR details).

The TPB does not require or recommend keeping copies of ID. It requires a contemporaneous record, such as a checklist, showing the date and time of the check, who did it, which documents were sighted and whether originals or certified copies, how they were sighted, and confirmation the documents were clear and gave no reason for doubt. Keep that record for at least five years after the engagement ends (TPB(GS) 42/2022; TPB(GS) 52/2024).

Two points from the guidance that matter for remote onboarding:

• If you sight ID over video, the requirements are the same as face to face, and you note in your record that it was by video. If certified copies were sent to you, the TPB strongly recommends destroying them once the record is made.
• The TPB does not recommend receiving ID documents by plain email. It recommends a secure website, secure messaging, or an encrypted or password protected attachment.

Authority to act and letters of authority

Where someone engages you on another person's behalf, the TPB expects you to verify the representative and the legal basis of their authority. Examples include an enduring power of attorney, court order, guardianship document or a letter of authority. The TPB describes a letter of authority as a legal letter (including an email) authorising a third party to act for an individual on the discrete matters listed in it. Depending on the circumstances, it may be appropriate to confirm the authority directly with the principal by phone, video or in person.

Client-to-agent linking will add an ATO-side confirmation from the client, but it is not a letter of authority or an engagement letter. It tells the ATO the client agrees to you seeing their record. Your engagement letter still sets out scope, fees and responsibilities. See the engagement letter template for a starting point.

Frequency of checks

The TPB leaves it to you to decide how often to repeat checks for ongoing clients, considering factors such as the scope of services, whether you deal with them online or in person, changes in their circumstances and any discrepancies. You must record your assessment of the right frequency for each ongoing client.

What to do now: a practical plan

The ATO says no action is required yet. That is true for the ATO process. There is still useful work to do before November 2027, mostly in your own onboarding.

The client onboarding guide and new client checklist cover the rest of the intake sequence.

Worked example: a family group in 2028

The Nguyen family engages your firm in January 2028. The group has a family trust with an ABN, a corporate trustee, and two adults: Linh, a sole trader, and Minh, an employee with a rental property.

• Trust and company. These are ABN entities. Linh, as principal authority, logs in with myID, nominates your firm in Online services for business for each entity and tells you. You add both within 28 days.
• Linh as a sole trader. You send a nomination request from Online services for agents or your practice software. Linh confirms it in the ATO app.
• Minh as an individual. Same as Linh. If Minh has no myGov account, he either sets one up or uses the assisted pathway the ATO has said it is developing.
• Before any of that, you verify Linh's and Minh's identity under TPB(GS) 42/2022, verify the trust and company and Linh's authority as director, and have the engagement letter signed.

Four linking actions, two different ATO processes, and one TPB identity process. Tracking each one on the client file is where most delays will come from.

What clients will need

Client message templates

Adapt these to your firm. Do not include links in SMS messages asking clients to log in to government services; tell clients to open myGov or the ATO app themselves. That habit protects them from scam messages.

Email: individual or sole trader (from November 2027)

SMS: individual or sole trader

Email: company, trust or SMSF (process available now)

Where software fits

The ATO process happens in ATO systems. What a firm controls is everything around it: collecting client details, verifying identity, getting the engagement signed and chasing the client until each link is done. Nagaris puts proposals, AML, e-signing and client queries on one client file, so a family group can be engaged on one proposal and each person verifies their ID on their phone. See client onboarding software.