Pricing accounting services in Australia
Australian accountants can set any fee they consider appropriate, but APES 305 requires the basis and calculation of fees to be in the engagement document, and APES 110 section 330 treats a fee too low to do the work properly as a threat to competence. Clear scope, written variations and honest price display do most of the work.
What the rules require, and what they leave to you
There is no fee scale for accounting work in Australia. APES 110 says it directly: a member in public practice "might quote whatever fee is considered appropriate," and quoting lower than another accountant "is not in itself unethical." What the standards care about is that the client understands the basis of the fee, that the fee is enough to do the work properly, and that the way you are paid doesn't compromise your judgement.
That leaves most of pricing to the firm. This guide covers the rules first, briefly, then the decisions that actually determine whether a firm's fees work: the pricing method, how to price a family group, scope and variations, annual rollovers, payment terms, and GST on the invoice.
The professional standards on fees
APES 305 Terms of Engagement
The current APES 305 applies to engagements commencing on or after 1 January 2025. Paragraph 3.8 requires the terms of engagement to be recorded in an engagement document. Paragraph 4.8 covers fees: the document should refer to "the basis and calculation of fees," for example time based billing or fixed price contracts, and to "agreed upon billing schedules."
For recurring engagements, paragraphs 5.1 and 5.2 set out when to reissue or amend the engagement document, including where there are significant changes to the engagement, the services, or the terms. A fee change of any size is a good prompt to ask whether that threshold has been crossed.
APES 110 section 330: fees and other remuneration
| Paragraph | What it says | What it means in practice |
|---|---|---|
| 330.3 A1 to A2 | The level of fees might affect your ability to do the work to the required standards. A fee so low the engagement is hard to perform properly creates a self-interest threat to competence and due care. | A loss-leader BAS fee is allowed. Cutting corners to make it pay is not. |
| 330.3 A3 | Relevant factors include whether the client is aware of the terms and "the basis on which fees are determined and which Professional Services are covered." | A clear scope is part of the ethics, not only the commercials. |
| 330.3 A4 | Safeguards include adjusting the fee or the scope, or having an appropriate reviewer review the work. | If the fee is tight, narrow the scope in writing. |
| 330.4 | Contingent fees can create a self-interest threat to objectivity. AUST R330.4.1 prohibits them in specific engagements under APES 215, 225, 330, 345 and 350. | "Percentage of the refund" pricing needs careful thought, and a written agreement on the basis of remuneration is a listed safeguard. |
| AUST R330.5.1 | A member receiving a referral fee or commission must tell the client in writing of the arrangement, the other party, and how the fee or benefit is calculated. | Software or finance commissions belong in the engagement letter or a separate written disclosure. |
| AUST R330.5.2 | No commissions in connection with an assurance engagement. | Keep audit and SMSF audit fees clean of any commission. |
These references are to APES 110 as compiled by the APESB as at July 2025. Check the current compiled version before relying on paragraph numbers.
Should you charge fixed fees, by time or on value?
Most firms end up with a mix. The useful question is which method fits which kind of work.
| Method | Fits best | Main risk | How to manage it |
|---|---|---|---|
| Fixed fee per service | Recurring compliance: tax returns, BAS, financial statements, SMSF administration | Scope creep and messy records eat the margin | Define the inputs you expect, not only the outputs you deliver |
| Time-based | Genuinely uncertain work: ATO reviews, restructures, clean-up of years of unreconciled books | Clients can't budget, and efficiency is penalised | Give an estimate range and agree a point at which you will check in |
| Value-based | Advice where the outcome matters far more than the hours: structuring, sale of a business, succession | Hard to justify without a clear statement of the outcome | Write down what the client is trying to achieve before you price it |
| Subscription (monthly or quarterly) | Clients with ongoing bookkeeping, BAS and advisory needs | Annual work bunched into one quarter while fees arrive evenly | Price on the annual total and spread it; review usage once a year |
Fixed fees are a bet on inputs
A fixed fee for a company tax return is really a fixed fee for a company tax return prepared from reconciled ledgers, with a loan account schedule, and no Division 7A surprises. When those assumptions fail, the fee fails with them. The fix is to price the inputs you expect into the scope, and say what happens when they arrive in a different state. That turns a dispute about the fee into a conversation about the records.
Time is information, even if you don't bill on it
Firms that move to fixed fees often stop recording time. That removes the only data that tells you whether a fee was right. Recording time against a fixed-fee job is not about billing. It is about knowing which clients and which services are profitable when you set next year's fee.
