Bookkeeper vs BAS agent vs accountant vs CFO in Australia: the seven roles a Shopify founder has to keep straight

We talk to a lot of Australian Shopify and Amazon founders who hired 'an accountant' and assumed they got their GST, books, cashflow forecast, and board pack done. They didn't. One founder we spoke to had a CPA on retainer for two years and only realised the CPA wasn't doing CFO work when the bank asked for a 13-week cashflow and the founder had to build it themselves. That's not the CPA's fault. CFO work isn't in scope. The Australian finance stack is legally fragmented across seven distinct roles, each gated by different regulators (the Tax Practitioners Board for tax and BAS, ASIC for audit, the three professional accounting bodies for the CA/CPA/IPA designation), and the founders who get this right hire to fill the right gap. This post is the role-map: who does what, who's regulated by whom, what they cost in 2026, and when a growing ecom brand should upgrade.

The seven roles and what each one can legally do

This is the AI Overview bait. If you only read one part of this post, read the table below.

Six of these seven roles are gated by a regulator. One isn't. The bookkeeper title is unregulated (anyone can use it, though most credible ones hold FNS40222 Certificate IV in Accounting and Bookkeeping). BAS agents and tax agents are gated by the Tax Practitioners Board (TPB) under the Tax Agent Services Act 2009 (TASA). The CA, CPA, and IPA designations are gated by their respective professional bodies (CA ANZ, CPA Australia, IPA) via a Public Practice Certificate. ASIC registered company auditors are gated by ASIC under Part 9.2 of the Corporations Act 2001. The fractional or virtual CFO title is not gated by anyone.

Role	Regulator	Minimum credential	Legally can	Legally cannot	Typical engagement
Bookkeeper (unregistered)	None (unregulated title)	FNS30322 Certificate III or FNS40222 Certificate IV common but not mandatory	Day-to-day data entry, bank reconciliation, payroll data prep, accounts payable and receivable	Lodge BAS for a fee, prepare tax returns for a fee	Hourly or monthly bundle
Cert IV Bookkeeper (qualified, unregistered as BAS agent)	None (qualification only)	FNS40222 Certificate IV in Accounting and Bookkeeping	Everything an unregistered bookkeeper can do, with formal training credentials	Still cannot lodge BAS or advise on GST for a fee without TPB registration	Hourly or monthly bundle
Registered BAS agent	Tax Practitioners Board (TPB)	FNS40222 plus TPB-approved GST/BAS course plus 1,400 hours experience (1,000 hours for recognised-association voting members)	Prepare and lodge BAS and IAS, advise on GST, PAYG(W), PAYG instalments, fuel tax credits, certain superannuation guarantee functions (TASA s 90-10)	Prepare income tax returns, advise on CGT or FBT (these are tax agent services under s 90-5)	Quarterly BAS bundle or hourly
Registered tax agent	Tax Practitioners Board (TPB)	Accounting degree or equivalent plus tax and commercial law units plus 1 to 4 years experience (TASR Schedule 2)	Everything a BAS agent can, plus prepare and lodge income tax, FBT, company, trust, and SMSF returns. ATO representation and tax structuring	Sign a statutory audit opinion (requires separate ASIC registration)	Annual tax return package or hourly
CA / CPA / IPA member (Public Practice Certificate holder)	CA ANZ / CPA Australia / IPA	Accredited accounting degree plus CA or CPA Program plus typically 3 years practical experience plus Public Practice Certificate	Public accounting services under their body's brand, advisory, management accounting, some assurance engagements	Provide tax or BAS services for a fee without separate TPB registration. Sign a statutory audit without ASIC registration	Monthly retainer or project fee
ASIC Registered Company Auditor	ASIC	CA or CPA plus audit experience plus ASIC registration (Corporations Act Part 9.2; ASIC RG 180)	Sign statutory audit opinions required by the Corporations Act	Act outside audit and assurance unless separately qualified	Annual audit engagement fee
Virtual or fractional CFO	Not regulated (no statutory title)	No formal requirement. Most credible operators hold CA or CPA plus 10 plus years of senior commercial finance experience	Strategic finance, FP&A, cashflow modelling, fundraising support, board reporting	Sign tax returns, BAS, or audit opinions unless separately registered	Monthly retainer (often A$8K to A$15K) or day rate

One regulator point worth making explicit. The Tax Agent Services Act 2009 sections 50-5, 90-5, and 90-10 do most of the heavy lifting here. Section 50-5 prohibits anyone providing tax agent services or BAS services for a fee or reward without TPB registration. Section 90-5 defines what a tax agent service is. Section 90-10 defines what a BAS service is. Those three sections are why you cannot just hire 'a bookkeeper' off Gumtree and have them lodge your BAS even if they're cheaper.

