Join us for one of two practical sessions exploring the new requirements, where issues can arise, and how to respond.

Session details

Session 1 | Universities & higher education providers

15 September | 12.30pm–1.30pm

A dedicated session for universities, focusing on the practical considerations and challenges relevant to the sector.

Please feel free to forward this invitation to your payroll team and other colleagues involved in superannuation and payroll compliance.

Session 2 | General session

29 September | 12.30pm–1.30pm

A broader session for employers across all industries, covering the practical implications of Payday Super and what organisations should now be considering.

What we’ll cover

• What Payday Super means in practice.
• Where things can go wrong.
• What to do when issues arise.
• How SW can support review and remediation.
• How technology can help, including SW’s Superannuation Reviewer solution.

Your presenters

Paul Hum

Director | Tax

SW

Will present the session, drawing on 15 years’ experience in payroll and employment tax, including complex payroll issues and remediation programs.

Stephen O’Flynn

Director | Tax

SW

Brings more than 25 years’ tax experience, including advising organisations across the higher education sector, and will facilitate the discussion.

The post Navigating the new requirements for Payday Super appeared first on SW Accountants & Advisors.

These updates provide further clarity on the 2026–27 Federal Budget reforms, outlining how key measures will operate in practice, as set out in the Government’s tax reform implementation announcement and legislated through the Treasury Laws Amendment (Tax Reform No. 1) Bill 2026. The Bill and explanatory memorandum can be found here.

The latest announcements do not change the core direction of the Budget as highlighted in our FedBud 26 overview and FedBud 2026 follow-up webinar series. However, they begin to address key concerns raised during consultation, particularly in relation to targeted concessions and the treatment of testamentary trusts and capital gains tax (CGT) settings.

Key updates

Expanded access to CGT concessions

• The turnover threshold for the small business 50% active asset CGT concession is proposed to increase from $2m to $10m.
• This is expected to extend eligibility to around 98% of Australian businesses.

New support for startups and innovation

• A proposed Innovative Business CGT Concession introduces a 50% discount for early-stage investors, founders, and employee share scheme participants.
• Consultation is ongoing on how this concession will operate in practice.

Removed the power of the Minister to determine other assets that would retain the 50% CGT discount

• The types of assets that are able to access the 50% CGT discount are now locked in and can not be expanded by the Minister.

Introduction of a 30% minimum tax on discretionary trusts

• From 1 July 2028, a minimum 30% tax is proposed to apply to discretionary trust income.
• This represents a fundamental change to traditional income distribution strategies and is designed to limit income splitting.

Removing the ability for superfunds to use limited recourse borrowing

• In another blow to investors, self-managed super funds (SMSFs) will no longer be able to utilise limited recourse borrowing arrangements to acquire property.
• There are transitional arrangements that allow existing limited recourse borrowing arrangements to continue.

Removing the exemption for salary packaged work related items

• From 1 July 2027, eligible work-related items such as iPads, mobile phones, laptops, protective clothing, and tools of trade will not longer be exempt from fringe benefits tax (FBT) if salary packaged.

Testamentary trusts

• As part of the reform package, the Government confirmed in the media release that income from testamentary trusts will be exempt from the proposed 30% minimum tax, including discretionary testamentary trusts.

However, the supporting consultation materials indicate that this exemption will be subject to conditions and further clarification, as such it will be important to review the legislative detail and guidance before these measures take effect.

For a more detailed breakdown, see our alert on Proposed testamentary trust rules: Understanding the 30% minimum tax exemption.

What this means for clients

These reforms will impact businesses, investors, and families differently depending on their structure:

• Small business owners will benefit from broader CGT concessions and improved cash flow planning opportunities, particularly where business sale or succession is being considered.
• Startups and founders may gain access to new investment incentives, supporting capital raising and growth.
• Trust vehicles in family groups and private business owners will be subject to higher tax from 2028.
• Estate planning strategies will become more complex, with testamentary trusts remaining attractive but subject to new conditions and integrity measures.

Importantly, while most small businesses will continue to access CGT relief, those operating through discretionary trusts will need to reassess whether their current structures remain fit for purpose.

The impact

Overall, the reforms aim to strike a balance between supporting investment and reducing tax barriers for business, while strengthening integrity around trust taxation.

The shift toward a minimum tax regime represents a move away from flexible income splitting and toward more consistent tax outcomes across different structures. For many clients, this will mean:

• reviewing ownership and operating structures before 2028
• reconsidering succession and estate planning arrangements
• identifying opportunities to restructure, particularly during any available transitional relief period
• modelling future tax positions under the new rules.

How SW can help

SW can support you in navigating these reforms with confidence. Our team can:

• assess the impact of proposed changes on your current structure
• review your tax, succession, and estate planning strategies
• identify restructuring opportunities ahead of the 2028 commencement
• provide practical guidance as further legislation and ATO guidance is released.

