While many aspects remain the unchanged such as the frequency of reporting and Payment Times Small Business Definition - the Amendment Act introduces several important changes, including:

1. Updated Reporting Eligibility: Large businesses with annual consolidated revenue of $100M or more must now determine their reporting requirement using Australian Accounting Standards, rather than tax income.
2. Default to Consolidated Reporting: Businesses will now have the default requirement to report at a consolidated level instead of the previous entity-by-entity approach, which is aimed to streamline reporting processes for complex organisations. Separately, to cater for controlled entities with distinct governance structures, an option to report separately via application of nominee entities is available.
3. Subsidiary Reporting Update: All entities within the consolidated group are now required to include their data in reporting, with some exceptions. The previous $10M threshold for subsidiaries has been removed.
4. Adjusted Reporting Metrics: Companies are now required to report on additional metrics, including the average, median, 85th, and 95th percentiles of payment times to small businesses. These new metrics are complemented by a consolidation of the existing payment times value and volume percentage bands, along with a reduction in the overall number of reportable fields. This shift enhances transparency, demands greater precision in reporting practices, and streamlines the reporting process.
5. New Payment Dataset: Entities are required to create a Trade Credit Payment (TCP) and Small Business Trade Credit Payment (SBTCP) complete payment datasets for documentation and reporting.
6. Enhanced Accountability Measures:

• Deterrent: The Regulator now holds the authority to identify and publicly highlight on Payment Times Reporting Register, the slowest 20% of payment reporters based on the 95th percentile of payment times within a given division of the ANZSIC (Amendment Act, Section 22E). Slow payers are defined as those that fall within the slowest 20% of the 95th percentile either by industry or overall among large Australian businesses for two consecutive reporting periods. These businesses could be compelled to disclose their status as slow payers on their websites, financial statements, and other public-facing documents, such as ESG reporting, which could impact their reputation.
• Incentive: Conversely, entities identified as the fastest small business payers will be recognised and included in a public register, showcasing their commitment to timely payment practices. Fastest payers are those with payment times that are less than 20 days of the 95th percentile for 2 consecutive reporting periods. This recognition can enhance their brand reputation and attract more business partnerships.

Key guidance on reporting data and calculation logic is provided in the latest Payment Times Reporting: Exposure Draft Guidance released by the Regulator on 28 October. Reporting entities will need to consider whether additional data extraction and classification will be required to comply with the requirements.

1. Production of Complete Payments Dataset: Entities may be required to provide complete payments dataset used for reporting if requested by the Regulator. This enables the Regulator with more granular oversight if and when required.
   • Trade Credit Payments Dataset (TCP Dataset): This dataset must include all payments made under trade credit arrangements and requires careful classification to avoid misleading reports. The following key columns should be included:
     • Payer Name (Text): The name of the entity making the payment.
     • Payer ABN (or ACN, ARBN) (Text, 11 characters): The Australian Business Number (ABN), Australian Company Number (ACN), or Australian Registered Body Number (ARBN) of the payer.
     • Payee Name (Text): The name of the entity receiving the payment.
     • Payee ABN (Text, 11 characters): The Australian Business Number (ABN) of the payee.
     • Payment Date (Date): The date on which the payment was made.
     • Payment Amount (Numeric): The total amount paid (including GST).
     • Credit Card Payment (Y/N): Indicates whether the payment was made via credit card.
     • eInvoice Enabled Payment (Y/N): Indicates if the payment was made using an electronic invoicing system.
     • Partial Payment (Y/N): Indicates if the payment made was a partial payment.
     • Invoice Date (Date): The date the invoice was issued.
     • Invoice Receipt Date (if known) (Date, optional): The date the invoice was received by the payer (if applicable).
     • Payment Terms (calendar days) (Integer): The agreed payment terms in calendar days.
     • RCTI (Y/N): Indicates if a Recipient Created Tax Invoice (RCTI) was issued.
     • Small Business Payee (Y/N): Indicates if the payee qualifies as a small business according to the Small Business Identification Tool.
     • Payment Time (calendar days) (Integer): The number of days taken to make the payment from the invoice date or receipt date.
   • Small Business Trade Credit Payments Dataset (SBTCP Dataset): This dataset must include payments made to small businesses. The columns for this dataset will mirror those of the TCP Dataset.
2. Adjusted Reporting Metrics: Companies are now required to report on additional metrics. These new metrics are complemented by a consolidation of the existing payment times value and volume percentage bands, along with a reduction in the overall number of reportable fields. This shift enhances transparency, demands greater precision in reporting practices, and streamlines the reporting process.
   • Percentage of Invoices Paid Within Specified Days: Report the percentage of invoices paid within 0-30 days, 31-60 days, and over 60 days.
   • Mean Payment Time: Calculated as the average payment times on the SBTCP dataset.
   • Median Payment Time: The middle value of payment times when arranged in order.
   • 85th Percentile: The payment time below which 85% of the payments fall.
   • 95th Percentile: This will be used to identify the slowest and fastest payment practices, with businesses in the lowest 20% needing to disclose their status as slow payers publicly.
   • Invoices paid within terms: The percentage of invoices paid on or before the agreed payment term as a percentage of the total number of payments.
   • Percentage of Peppol-enabled Small Business Procurement: proportion of small business payments (volume) that used Peppol-enabled systems.
   • Additional updates to reportable metrics and dimensions include:
     • Comparison of Receivable Terms to Payment Terms: Faster, Slower or Same
     • Small Business Procurement Calculation: The proportion by volume of trade credit payments made to small businesses.
     • Legal or Voluntary Obligations Disclosure Requirements (Y/N): Businesses must now incorporate disclosures related to legislative requirements, both legal and voluntary, such as SOPA, ensuring compliance with reporting standards. Commentary is required to support a “yes” response.
     • Excluded payments include additional guidance such as intragroup and payees without an ABN where reasonable.