What it actually costs in 2026

Indicative onshore Australian billing rates for 2026, metro mid-tier, reconciled to publicly available 2025 to 2026 finance salary guides plus standard 2.0 to 2.5 times salary-to-billing-rate conversions for contractor work.

The pattern is the one most founders intuit but get wrong on the specifics. Bookkeepers start at A$60 to A$90 per hour for general work and A$90 to A$110 for ecom-specialist work (A2X, Link My Books, multi-channel inventory). BAS agents sit at A$80 to A$150. Tax agents and intermediate public-practice accountants run A$130 to A$180. Senior CA or CPA practitioners are A$170 to A$250. ASIC registered company auditors charge A$280 to A$450 per hour or A$5K to A$100K per engagement depending on the audit's complexity. Fractional CFOs range from A$250 to A$550 per hour or A$8K to A$15K per month on retainer.

Role	Low ($/hr AUD)	High ($/hr AUD)
Onshore bookkeeper (general)	$60	$90
Onshore bookkeeper (ecom-specialist)	$90	$110
Registered BAS agent	$80	$150
Tax agent / intermediate practice accountant	$130	$180
Senior CA/CPA public practitioner	$170	$250
ASIC registered company auditor (signatory)	$280	$450
Fractional CFO	$250	$550

Two reads on the rate gap. First, the jump from senior CA/CPA practitioner (A$170 to A$250) to ASIC registered company auditor (A$280 to A$450) is the regulatory premium for audit-signing capacity, not a quality premium. You only pay it when the Corporations Act forces you to. Second, the fractional CFO range overlaps the ASIC auditor range on the high end because the work is genuinely senior. A founder paying A$15K per month for a fractional CFO is paying for a person who would otherwise be a full-time CFO at A$300K total compensation at a A$30M plus brand.

When the Corporations Act forces a statutory audit

This is the section most founders blow past until their bank or a potential acquirer asks the question.

A proprietary company (a 'Pty Ltd') must appoint an ASIC Registered Company Auditor and prepare audited financial statements once it becomes a 'large proprietary company' under Corporations Act 2001 section 45A. You are large if you meet at least 2 of the 3 thresholds at year-end. Thresholds doubled on 1 July 2019, which is the part most ecom founders missed.

Threshold (meet any 2 of 3)	Pre-1 July 2019	From 1 July 2019
Consolidated revenue	A$25 million	A$50 million
Consolidated gross assets	A$12.5 million	A$25 million
Employees at year-end	50	100

The practical read. If your Pty Ltd is doing A$30M in revenue with A$15M in gross assets and 70 employees, you meet zero of the three thresholds and you do not need a statutory audit. If you cross A$50M revenue and A$25M assets in the same year, you do. Audits also get triggered by shareholder direction under s 293 (5% of shareholders can require it) and by financiers or investors as a condition of a debt facility or capital raise. None of those require the s 45A threshold. The threshold is the floor for mandatory audit, not the ceiling for when an audit is useful.

The role escalation pattern as your Shopify brand scales

The cleanest way to think about staffing your finance stack is by revenue band. Required, recommended, or optional reads differently at A$1M than at A$25M, and the public-company auditor only enters the picture at the top of the range.

Revenue band	Primary finance need	Typical staffing	External auditor required?
Under A$1M	Accurate books plus BAS	Bookkeeper plus tax agent for year-end	No
A$1M to A$5M	Books plus BAS plus tax planning plus simple management reporting	Bookkeeper plus BAS agent plus tax agent	No
A$5M to A$10M	Inventory KPIs plus gross margin plus working capital	Senior bookkeeper plus BAS agent plus tax agent plus part-time fractional CFO	No
A$10M to A$25M	FP&A plus board reporting plus fundraising readiness	Finance manager plus fractional CFO (1 to 2 days per week) plus tax agent	Optional (lender or investor driven)
A$25M to A$50M	Full FP&A plus treasury plus investor reporting	Full-time finance manager plus fractional or full CFO	Recommended (audit-ready)
A$50M plus (or 'large proprietary')	Statutory financial reports plus audit plus group consolidation	Full-time CFO plus finance team plus ASIC registered auditor signatory	Yes (s 45A trigger)

