Supporting Bookkeeper Recognition

NZQBA’s Submission on Bookkeeper Recognition and Intermediary Reform

On 11 June 2026, NZQBA submitted a formal response to Inland Revenue’s consultation on proposed legislative changes for intermediaries.

The consultation explored how Bookkeepers, tax agents, payroll providers, digital service providers, and other intermediaries should be recognised and regulated in the future.

As the professional association representing Bookkeepers across New Zealand, NZQBA considered it important to contribute to the discussion and advocate for greater recognition of Bookkeepers and a framework that accurately reflects the role they play in supporting businesses and compliance outcomes.

Why NZQBA made a submission

Bookkeepers play a vital role in New Zealand’s business community.

Every day, Bookkeepers help business owners maintain accurate records, meet their GST and payroll obligations, implement and manage accounting systems, and stay on top of their financial responsibilities. For many small businesses, their Bookkeeper is the person they interact with most frequently when it comes to financial administration and compliance.

Despite this, the current intermediary framework has not always reflected the reality of modern bookkeeping practice.

NZQBA believes the profession deserves appropriate recognition within legislation and regulatory frameworks, while also supporting standards that promote professionalism, accountability, and public confidence.

What did NZQBA support?

Our submission strongly supported the creation of a dedicated Bookkeepers category within the legislation.

We believe Bookkeepers perform a distinct role within New Zealand’s compliance ecosystem and should be recognised accordingly. While Bookkeepers often work alongside accountants, tax agents, payroll specialists, and software providers, our role is different. Bookkeepers are typically responsible for the day-to-day financial administration and compliance activities that help businesses remain organised, compliant, and informed throughout the year.

We also supported the development of a clear definition of what a Bookkeeper is. If a new category is introduced, it is important that there is clarity around who belongs within that category and how Bookkeepers are distinguished from other intermediary groups.

Replacing the 10-Client Rule

One of the most significant proposals related to the current requirement for Registered Bookkeepers to have at least 10 clients.

NZQBA strongly supported replacing this requirement.

The bookkeeping profession has evolved significantly over recent years. Many highly capable Bookkeepers operate specialist, part-time, contractor, or embedded finance support businesses. Some may work with only one or two organisations while providing substantial bookkeeping and compliance support.

In our view, professionalism should be measured by competency, ethics, accountability, and ongoing professional development – not simply by the number of clients a person serves.

Supporting Professional Standards

NZQBA also supported appropriate and proportionate regulation of the bookkeeping profession.

As Bookkeepers take on increasing responsibility for supporting businesses with compliance obligations, payroll administration, and digital reporting, it is reasonable that professional standards continue to evolve alongside the profession.

Our submission supported replacing the 10-client rule with membership of an approved professional body as a more meaningful indicator of professionalism and accountability.

We believe any future framework should promote:

• Competency and ongoing education
• Ethical standards
• Accountability
• Public confidence
• Accessible pathways for practitioners throughout New Zealand

At the same time, any changes must remain practical and achievable for sole practitioners, contractors, and smaller bookkeeping businesses.

Recognising the diversity of the profession

A key theme throughout our submission was that there is no single bookkeeping business model.

Bookkeepers operate in a variety of ways. Some run large bookkeeping practices, some work as sole practitioners, some provide embedded finance support, and others combine bookkeeping with payroll, tax agency, or advisory services.

Any future framework needs to recognise this diversity and avoid creating unnecessary barriers or complexity.

Why this matters

While the consultation period has now closed, the decisions that follow could have a lasting impact on Bookkeeper recognition and how the profession is recognised within New Zealand’s tax and compliance framework.

The proposals discussed during the consultation included the creation of a dedicated Bookkeepers category, changes to eligibility requirements, and the introduction of stronger professional standards.

NZQBA believes these discussions represent an important step forward for the profession and will continue to engage with Inland Revenue as the process progresses.

Thank You

This submission was strengthened by feedback from members, industry discussions, and the practical experiences of Bookkeepers working with businesses throughout New Zealand.

We are particularly grateful to Emma Diver from Balanced Books NZ and Angela Fisher from ClockworX, whose insights and expertise helped strengthen the final submission.