Standard
Business
Reporting
Australian Taxation Office –
Client Update 2016 (CUREL.0001,
CUDTL.0001, CUADDR.0001, CUFI.0001,
CURNN.0001, CUEC.0001,
CUMASADD.0001 & CUMASCANCEL.0001)
Business Implementation Guide
Date: 17 October 2016
Production Release - suitable for use
This document and its attachments are Unclassified
For further information or
questions, contact the SBR
Service Desk at
[email protected]
or call 1300 488 231.
International callers may use
+61-2-6216 5577
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
VERSION CONTROL
Version
1.0
Release date
17/10/2016
Description of changes
The following sections have been amended from ATO review
- 2.1: Correct reference of ebMS3.0
- 2.2: Updated text for clarity
- 2.3: Updated text for clarity
- 2.4: Updated note text for clarity
- 2.9: Clarity on CUMAS and the deregistration implications
- 3.1: Updated text for business correctness
- 6.1: Correct reference of ebMS3.0
Based on legislative changes, the following sections have been
modified to remove references to ‘gender’ in the CU services
- 2.4
- 4.3
VERSION 2.0
UNCLASSIFIED
PAGE 2 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
ENDORSEMENT
APPROVAL
Pam Edward
Acting Director
Service Delivery
Australian Taxation Office
David Baker
Director
Tax Practitioner, Lodgment Strategy and Compliance Support
Australian Taxation Office
Copyright
© Commonwealth of Australia 2016 (see exceptions below).
This work is copyright. Use of this Information and Material is subject to the terms and conditions in the
"SBR Disclaimer and Conditions of Use" which is available at http://www.sbr.gov.au. You must
ensure that you comply with those terms and conditions. In particular, those terms and conditions include
disclaimers and limitations on the liability of the Commonwealth and an indemnity from you to the
Commonwealth and its personnel, Standard Business Reporting Agencies and their personnel.
You must include this copyright notice in all copies of this Information and Material which you create. If
you modify, adapt or prepare derivative works of the Information and Material, the notice must still be
included but you must add your own copyright statement to your modification, adaptation or derivative
work which makes clear the nature of your modification, adaptation or derivative work and you must
include an acknowledgement that the adaptation, modification or derivative work is based on
Commonwealth or SBR Agency owned Information and Material. Copyright in SBR Agency specific
aspects of Standard Business Reporting Taxonomy is owned by the relevant SBR Agency.
VERSION 2.0
UNCLASSIFIED
PAGE 3 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
TABLE OF CONTENTS
1.
2.
3.
4.
5.
6.
Introduction ...........................................................................................................................................5
1.1
Purpose ........................................................................................................................................5
1.2
Audience .......................................................................................................................................5
1.3
Document Context ........................................................................................................................5
1.4
Glossary ........................................................................................................................................6
What are the Client Update Services? .................................................................................................8
2.1
Channels .......................................................................................................................................8
2.2
Add Client Role Relationship (CUREL.Lodge) .............................................................................8
2.3
Remove Client Role Relationship (CUREL.Lodge) ......................................................................9
2.4
Update Client Details (CUDTL.Lodge) .........................................................................................9
2.5
Update Client Address (CUADDR.Update) ..................................................................................9
2.6
Maintain Electronic Contact (CUEC.Lodge) ...............................................................................10
2.7
Add/Update Client Lodgment Obligation Status (CURNN.Lodge) .............................................10
2.8
Maintain Client Financial Institution Account (CUFI.Lodge) .......................................................10
2.9
Maintain Activity Statement Role (CUMAS.Add and CUMAS.Cancel) ......................................10
Authorisation .......................................................................................................................................12
3.1
Intermediary Relationship ...........................................................................................................12
3.2
Access Manager .........................................................................................................................12
3.2.1
Initiating Parties ......................................................................................................................12
3.2.2
Permissions ............................................................................................................................14
Constraints and Known Issues ...........................................................................................................16
4.1
Constraints When Using These Services ...................................................................................16
4.2
Add/Remove Client Relationship Service ...................................................................................16
4.3
Update Client Details Service .....................................................................................................16
4.4
Update Client Address Service ...................................................................................................16
4.5
Maintain Client Electronic Contact Service.................................................................................17
4.6
Add/Update Client Lodgement Obligation Service .....................................................................17
4.7
Maintain Client Financial Institution Account Service .................................................................17
4.8
Maintain AS Role Service ...........................................................................................................17
4.9
Known Issues .............................................................................................................................17
Taxpayer Declarations ........................................................................................................................18
5.1
Suggested Wording ....................................................................................................................18
Client Update Services Guidance .......................................................................................................19
6.1
Differences Between ELS and SBR ...........................................................................................19
6.2
Orchestration of Address or Electronic Contact Additions, Updates and Deletions ...................19
6.3
Maintain AS Role - Use of Non-Individual Name for Sole Traders ...........................................20
6.4
Deleting an AS ROLE Financial Institution Account ...................................................................20
6.5
Notifying the ATO of an Individual Taxpayer’s Death .................................................................20
6.6
Removing a Relationship Where the Client’s Address is Unknown ...........................................20
Table 1: Interactions available for update of client information ................................................................... 8
Table 2: Channel availability of Client Update interactions ......................................................................... 8
Table 3: Client Update service permissions .............................................................................................. 14
Table 4: Access Manager permissions...................................................................................................... 15
Table 5: General constraints ..................................................................................................................... 16
Table 6: Add/Remove Client relationship constraints................................................................................ 16
Table 7: Update Client details constraints ................................................................................................. 16
Table 8: Update Client address constraints .............................................................................................. 17
Table 9: Update Client address constraints .............................................................................................. 17
Table 10: Maintain Client address constraints .......................................................................................... 17
Table 11: Maintain AS Role constraints .................................................................................................... 17
Table 12: Differences between ELS and SBR .......................................................................................... 19
VERSION 2.0
UNCLASSIFIED
PAGE 4 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
1. INTRODUCTION
1.1 PURPOSE
The purpose of this document is to provide information that will assist software developers in
understanding the business context surrounding Client Update interactions with the Australian Taxation
Office (ATO) through the Standard Business Reporting (SBR) platform.
This document defines each of the services that are available to update client details held on the ATO’s
client register, outlines which reporting parties can use each of the services and explains any constraints
and known issues with the use of the services.
Specifically, Client Update refers to the interactions with the ATO for a user, depending on their role, to:
 add or remove their relationship with a client
 change contact details of a client for the income tax return and activity statement interactions
 maintain client financial institution details
 advise return not necessary, and
 maintain the Activity Statement (AS) roles
1.2 AUDIENCE
The audience for this document is any organisation that will be building any ATO SBR services into their
products. Typically this will be software application developers and business analysts.
1.3 DOCUMENT CONTEXT
The ATO Client Update Business Implementation Guide forms part of the broader suite of documents
used by the ATO to describe or interpret how the technical implementation relates back to the business
context and process. This document is designed to be read in conjunction with the ATO SBR
documentation suite including the:



Web service/platform information
Message information eg ATO Message Implementation Guide, and
Test information eg Conformance suites
See the SBR high level document map for the relationship of this document with others in the suite.
VERSION 2.0
UNCLASSIFIED
PAGE 5 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
1.4 GLOSSARY
This table only contains terms that need specific explanation for this document. Other terminology can
be found in the SBR glossary.
Term
Definition
ABN
Australian Business Number
(for full definition please see the SBR Glossary)
AS
Activity Statement
AS Role
The role type signifying that a client has an obligation to lodge Activity
Statements.
ATO
Australian Taxation Office
BAS
Business Activity Statement
BMS
Business Management Software
Business
Intermediary
A business or individual appointed by another business to be their agent (but the
appointee is not a registered tax or BAS agent).
See business appointments page on the ATO website for more information.
Client
For the purpose of the client update services, a client can be either an individual
or a non-individual entity.
ebMS3.0
ebXML Messaging Service, version 3.0
(for full definition please see the SBR glossary)
ELS
Electronic Lodgment Service
(for full definition please see the SBR Glossary)
FIA
Financial Institution Account
FRNN
Further returns not necessary
FTC
Fuel Tax Credit
GST
Goods and Services Tax
Intermediary
A party that facilitates a transaction between a taxpayer and the ATO
IT
Income Tax
IT role
The role type signifying that a client has an obligation to lodge Income Tax
Returns.
LCT
Luxury Car Tax
Non-Individual
Non-individual entities include companies, partnerships, trusts, funds and selfmanaged superannuation funds.
VERSION 2.0
UNCLASSIFIED
PAGE 6 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Term
Definition
RNN
Return not necessary
SBR
Standard Business Reporting
(for full definition please see the SBR Glossary)
Tax practitioner
Tax agent or a BAS agent
WET
Wine Equalisation Tax
VERSION 2.0
UNCLASSIFIED
PAGE 7 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
2. WHAT ARE THE CLIENT UPDATE SERVICES?
The Client Update suite of services allow tax practitioners, businesses and intermediaries using SBRenabled software to interact electronically with the ATO in the management of their clients’ details. Each
interaction will initiate a request to add, update or remove client information held on the ATO Client
Register. Below is a list of interactions to be provided through SBR.
Interaction
Short Description
Single
Batch
CUREL.Lodge
Add or remove a link between a client
and the tax practitioner for an IT and/or
AS role
Y
Y
CUDTL.Lodge
Advise non-individual change of legal
name or advise that an individual
taxpayer is deceased
Y
Y
CUADDR.Update
Add, update or remove addresses
Y
Y
CUEC.Lodge
Add, update or remove electronic
contact information
Y
Y
CURNN.Lodge
Advise a return is not necessary
Y
Y
CUFI.Lodge
Advise changes to the financial
institution details
Y
Y
CUMAS.Add
CUMAS.Cancel
Add or remove obligations to a client’s
AS Role
Y
Y
Table 1: Interactions available for update of client information
2.1 CHANNELS
The Client Update interactions are available in the following channels:
Interaction
SBR Core Services
SBR ebMS3.0
CUREL.Lodge
N
Y
CUDTL.Lodge
N
Y
CUADDR.Update
N
Y
CUEC.Lodge
N
Y
CURNN.Lodge
N
Y
CUFI.Lodge
N
Y
CUMAS.Add
N
Y
CUMAS.Cancel
N
Y
Table 2: Channel availability of Client Update interactions
2.2 ADD CLIENT ROLE RELATIONSHIP (CUREL.LODGE)
This service allows a tax practitioner to add a relationship with a client for a particular role. This is
required for income tax or activity statement role purposes, and creates a permission in ATO systems to
allow tax practitioners to access client information and lodge on their behalf.
A relationship must already exist between the tax practitioner and client before a tax practitioner can
interact with the ATO on their behalf. This approach is significantly different to the same function in
ELS where the link between the tax practitioner and the client was automatically established when a tax
practitioner performed a lodgment or submission on behalf of that client. This difference may frustrate
VERSION 2.0
UNCLASSIFIED
PAGE 8 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
some users who are used to the ELS approach and so messaging and responses to users will need to
reflect this difference to deliver the best user-experience.
When adding a client, if a relationship already exists for that client and another tax practitioner for that
particular role type, that relationship will cease to exist (through the setting of an end date for the period
of that relationship).
If a taxpayer appoints a tax agent for their income tax obligations, and a different Tax Practitioner (i.e.
BAS Agent) for their activity statement obligations, a change of tax agent for their Income Tax role will
not affect their relationship with the BAS agent for their Activity Statement role.
Note: SBR cannot be used to create or update authorised contacts. Primary contacts can authorise
contacts to act on their behalf to contact the ATO in relation to some or all of the entity's tax affairs.
This process in handled independently from SBR.
2.3 REMOVE CLIENT ROLE RELATIONSHIP (CUREL.LODGE)
This service is used to remove the relationship between the tax practitioner and the taxpayer. The ATO
recommends that tax practitioners update the client’s address prior to removing the relationship,
particularly if the agent has used their address as the primary address for their client. This will ensure
that the ATO has up to date records if required to contact the taxpayer regarding any tax affairs, and that
any correspondence sent to client will go to the the correct address/contact.
Tax practitioners utilising SBR-enabled software are encouraged to remove old client listings to ensure
the ATO systems accurately reflect their current client listings.
2.4 UPDATE CLIENT DETAILS (CUDTL.LODGE)
For trust, superannuation fund and partnership taxpayers, this service can be used to notify the ATO of a
change of legal name. This can be performed by the business themselves, a business intermediary or
their tax agent. However, companies registered with the Australian Securities & Investment Commission
(ASIC) cannot have their legal name updated via SBR. Similarly, trading names cannot be updated
through SBR.
Another function this service provides is for tax agents to notify the ATO when an individual taxpayer is
deceased.
Note: Tax agents are able to act on behalf of individual taxpayers to update taxpayer details, but this
service cannot be used to update taxpayer name or date of birth as the taxpayer’s identity needs
to be verified for this to occur. These updates must be initiated by the taxpayer via the ATO Online
services, phone or post.
See name changes for individuals and sole traders on the ATO website for further information.
2.5 UPDATE CLIENT ADDRESS (CUADDR.UPDATE)
This service is used to notify the ATO of a new or updated address to be applied to the ATO client
register for either income tax or activity statement obligations. This interaction will allow a tax
practitioner, business or business intermediary to advise of additions, updates for the following address
types:



Individual taxpayer residential address (by tax agents only)
Postal address
Business address
This service provides the ability to advise the ATO if an address is incorrect.
Since the address details for these roles are held separately in ATO systems, updating one role will not
automatically update the others. Each role will need to be updated separately
Note: The business or postal address of an entity with an ABN must update the above through the
Australian Business Register (ABR). However the ABN holder’s ATO held business or postal
VERSION 2.0
UNCLASSIFIED
PAGE 9 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
address for IT and AS Role obligations are recorded separately from the entity’s addresses in ATO
systems and can be updated through this service.
2.6 MAINTAIN ELECTRONIC CONTACT (CUEC.LODGE)
The Maintain Electronic Contact interaction will allow a tax practitioner, business or business
intermediary to advise of changes to the following electronic contact types:





Business Hours Phone Number
After Hours Phone Number
Mobile Phone Number
Fax Number
Email Address
Since the electronic contact details for these roles are held separately in ATO systems, updating
one role will not automatically update the others. Each role will need to be updated separately.
Note: As with CUADDR.Update an entity with an ABN must update their own electronic contacts through
the ABR. However the ABN holder’s ATO held electronic contacts for their IT role and AS Role
obligations are recorded separately from their entity’s contact information in ATO systems and can
be updated through this service.
2.7 ADD/UPDATE CLIENT LODGMENT OBLIGATION STATUS (CURNN.LODGE)
Tax agents will have the ability to notify the ATO if their clients do not need to lodge an income tax return
for a reporting period. Tax agents need to provide this notification to the ATO, not only to keep their
clients’ affairs in order but also to ensure their on-time lodgment performance is calculated only on clients
who have a requirement to lodge. This notification needs to be done prior to the lodgment due date.
This keeps their client list up to date and accurately reflects their on-time lodgment performance.
The Client Lodgment Obligation service can be used to advise when:

a return is not necessary (RNN)
o Where no obligation to lodge an income tax return for one or more years

further returns are not necessary (FRNN)
o Client no longer has an obligation to lodge further income tax returns,
commencing from the financial year ending
For more information refer to the lodgment program page on the ATO website.
2.8 MAINTAIN CLIENT FINANCIAL INSTITUTION ACCOUNT (CUFI.LODGE)
The fastest, most secure way for taxpayers to receive refunds is through electronic funds transfer (EFT)
into an Australian financial institution account (FIA). This can be done by the tax practitioner, business or
business intermediary. The Maintain Client FIA Details interaction has been designed to facilitate this
functionality by allowing users to add, update or remove their client's financial institution details via the
SBR channel. The FIA details can be added, updated or removed for either a taxpayer’s AS or IT roles.
2.9 MAINTAIN ACTIVITY STATEMENT ROLE (CUMAS.ADD AND
CUMAS.CANCEL)
The Maintain AS Role interactions will allow a tax practitioner, business or business intermediary to add
or remove the following lodgment obligations against an existing AS role:
 Pay As You Go Withholding (PAYGW)
 Goods and Services Tax (GST)
 Luxury Car Tax (LCT)
VERSION 2.0
UNCLASSIFIED
PAGE 10 OF 20
STANDARD BUSINESS REPORTING


ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Wine Equalisation Tax (WET)
Fuel Tax Credit (FTC)
The Pay As You Go Withholding (PAYGW) role can apply to entities with or without an ABN. All other
registrations mentioned above apply to entities that have an ABN.
To register for Luxury Car Tax, Wine Equalisation Tax or Fuel Tax Credit a client must already be
registered for GST.
De-registering for the GST role will cancel all sub roles including Fuel Tax Credit (FTC), Luxury Car Tax
(LCT) and Wine Equalisation Tax (WET).
VERSION 2.0
UNCLASSIFIED
PAGE 11 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
3. AUTHORISATION
3.1 INTERMEDIARY RELATIONSHIP
The SBR services that a tax practitioner or business intermediary can use on behalf of their clients
depend on the activity being undertaken and whether they have a relationship with the client. For
example:



