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Compliance Crunch: Navigating Payment Times Reporting Enforcement

Is Your Business Compliant?

The Payment Times Reporting Regulator (Regulator) has ramped up its compliance program on businesses that should have reported under the Payment Times Reporting Scheme but are yet to do so. Businesses may be required to submit a payment report if in the last 3 years the $100m threshold has been reached.

The Payment Times Reporting Scheme (PTRS or Scheme) came into effect in 2021. The Scheme aims to promote transparency and fair payment practices, help small businesses make informed decisions about who they do business with, and improve cash flow for small enterprises by encouraging prompt payments.

It requires large businesses that meets the $100m threshold to publicly disclose, twice a year on how quickly they pay small business invoices. Disclosures are submitted by the Regulator’s portal and made publicly available via the Payment Times Reporting Register.

The Regulator actively monitors and enforces non-compliance through a number of different forums such as official warning letters, compliance audits and civil penalties of up to 60 penalty units for individuals and 300 units for incorporated entities per day of non-compliance. The value of one penalty unit as of July 1, 2023, is $313 per penalty unit per day, meaning the fines for non-compliance could be significant.

The first step is to assess the requirements to report under the Scheme against the criteria outlined. If the criteria to report has been met any time since January 2021, then payment times reports are required to be prepared and submitted for all historic periods since becoming eligible.

See worked example below of reporting periods that would repeat each 12months.

The Regulator has been notifying businesses of their potential requirement to report under the Scheme via email communication. In most cases, the notification is asking the business to assess whether it is eligible to report and provide the Regulator with the outcome within a certain period of time. 

In these cases, accurately determining if the business is required to report, and from when, is an important first step. If, following that assessment, the result is that a payment report is required to be submitted, then the details of the reporting guidance need to be understood and actioned to produce and submit the required report.  

Each reporting entity must report over 60 data points with respect to their payment practices to small business suppliers including information about the entity, payment terms, aggregated payment time metrics as well as other qualitative details. 

What is the reporting format?
The reports must be submitted in the CSV reporting templates and in prescriptive formats as defined by the Regulator.

What fields are reported?

  • Primarily a collection of calculated metrics on paid invoices into ageing buckets based on the number of days taken to pay the invoices (within 20 days, 21-30 days, 31-60 days, 61-90 days, and more than 120 days) both by volume and value and; calculating the total percentage of spend to small business suppliers. 
  • Additional qualitative payment practice information is required to provide transparency on how the reporting entity may engage with a small business, standard payment terms, details of payment processes and details of responsible governing body.

PTRS is complex, demands rigorous accuracy and deep trust in your data and reportable metrics. Common reporting challenges that are faced by reporting entitles are as follows:

  1. Data extraction and completeness  
  2. Correct application of the legislation to the data
  3. Data cleaning, structuring and validating to ensure data quality
  4. Submission approval and governance
  5. Providing transparency and comfort to reported metrics
  6. Process repeatability

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