Value pricing without the jargon
Value pricing, done honestly, starts with a question: what is this outcome worth to the client, and what would it cost them to get it another way? A restructure that moves a growing business out of a sole trader structure before a sale is worth more than the hours it takes. A fee that reflects that is fine under APES 110, provided the client understands the basis, and provided the fee isn't contingent on an outcome in an engagement where contingent fees are prohibited or the threat can't be managed.
Not every job has a value story. Most compliance work doesn't. Pretending otherwise produces proposals clients see through.
Pricing a family group
A typical client group in an Australian practice is not one client. It is two individuals, a discretionary trust, a trading company, perhaps a bucket company and an SMSF. Pricing each entity on its own misses how the group actually generates work.
Where the work really sits
- Interdependencies. The trust's distribution resolution affects the individuals' returns and the bucket company. Pre-30 June planning for the group is one piece of work spread across four returns.
- Repeat information. Contact details, ID, related-party loans and minutes cross entities.
- Uneven complexity. The SMSF may be routine while the trust carries the real thinking.
A worked example
The Nguyen family group, all fees GST-exclusive for illustration only:
| Entity | Service | Fee |
|---|---|---|
| Nguyen Family Trust | Financial statements, tax return, distribution minutes | $3,200 |
| Nguyen Pty Ltd (trading) | Financial statements, tax return, quarterly BAS | $5,400 |
| Nguyen Investments Pty Ltd (bucket company) | Financial statements, tax return, Division 7A loan schedule | $1,800 |
| Minh and Lan Nguyen | Individual tax returns | $900 |
| Group | Pre-year-end tax planning meeting and distribution recommendation | $1,500 |
| Total | $12,800 | |
Two things are worth noticing. The planning work is priced once, at group level, rather than buried in four entity fees. And the client sees one number for the group, while the firm can still invoice entity by entity if the trust and company need their own invoices for deductibility.
Deciding who pays matters too. Each entity paying its own fee is usually the cleanest for tax, but some families want one payment. Write down which entity is billed for which service, so the GST and deductibility questions have a clear answer.
Nagaris is built around this. Trusts, companies, SMSFs and individuals go on one proposal, priced together or entity by entity, and the client signs once for the whole group. The group can pay together, entity by entity, or in a split you set. See group proposals and the family group engagement letter template.
Scope and variations
Most fee disputes are scope disputes. A good scope does three things: lists what's included, lists the assumptions behind the price, and says how anything else will be charged.
That last point matters most. A variation the client agreed to before you started is an invoice. A variation they first see on the invoice is an argument.
Unfair contract terms
Engagement letters are usually standard form contracts, and many business clients are small businesses for the purposes of the unfair contract terms laws. From 9 November 2023 the ACCC describes a small business as one with fewer than 100 employees or annual turnover under $10 million. From the same date, proposing, using or relying on an unfair term in a standard form contract is prohibited, and penalties apply. For a business, the maximum is the greatest of $50 million, three times the benefit attributable to the conduct, or 30% of adjusted turnover during the breach period, if the benefit can't be determined.
The ACCC's example is relevant to fee clauses. A term letting one party change the price at any time while the other can't exit is likely unfair. A similar price-change term is likely not unfair if the customer can end the contract without penalty. So a fee review clause works best when it gives notice of the change and lets the client walk away without a break fee. Only a court can decide finally whether a term is unfair, so have your engagement letter reviewed.
Nagaris prices a family group together or entity by entity, and sets up payment in the same step the client signs.
Schedule a demoAnnual rollovers
The annual fee review is where firms either keep their fees honest or quietly lose margin. A rollover process that works:
- Look at last year's actual effort against each fee, by entity and by service. This is where recorded time pays for itself.
- Separate the causes. Was the overrun the client's records, a one-off event, or a fee that was simply too low?
- Change the scope or the fee, not both silently. If records were poor, the fix might be a records standard in the scope rather than a higher fee.
- Reissue or amend the engagement document where APES 305 paragraph 5.2 points that way, for example a significant change to services or terms.
- Give notice early, before the work starts, with the right to decline.
A flat percentage increase across the client list is simple but treats the well-organised client and the shoebox client the same. The well-organised client notices.
Payment terms
How and when you are paid is part of the price. A $5,000 fee paid in advance by direct debit is worth more than a $5,000 fee paid 90 days late after three reminders.
| Approach | Works for | Watch |
|---|---|---|
| Payment details captured at signing, charged on completion | Annual compliance work | Tell the client clearly when the charge will happen |
| Monthly or quarterly recurring billing | Groups with ongoing work and larger annual fees | Reconcile the total once a year against the scope |
| Deposit, then balance on completion | Project and advisory work | Say what happens to the deposit if the job stops |
| Invoice with standard terms | Clients who need it for their own processes | Collections effort is a cost, so price it in |
One change matters from this month. The ACCC states that from 1 October 2026 businesses can no longer add a surcharge for payments made using Visa, Mastercard, American Express and eftpos cards. Firms that used to pass card fees on should review their payment terms and invoices, and factor processing costs into the fee itself.