The most common mistake we see at A$5M to A$10M is hiring a second bookkeeper instead of bringing in a fractional CFO. The work piling up at that band is not transactional volume (your bookkeeper can handle that with better tooling). It's the FP&A and gross-margin work that needs a senior brain on it one or two days per week. The second mistake we see at A$10M to A$25M is keeping a generalist tax-focused public practice accountant as the primary finance relationship. They are excellent at year-end tax planning. They are not built to give you a 13-week cashflow.

What generalist AU accountants leave on the table for ecom brands

The most consistent gap. Many excellent CA and CPA practitioners run general practice books across construction, professional services, hospitality, and the occasional Shopify brand. The ecom-specific FP&A capabilities that a A$5M plus brand actually needs sit outside that scope.

Five things specifically. Monthly inventory accounting (FIFO versus weighted average, landed cost capture, stock-in-transit, ageing and obsolescence provisioning) rarely appears in a generalist practice's monthly close. A2X or Link My Books channel mapping (the Shopify, Amazon, eBay, Walmart payout reconciliation work) is increasingly common but still not universal. Returns provisioning (the difference between accrued and realised returns over the next 90 days) is almost never modelled outside the brand itself. Multi-currency consolidation, when your USD entity and AUD entity feed the same group P&L, takes a Xero or NetSuite setup most generalist accountants don't run. And CAC by channel, the metric every Meta-and-Google-funded brand lives and dies by, sits in your ad platforms and Shopify data, not your accounting file.

The escalation point is usually A$5M to A$10M in revenue. The signal isn't the revenue number itself. The signal is that your generalist accountant starts asking questions you've already answered with your operations team because the data lives in a different system.

How to verify any of this in 60 seconds

The four registers that matter. Bookmark them.

Check a tax agent or BAS agent on the TPB Public Register. Search by name or registration number. If they're not there, they cannot legally provide tax or BAS services for a fee. Check an ASIC registered company auditor on the ASIC Auditor Search. Check a CA on the CA ANZ Find a CA directory. Check a CPA on the CPA Australia Find a CPA directory. There is no 'find a fractional CFO' register because no one regulates it.

One founder we spoke to had a CPA on retainer for two years and only realised the CPA wasn't doing CFO work when the bank asked for a 13-week cashflow and the founder had to build it themselves. That's not the CPA's fault. CFO work isn't in scope. The pattern is universal. Match the credential to the job, not the job to the credential you already have.

Sources and methodology

Tax Practitioners Board. The federal regulator for tax and BAS agents. The two definitional sections that do the legal heavy lifting in this post are Tax Agent Services Act 2009 (Cth) section 90-5 (tax agent service) and section 90-10 (BAS service), plus section 50-5 (prohibition on unregistered provision for a fee). Registration qualifications are set out in Schedule 2 of the Tax Agent Services Regulations 2022. The TPB's "Who needs to register," "BAS services," "Qualifications and experience for BAS agents," and "Public Register" pages are the primary citations. The TPB Public Register is the operational tool every founder should bookmark.

ASIC. The Australian Securities and Investments Commission. The large proprietary company definition sits in Corporations Act 2001 (Cth) section 45A. The audit trigger is Corporations Act section 301 (audit requirement for s 292 reports). Auditor registration is governed by Corporations Act Part 9.2 and operationalised by ASIC Regulatory Guide 180. The 2019 threshold change is the Corporations Amendment (Proprietary Company Thresholds) Regulations 2019, which doubled all three trigger numbers effective 1 July 2019.

training.gov.au and the National Training Register. FNS40222 Certificate IV in Accounting and Bookkeeping is the qualification baseline for BAS agent registration and the de facto market standard for bookkeepers. FNS40222 supersedes and is equivalent to the prior FNS40217.

Professional bodies. Three accounting bodies issue Public Practice Certificates in Australia: Chartered Accountants Australia and New Zealand (CA ANZ), CPA Australia, and the Institute of Public Accountants (IPA). A PPC is the body's authorisation to offer accounting services to the public. It does not override statutory TPB or ASIC registration. Those are separate gates.

