iscoverThe Tax Institute has urged the Tax Office to commit to significant investment in the implementation phase of its vulnerability framework to ensure it meets its objectives.
ATO vulnerability framework needs ‘training, transparency, support’: The Tax Institute
05 August 2025
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9 minute read
The Tax Institute is pleased that the ATO has genuinely committed to supporting vulnerable taxpayers, yet believes the proposed vulnerability framework requires significant investment, time and attention.
In a submission made to ATO assistant commissioner, Robert Thomson, The Tax Institute outlined key areas the ATO needed to focus on during the implementation phase of its proposed vulnerability framework.
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These key focus areas included the development of actionable steps, a clear roadmap and timeline for implementation, training ATO staff, ensuring transparency, consistency and accountability across different areas of the ATO and the development of tailored educational material and resources to help taxpayers understand their obligations and rights.
Julie Abdalla, head of tax and legal at The Tax Institute, said that in the development of the submission, the institute consulted with its national technical committees to prepare a considered response that represented the views of its broader membership base.
“Attention to these matters will help to ensure that the vulnerability framework meets its objectives. We acknowledge that not all the changes required will be able to be given immediate effect. It will therefore be important to identify how these and other related matters will be prioritised and actioned,” she said.
“We are committed to shaping the future of the tax profession and the continuous improvement of the tax system for the benefit of all. In this regard, The Tax Institute seeks to influence tax and revenue policy at the highest level with a view to achieving a better Australian tax system for all.”
Based on consultation released by the ATO, the institute said it adequately outlined the ATO’s commitments to supporting individuals experiencing vulnerability through its core focus areas and guiding principles.
The institute noted that internal controls and protocols to ensure the effective implementation of the framework, and an outline of the ATO’s successful commitment to it, should be measured, documented and made publicly available for accountability purposes.
In addition, it said it looked forward to continued engagement on the implementation of the framework when in practice to help best serve the overarching purpose of enhancing support for vulnerable taxpayers in their dealings with the ATO.
“We acknowledge that ATO staff and, equally, tax practitioners, may not possess all of the necessary qualifications to fully support vulnerable taxpayers,” Abdalla said.
“To address this gap, it is recommended that mental health professionals, financial counsellors, and other support services be involved in the process. Continuous collaboration will help to ensure that vulnerable individuals receive the appropriate support and understanding during their interactions with the ATO.”
The framework was commended for its use of clear and easy-to-understand language, as well as the fluidity of the definition of ‘vulnerable’, as well as articulating a strong commitment to values such as empathy, fairness, inclusion and respect.
Despite this, The Tax Institute said that while the framework currently spoke on “creating a support and respectful environment”, it did not detail the steps the ATO would take in response to vulnerability.
The institute said the framework would benefit from greater clarity on these principles and how it would translate into practical, measurable actions, such as incorporating more action-oriented commitments.
“This would also better serve some of the primary objectives of the draft framework, being to provide transparency of ATO interactions,” Abdalla said.
“This underscores the need to translate high-level concepts into actionable strategies that can be clearly communicated and understood by all stakeholders involved.”
More examples of guiding principles and an added privacy and data security section were mentioned for recommendations that the framework could also incorporate.
“As a tax education body and an advocate of a better tax system, The Tax Institute supports steps taken to improve outcomes for vulnerable taxpayers and to equip tax practitioners with the tools they need to identify and best support them,” Abdalla said.
“Feedback from members indicates that the draft Framework is useful in understanding the ATO’s intentions concerning vulnerable taxpayers. Further, establishing internal protocols and methods to measure success would increase public confidence in the ATO’s approach, provide greater transparency, and encourage collaboration between vulnerable taxpayers, practitioners, and the ATO.”
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