Nagaris lets clients sign and set up payment in the same step. Payment details can be captured when the engagement is signed, then charged on completion, or set up as recurring monthly or quarterly billing. Direct debit and PayID are 1% plus 30 cents, capped at $5 a payment, and cards are 1.95% plus 30 cents. Payments are matched to the invoice. See payments.
Showing prices honestly
The Australian Consumer Law applies to how fees are advertised and quoted. The ACCC says businesses "must not mislead consumers about their prices" and that information about prices "must be accurate, truthful and based on reasonable grounds." Its examples of misleading price claims include a price shown without GST or other costs included.
The ACCC's price display guidance says a total price must be shown as a single figure, including taxes and unavoidable fees, and that "the total price must be at least as prominent as the partial price." A monthly fee for a 12-month arrangement should sit alongside the annual total. There is one exception that matters for accountants: "If a business is displaying prices only to other businesses, it doesn't need to include GST in the total price." Pricing on a website seen by individuals should include GST.
Practical points for a fee page or proposal:
- "From $X" pricing should be a price some real clients actually pay.
- If a fee depends on records being in order, say so next to the price.
- Don't show a "was" price that was never charged.
Do you charge GST on accounting fees?
Most firms are registered for GST and charge it on their fees. The ATO requires registration when GST turnover is $75,000 or more, measured as total business income, not profit, on a current or projected basis. Once required, registration has to happen within 21 days.
On invoices: if a client asks for a tax invoice, the ATO says you must provide one within 28 days, unless the sale is $82.50 including GST or less. A tax invoice under $1,000 must let the reader identify that it is a tax invoice, your name and ABN, the date, a description, quantity where relevant and price, the GST amount, and the extent each sale is taxable. For $1,000 or more, it also needs the buyer's identity or ABN. Most annual group invoices clear $1,000, so the entity name or ABN of the entity being billed needs to be right. This is another reason to decide which entity pays for which service.
| Fee (GST-exclusive) | GST at one-eleventh of the inclusive price | Total |
|---|---|---|
| $3,200 | $320 | $3,520 |
| $12,800 | $1,280 | $14,080 |
Quote individual clients GST-inclusive. Quote business clients in whichever form is clearer, but state which it is every time.
Putting it together
A fee that works is one the client understood before the work started, that reflects the real effort for that group, that is reviewed each year against what happened, and that is paid on time without chasing. None of that depends on a particular pricing philosophy. It depends on writing things down: the scope, the assumptions, the basis of the fee, and how changes are handled. APES 305 and APES 110 ask for exactly that, and clients tend to respond to it well.
Related: engagement letters guide, engagement letter template, client onboarding guide.
Questions
Is there a set fee scale for accountants in Australia?
No. APES 110 paragraph 330.3 A2 says a member in public practice might quote whatever fee is considered appropriate, but a fee so low that the work can't be done properly creates a self-interest threat.
What does APES 305 require about fees?
Paragraph 4.8 says the engagement document should refer to the basis and calculation of fees, for example time based billing or fixed price contracts, and to agreed billing schedules. The current version applies to engagements commencing on or after 1 January 2025.
Can I charge a card surcharge on client fees?
The ACCC states that from 1 October 2026 businesses can no longer surcharge payments made using Visa, Mastercard, American Express and eftpos cards.
Do unfair contract terms laws apply to engagement letters?
They can. They cover standard form contracts with small businesses, which the ACCC describes as fewer than 100 employees or turnover under $10 million, and penalties apply from 9 November 2023.
Should fees be quoted including GST?
Prices displayed to consumers should include GST in the total price. The ACCC says a business displaying prices only to other businesses doesn't need to include GST in the total.
Do I have to disclose referral fees or commissions?
Yes. AUST R330.5.1 of APES 110 requires written disclosure of the arrangement, the other party, and how the fee or benefit is calculated.
Sources
- APESB, APES 305 Terms of Engagement (September 2024)
- ACCC, Contracts (unfair contract terms)
- ACCC, Businesses urged to remove unfair contract terms ahead of law changes
- ACCC, Advertising and selling guide: Pricing
- ACCC, Price displays
- ACCC, False or misleading claims
- ATO, Registering for GST
- ATO, Tax invoices
- APES 110 Code of Ethics for Professional Accountants (compiled July 2025)
- ACCC: Card surcharges
- RBA: Review of Merchant Card Payment Costs and Surcharging, FAQs
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