New client onboarding checklist for accountants

Tick off acceptance, clearance, ABR and ASIC checks, TPB proof of identity, AML/CTF where it applies, a signed APES 305 engagement letter, secure TFN collection and ATO and ASIC authority before work starts.

General information only, not legal or tax advice. Check the current rules against the source before relying on this. Adapt it to your firm's own policies and AML/CTF program. Reviewed 18 October 2026.

One list for taking on a new client, from first call to work started. Copy it into your client file or practice software and tick each line. Run the identity and authority sections once per person and once per entity. The reasoning behind each step is in the client onboarding guide.

How to use it

Work top to bottom. Acceptance and clearance come before the engagement letter is signed.
For a family group, repeat Sections 3, 7 and 8 for each entity.
Record who ticked each item and the date.

1. Enquiry and acceptance

Names of every person and entity in the group recorded
Services and periods needed for each entity recorded
Current or previous accountant identified
ATO debts, audits, reviews or disputes asked about and noted
Any questionable issues about the client, owners or activities considered (APES 110 320.3 A1)
Team has, or can get, the skills needed (APES 110 320.3 A3)
Acceptance decision and reasons recorded

2. Professional clearance

Client's written permission to contact the existing or predecessor accountant obtained (APES 110 320.5 A1)
Clearance request sent, asking for anything you need to know before accepting
Handover items requested: prior returns, workpapers, asset and depreciation registers, deeds, minutes, loan balances, losses, lodgement status
Reply received and reviewed, or other reasonable steps taken if no reply (R320.6)
For audit or review of financial statements: request made under R320.8

3. ABR and entity checks

ABN Lookup run for each entity: ABN active, legal name, GST status match what the client said
ASIC extract obtained for each company and corporate trustee
Trust deed and SMSF deed (with amendments) received
Exact legal names of trustees and trusts confirmed for the engagement letter

4. Proof of identity (TPB(GS) 42/2022)

Each individual client: full name and residential address or date of birth obtained
Each individual: primary photo ID, or primary non-photo ID plus secondary ID, sighted (original or certified copy)
Photo matched to person; names, addresses and dates of birth consistent
Each entity: existence confirmed with ASIC extract or constituting documents
Each representative: identity verified and authority sighted (officeholder extract, minutes, power of attorney or court order)
Method recorded (in person or video)
Record made: date, time, who checked, documents sighted, how sighted, legible and unquestionable
No copies of ID kept; any certified copies destroyed after recording
Record retention set to at least five years after the engagement ends

5. AML/CTF (from 1 July 2026, where applicable)

Each service checked against AUSTRAC's list of accountant designated services
Assessment recorded, including where no designated service applies
If designated: initial CDD done under your AML/CTF program before the service starts
If designated: beneficial owners and people acting for entities identified using AUSTRAC's guides for that customer type
If designated: risk rating recorded

6. Engagement letter (APES 305)

Engagement document covers purpose, scope, outputs, responsibilities, other practitioners, fees and billing, document ownership
Every entity in the group named, with services and fees for each
Signer's authority confirmed for each entity
Privacy collection notice included
Signed copy received and filed, preferably before work commences

7. Privacy and TFNs

Only information the engagement needs requested (APP 3)
Collection notice given (APP 5)
When asking for a TFN: authorising law, purpose and that declining is not an offence explained
TFNs received by phone or secure channel, not ordinary email
TFN access limited to staff who need it

8. ATO authority

Each ABN entity told to nominate the firm in Online services for business
Registered agent number and ATO nomination instructions sent
Nomination confirmation PDF received
Client nominations on-demand report checked
Client added within 28 days of nomination, to the right accounts (income tax with business TFN, activity statement, STP payroll only)
Individuals and sole traders: linked under current ATO arrangements (new nomination process planned from 2027; check ATO page)
No other agent removed without client authority

9. ASIC authority (companies)

Form 362 signed by an officeholder and lodged, or
Corporate key received securely and stored as sensitive

10. Work set up

Jobs, budgets and due dates created for each entity and period
Software and bank feed access received where in scope
Outstanding items listed with who they are waiting on
First reconciliation of prior lodgements and balances scheduled
Welcome message sent with contact person and next steps

Questions

Do I run this checklist once per family group?

Run acceptance, clearance and the engagement letter once for the group, and the identity, ATO and ASIC sections once for each person and entity.

What do I keep as evidence of an identity check?

TPB guidance says to keep a record of the date and time, who checked, the documents sighted and how, and not to keep copies of the ID itself.

Sources

Run this inside Nagaris

Proposals, AML checks, e-signing, client queries and jobs on one client file.

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New client onboarding checklist