A tax agent has the appropriate authorisation for the interaction being performed on behalf of the
taxpayer recorded in ATO systems.
To use the Manage Client Details client update service interaction for income tax purposes, the
tax agent must be linked at the whole of client level in ATO systems.
A business intermediary must be appointed by a business in Access Manager to use the
available services on their behalf.
The tax practitioner or business intermediary to taxpayer relationship is a fundamental
precondition to interacting with SBR for client update service interactions
3.2 ACCESS MANAGER
AUSkey and Access Manager are used to manage access and permissions for SBR web services. The
initiating parties authorised to use each service and the Access Manager permissions required for a
business or intermediary are shown below.
For more information on Access Manager, see the ATO website. For further information on AUSkey,
see the Australian Business Register’s website.
3.2.1 INITIATING PARTIES
Activity
Manage Client
Relationships
CUREL.Lodge
Add Client Relationship
for AS role

Add Client Relationship
for IT role (Non-individual
& Individual)
Remove Client
Relationship
for AS role
Remove Client
Relationship
for IT role (Non-individual


Business
Intermediary
Interaction
Business
Service
BAS agent
Tax agent1
ATO systems will check that the initiating party is allowed to use the interaction that is received through
the SBR channel.



1
A tax agent should only make changes to an AS role or its associated details where they represent the
taxpayer for those obligations.
VERSION 2.0
UNCLASSIFIED
PAGE 12 OF 20
Business
Intermediary
Activity
Business
Interaction
BAS agent
Service
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Tax agent1
STANDARD BUSINESS REPORTING
& Individual)
Manage Client
Details
CUDTL.Lodge
CURNN.Lodge
CUADDR.Update
CUFI.Lodge
CUEC.Lodge
VERSION 2.0
Advise Change of legal
name (Non-individual Trust)
Advise Change of legal
name (Non-individual Super Fund)
Advise Change of legal
name (Non-individual Partnership)
Update Client Deceased
(Individual)









Update Client Lodgment
Obligation Status
for IT role
- Advise return not
necessary (RNN)
Update Client Lodgment
Obligation Status
for IT role
- Advise further returns
not necessary (FRNN)
Add/Update Postal,
Business or Residential
Address for IT role
(Individuals only)

Add/Update Postal or
Business Address
for IT Role (Nonindividual)



Add/Update Postal or
Business Address
for AS Role (ABN holder)
Add/Update Postal or
Business Address
for AS Role (Non-ABN
holder)
Add, update or remove
Financial Institution
Account details
for IT role
Add, update or remove
Financial Institution
Account details
for AS role
Add, update or remove for
IT role:
 email address
 after hours
telephone number












UNCLASSIFIED







PAGE 13 OF 20
Business
Intermediary
Activity
Business
Interaction
BAS agent
Service
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Tax agent1
STANDARD BUSINESS REPORTING

business hours
telephone number
 mobile number
 fax number
Add, update or remove for
AS role (ABN holder):
 email address
 after hours
telephone number
 business hours
telephone number
 mobile number
 fax number




email address
after hours
telephone number
 business hours
telephone number
 mobile number
 fax number
Add PAYGW role (nonABN holder)


Remove PAYGW role
(non-ABN holder)


Add ABN holder roles:


Add, update or remove for
AS role (Non-ABN
holder):










Maintain Activity
Statement Role
CUMAS.Add
CUMAS.Cancel


PAYGW
GST
o LCT
o FTC
o WET
Remove ABN holder
roles:


PAYGW
GST
o LCT
o FTC
o WET
Table 3: Client Update service permissions
3.2.2 PERMISSIONS
The below table references the SBR service to the relevant permission in Access Manager:
VERSION 2.0
UNCLASSIFIED
PAGE 14 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Interaction
Initiating
Party
Access Manager Permission
CUREL.Lodge
Tax agent or
BAS agent
Add / Delete Client
CUDTL.Lodge
Tax agent
Update client registration details
Business or
Business
Intermediary
Update business registration details
CURNN.Lodge
Tax agent
Update client registration details
CUADDR.Lodge
Tax agent or
BAS agent
Update client registration details
Business or
Business
Intermediary
Update business registration details
Tax agent or
BAS agent
Update client registration details
Business or
Business
Intermediary
Update business registration details
Tax agent or
BAS agent
Add / update financial institution details
Business or
Business
Intermediary
Add / update financial institution details
Tax agent or
BAS agent
Update client registration details
CUEC.Lodge
CUFI.Lodge
CUMAS.Add
CUMAS.Cancel
Business or
Update business registration details
Business
Intermediary
Table 4: Access Manager permissions
VERSION 2.0
UNCLASSIFIED
PAGE 15 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
4. CONSTRAINTS AND KNOWN ISSUES
These interactions have the following unique constraints:
4.1 CONSTRAINTS WHEN USING THESE SERVICES
#
Constraint
1.
Although batch requests can be sent for each AS or IT role, a combination of AS and IT requests
cannot be sent in a single message.
2.
For an individual only family name and first given name are valid for client name. For nonindividuals, only organisation name is valid for client name.
The exception to this is for Maintain AS when organisation name is used for some individual
clients – see Section 5.3.
Table 5: General constraints
4.2 ADD/REMOVE CLIENT RELATIONSHIP SERVICE
#
Constraint
3.
Businesses and business intermediaries are not authorised to perform the Add/Remove Client
Relationship interaction to add a relationship. A business or a business intermediary cannot
create a client link with another entity within ATO systems; therefore the service is not available
to them.
4.
BAS agents may not add a taxpayer as a client where the obligation/role type is for income tax
returns (IT role).
Table 6: Add/Remove Client relationship constraints
4.3 UPDATE CLIENT DETAILS SERVICE
#
Constraint
5.
Name and DOB updates for Individuals are not permitted as these require verification of identity.
6.
Either an individual death notification or non-individual legal name change can be performed per
message, not both in one message.
Table 7: Update Client details constraints
4.4 UPDATE CLIENT ADDRESS SERVICE
#
Constraint
7.
Residential address can only be added or updated by a tax agent for an individual client.
8.
Entities (individual or non-individual) that are registered for an ABN can only add or update their
ABR addresses through the Australian Business Register, not through this service.
9.
Only one instance of an address type (eg residential, business or postal address) can be added,
or updated per message.
10.
AS and IT address updates must be provided in separate messages.
VERSION 2.0
UNCLASSIFIED
PAGE 16 OF 20
STANDARD BUSINESS REPORTING
11.
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
Business, postal and residential addresses cannot be deleted through the SBR channel.
Table 8: Update Client address constraints
4.5 MAINTAIN CLIENT ELECTRONIC CONTACT SERVICE
#
Constraint
12.
Only one instance of an address type (eg mobile number) can be added, updated or deleted per
message
13.
Entities (individual or non-individual) who are registered for an ABN can only update their ABR
electronic contacts through the Australian Business Register, not through this service.
14.
Electronic contact additions, updates or deletions are only allowed for either the AS role or IT