Salary and billing rate sources. Indicative 2026 rate ranges reconcile the publicly available Lyros 2026 Finance Salary Guide AU, ScaleSuite 2026, Robert Walters Australia 2026 financial accountant survey, and the A-One Outsourcing BAS rate reference. Hays FY25/26 and Robert Half 2026 AU tables are gated behind registration so are not quoted directly. Contractor billing rates are derived from underlying salary bands using a standard 2.0 to 2.5 times salary-to-billing-rate conversion. Fractional CFO retainer figures (A$8K to A$15K per month) are synthesised from multiple 2026 industry pricing guides; no single official AU survey exists for fractional CFO rates.

Limitations. The rate ranges are indicative for onshore metro Australia in mid-tier ecommerce-capable practices. Regional, offshore, and Big 4 rates differ materially. The role-escalation pattern by revenue band reflects standard Australian ecom finance staffing patterns at the time of writing and is not a regulatory requirement (except where Corporations Act s 45A applies). Anyone calling themselves a 'fractional CFO' should be asked about CA or CPA membership and senior commercial finance experience because the title itself is not regulated.

If you have decided you need the role itself and not just compliance, see our virtual CFO for Australian ecommerce brands.

Frequently asked questions

what's the actual difference between a bookkeeper and a bas agent in australia?

A bookkeeper records transactions and reconciles your accounts. A BAS agent is TPB-registered and can lodge your BAS for a fee. Under Tax Agent Services Act 2009 (TASA) s 50-5, an unregistered bookkeeper cannot legally lodge BAS or advise on GST for a fee. If your bookkeeper says they handle your BAS, ask for their TPB registration number and check it on the TPB Public Register at tpb.gov.au/public-register.

do i legally need a registered bas agent or can my unregistered bookkeeper lodge my bas for me?

You need a registered BAS agent (or a registered tax agent) if you are paying them to lodge. TASA s 50-5 makes it a civil penalty offence to provide BAS services for a fee or reward without TPB registration. You can lodge your own BAS directly through ATO Online without a registered agent, but the moment you pay someone else to do it, they need to be on the TPB register.

can my bas agent also do my company tax return?

No. A registered BAS agent is limited to BAS provisions under TASA s 90-10: GST, PAYG withholding, PAYG instalments, fuel tax credits, and certain superannuation guarantee functions. Income tax returns, FBT returns, and CGT advice are tax agent services under s 90-5 and require a registered tax agent.

is a cpa or a ca better for an ecommerce brand?

Both are equivalent for almost all ecom work. CA ANZ (Chartered Accountants Australia and New Zealand) and CPA Australia issue Public Practice Certificates with broadly comparable rigour. What matters more for a Shopify or Amazon brand is whether the person has done multi-channel inventory accounting, A2X or Link My Books reconciliation, and multi-currency consolidation in practice. Ask for two client references at your revenue band before you choose.

what's the minimum qualification to be a bookkeeper in australia?

There is no statutory minimum to call yourself a bookkeeper. The market standard is FNS40222 Certificate IV in Accounting and Bookkeeping (the same qualification required for BAS agent registration). If your bookkeeper is also registered as a BAS agent with the TPB, they have at least FNS40222 plus 1,400 hours of relevant experience in the preceding 4 years.

when do i actually need an external auditor for my pty ltd?

When you become a 'large proprietary company' under Corporations Act 2001 s 45A. You're large if you meet any 2 of these 3 thresholds at year-end: consolidated revenue of A$50M or more, consolidated gross assets of A$25M or more, or 100 or more employees. The thresholds doubled on 1 July 2019. Below those numbers, an audit is only required if shareholders direct it under s 293 or a financier or investor mandates it.

what's the difference between an accountant and a cfo in plain english?

An accountant reads the numbers backward and signs the historical statements. A CFO reads the numbers forward, owns cashflow, FP&A, fundraising, and the operating decisions that show up in next quarter's P&L. Most accountants do not act as CFOs. Most CFOs are not the right person to file your tax return.

how much does a fractional cfo cost in australia in 2026?

Indicative 2026 onshore rates are A$250 to A$550 per hour, or A$8,000 to A$15,000 per month on a retainer. Sources include Lyros, ScaleSuite, and Robert Walters 2026 finance salary guides plus standard 2.0 to 2.5 times salary-to-billing-rate conversions for contractor work. Offshore or hybrid arrangements can run lower, but ask hard questions about who actually does the work and what their AU experience looks like.