iscoverThe professional accounting body has welcomed the ATO’s vulnerability framework but believes it needs amendments to “strengthen its clarity and effectiveness”.
Inclusivity and empathy must feature in ATO vulnerability framework, says CA ANZ
23 July 2025
•
8 minute read
CA ANZ has proposed numerous suggestions to the ATO’s draft vulnerability framework in a move to help support the Tax Office’s mission in “fostering a more inclusive and empathetic tax administration”.
In a submission to the ATO, CA ANZ proposed that the vulnerability framework should express recognition of tax agents as partners, provide a broader definition of vulnerable taxpayers and use the Australian Financial Security Authority’s (AFSA) vulnerability framework as a reference for the ATO’s own implementation.
You’re out of free articles for this month
To continue reading the rest of this article, please log in.
Create free account to get unlimited news articles and more!
Susan Franks, CA ANZ tax, superannuation and financial services leader, said the approach of the framework was “aspirational” yet believed the ATO should model the AFSA framework as it was more operational and client-focused in approach.
“It sets out the different vulnerabilities in more detail and sets our specific action items under each of their focus areas of support and services. AFSA’s vulnerability framework may assist the ATO with the development of their processes to deal with various vulnerabilities including how staff may identify vulnerability,” she said.
“To develop effective processes to deal with people with vulnerabilities, the ATO should ensure it is given adequate time and resourcing to enable people with lived and living experiences to take part in the co-design of these processes.”
It was emphasised that the co-design process should also be made in conjunction with people who had lived or were living experience of mental ill health and suicide, their supporters, service provider’s and practitioners.
The body suggested that while the ATO’s framework referred to “partners” and “non-government partners”, it should acknowledge the role of tax agents and professional advisers in supporting vulnerable taxpayers.
According to the submission, tax agents and their role in assisting vulnerable clients should be clearly recognised in the framework, as they were often the first point of contact for individuals and small businesses navigating complex tax obligations.
It was also noted that the framework should clarify that vulnerable taxpayers included small businesses and SMSFs as well as individual taxpayers.
“The framework should acknowledge that small business owners and SMSF trustees can also experience vulnerabilities and be able to rely on this framework,” Franks said.
CA ANZ recommended that the Tax Office prioritise concerns surrounding its debt collection practices, which have been raised previously by multiple sources, including the CA ANZ Aboriginal and Torres Strait Islander panel member Sarah Hyland.
Franks said CA ANZ was committed to and would continue to support initiatives that promoted fairness, transparency and accessibility in the tax system.
“CA ANZ looks forward to continuing to work with the ATO in the design and implementation of processes that will bring the framework to life within the ATO and are keen to raise awareness of these initiatives with our members to assist them in supporting their clients when they develop vulnerabilities.”
You need to be a member to post comments. Become a member for free today!