role in a single message.
4.6 ADD/UPDATE CLIENT LODGEMENT OBLIGATION SERVICE
#
Constraint
15.
A maximum of 20 years of returns not necessary can be reported for a single taxpayer per
message.
Table 9: Update Client address constraints
4.7 MAINTAIN CLIENT FINANCIAL INSTITUTION ACCOUNT SERVICE
#
Constraint
16.
Only one set of financial institution account details for one role type shall be added, updated or
removed per message.
Table 10: Maintain Client address constraints
4.8 MAINTAIN AS ROLE SERVICE
#
Constraint
17.
Cancelation and registration requests cannot both be included in a single message.
18.
When adding PAYGW role information use the TFN of the entity rather than the ABN.
Table 11: Maintain AS Role constraints
4.9 KNOWN ISSUES
N/A
VERSION 2.0
UNCLASSIFIED
PAGE 17 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
5. TAXPAYER DECLARATIONS
Each time an intermediary lodges an approved form on behalf of a taxpayer the law requires the
intermediary to have first received a signed written declaration from that taxpayer.
Developers of SBR-enabled software products may elect to provide a printable version of the taxpayer
declaration within their products to assist intermediaries.
A taxpayer declaration must be obtained by the intermediary for all lodgment obligations
performed on behalf of a taxpayer
This declaration, for the Client Update services, is only applicable to the CUADDR interaction.
For information on the retention of declarations and frequently asked questions, please refer to the ATO
website.
For more information on the declaration between the reporting party or intermediary and the ATO, see
the Common Message Implementation Guide.
5.1 SUGGESTED WORDING
Privacy
For information about your privacy, visit our website at ato.gov.au/privacy
Declaration
I declare that:
 All of the information I have provided to the agent for the preparation of this document is true and correct
 I authorise the agent to give this document to the Commissioner of Taxation.
VERSION 2.0
UNCLASSIFIED
PAGE 18 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
6. CLIENT UPDATE SERVICES GUIDANCE
6.1 DIFFERENCES BETWEEN ELS AND SBR
Below describes key differences between the functionality provided via the ELS CU form, and the SBR
Client Update service.
Functionality
ELS
SBR ebMs3.0
Update mechanism
Via CU form
Via 7 web services
Tax agent
Initiating parties
Tax agent
BAS agent
Businesses
Business Intermediaries
Time taken to update register
Up to 2 days
Immediate
Error handling
Gateway validation
only
Channel and ATO
system validation
Multiple provision of return not necessary years
No, one year per
form
Yes, up to 20 years per
message, via CURNN
Providing date of death
No
Yes, via CUDTL
Electronic contact detail, including email and mobile
number
No
Yes, via CUEC
Provision of client bank account details
No
Yes, via CUFI
Registration of activity statement role types
No
Yes, via CUMAS
Table 12: Differences between ELS and SBR
6.2 ORCHESTRATION OF ADDRESS OR ELECTRONIC CONTACT ADDITIONS,
UPDATES AND DELETIONS
To update an electronic contact using CUEC.Lodge, only the new information needs to be provided in a
message. There is no need to provide a deletion message for the previous one unless the intention is to
remove the contact information entirely. The message containing the new information will end date the
former information in ATO systems and add the new one. When an electronic contact is ‘deleted’ it is not
removed from the ATO systems, but only end dated and retained in history.
A CUEC.Lodge message can contain a mixture of updates, additions or deletions for one role only but no
more than one address of each type can be included in one message.
A CUADDR.Update message can contain a mixture of additions and updates for one role only and like
CUEC.lodge, these are one address type only per message.
For example a CUEC.Lodge message for a taxpayer’s AS role could contain:



An email address addition
A mobile number deletion, and
An after-hours telephone number update.
However, for example, two after-hours telephone numbers cannot be provided in a single message either
as a combination of an addition, update or deletion.
VERSION 2.0
UNCLASSIFIED
PAGE 19 OF 20
STANDARD BUSINESS REPORTING
ATO CLIENT UPDATE 2016 BUSINESS IMPLEMENTATION GUIDE
6.3 MAINTAIN AS ROLE - USE OF NON-INDIVIDUAL NAME FOR SOLE
TRADERS
When adding an AS role for a sole trader, i.e. an individual with an ABN, their first name, followed by a
space and their last name should be populated in the Non-individual name element (SBR alias CUMAS3)
eg John Smith.
The Individual Family Name (SBR alias CUMAS5) or Individual First Given Name (SBR alias CUMAS6)
should not be included in the message as having both individual and non-individual elements is not a
valid combination.
6.4 DELETING AN AS ROLE FINANCIAL INSTITUTION ACCOUNT
While it is possible to remove an AS role financial institution account from the client’s record, it is strongly
recommended not to do so without replacing it with a substitute bank account. AS refunds are all issued
by electronic funds transfer and therefore a refund cannot be issued without a valid bank account being
present.
6.5 NOTIFYING THE ATO OF AN INDIVIDUAL TAXPAYER’S DEATH
Using the CUDTL.Lodge interaction will allow a tax agent to notify the ATO of a taxpayer’s death. ATO
systems require the message to have the Current Individual Title (SBR alias CUDTL19) contain the value
“Executor for” when the Deceased Indicator (SBR alias: CUDTL25 / ELS tag: BFM) is set to true. The
Date of Death (SBR alias CUDTL26) can be included, but this is optional.
6.6 REMOVING A RELATIONSHIP WHERE THE CLIENT’S ADDRESS IS
UNKNOWN
When a tax practitioner removes a taxpayer from their client list using the Add/Remove Client
Relationship interaction, the ATO recommends they update the taxpayer’s address. This can be done
using the Update Client Address interaction.
This is to ensure the ATO has the latest taxpayer address details for further correspondence and that the
tax practitioner does not receive any on their behalf when the taxpayer is no longer their client.
If their client’s address is unknown, use the ‘Address No longer Correct’ element (SBR alias:
CUADDR24). This will ensure no further correspondence is sent to the tax practitioner.
VERSION 2.0
UNCLASSIFIED
PAGE 20 OF 20