If you would like to understand what these changes mean for you or your clients, please reach out to your SW advisor.

Contributors

Julia Lee | Business Development & Marketing Executive

The post Discretion advised on the 30% trust tax, $10m CGT lifeline & startup sweeteners appeared first on SW Accountants & Advisors.

Horizon Europe works on a 7-year cycle. Framework Program 9 (FP9) is the current version, running from 2021-2027. As institutions either conclude FP9 or look to begin participating in Horizon Europe projects, many will encounter European Commission financial reporting and audit requirements that differ from the Australian grant compliance frameworks they are familiar with.

Independent audits can play an important role in demonstrating that project expenditure has been properly managed, appropriately documented, and claimed in accordance with grant requirements. Early preparation can help universities reduce compliance risk, avoid financial corrections, strengthen governance, and approach project reporting with confidence.

Horizon Europe audit quick facts

Will my university need a Horizon Europe audit?

For some Horizon Europe projects, beneficiaries are required to obtain a Certificate on the Financial Statements (CFS).

Under the general Horizon Europe requirements, a CFS is required where the total European Union contribution claimed by an individual beneficiary or affiliated entity reaches or exceeds €430,000 over the life of the project. The threshold is assessed separately for each beneficiary or affiliated entity and not at the overall consortium level. A mandatory CFS is generally submitted once at the end of the project as part of the final reporting process. The cost of a mandatory CFS is generally eligible for reimbursement under the grant, subject to the applicable grant requirements.

As university participation in Horizon Europe grows, particularly following Australia’s association arrangements, many universities may find themselves exceeding this threshold for the first time.

What does a Horizon Europe audit involve?

A Horizon Europe audit examines the financial information submitted by a beneficiary in support of grant claims.

Depending on the nature of the project, the auditor may review:

The audit focuses on whether costs have been correctly calculated, recorded in the beneficiary’s accounting records, and supported by appropriate evidence. The auditor reports their findings through the prescribed European Commission framework, while the European Commission ultimately determines cost eligibility and any financial corrections.

Why audit readiness matters

While a mandatory CFS is generally only required at the end of a project, the supporting evidence required for the audit must be generated and retained throughout the project lifecycle.

Universities that wait until final reporting often discover gaps in documentation that can be difficult, costly, or impossible to rectify years after expenditure has been incurred.

Early preparation helps institutions:

• protect valuable research funding
• identify potentially ineligible costs before submission
• strengthen time-recording and personnel cost documentation
• reduce the risk of funding clawbacks or financial corrections
• demonstrate sound governance and financial oversight
• establish repeatable processes for future Horizon Europe projects.

Audit readiness should therefore commence at project establishment rather than when a project approaches completion.

Preparing for a new compliance environment

Horizon Europe compliance is rarely the responsibility of one team. Research Offices, Finance teams, Procurement personnel, Payroll teams, Principal Investigators, and Project Managers may all contribute information that supports project expenditure claims.

Institutions should consider:

• reviewing the financial requirements contained in each grant agreement
• determining early whether a CFS is likely to be required
• assigning clear ownership for compliance activities
• mapping Horizon Europe cost categories to internal finance systems
• documenting personnel cost and time-recording methodologies
• implementing appropriate procurement and subcontracting controls
• maintaining a central repository of audit evidence
• performing periodic project reconciliations and internal compliance reviews
• budgeting for the cost and timing of independent audit requirements.

Universities that establish these disciplines from project commencement are generally better positioned to navigate both project reporting requirements and independent audit procedures.

Why this matters for universities

Many universities already manage complex assurance requirements associated with government research funding, international grants, and regulatory reporting obligations.

However, Horizon Europe introduces a distinct set of European financial compliance requirements that may be unfamiliar to research and finance teams.

As participation in Horizon Europe expands and funding levels increase, universities are likely to experience greater scrutiny over cost eligibility, documentation, personnel costs, and supporting evidence. Building capability now can help institutions scale their participation in future European research programs while protecting valuable funding outcomes.

How SW can help

SW supports universities, research institutions, and complex grant-funded organisations across Australia with assurance, compliance, and governance requirements.

Our support can include:

• audit readiness assessments for Horizon Europe
• compliance reviews and gap analyses
• review of financial systems, controls, and documentation
• guidance on eligible cost requirements
• review of personnel costs and time-recording arrangements
• procurement and subcontracting compliance reviews
• independent Horizon Europe audits and CFS engagements
• training for Research Office, Finance, and Project teams
• ongoing compliance and reporting support throughout the project lifecycle.

SW already supports universities, research institutions, and complex grant-funded organisations across Australia. Our practical experience, combined with a strong understanding of Australian and EU compliance frameworks, enables us to help you align your grant management practices with Horizon Europe requirements and ensure your projects are audit-ready from day one.

Contributors

Matthew Paull | Associate Director, Assurance and Advisory Services

The post Horizon Europe audits explained & what universities need to know appeared first on SW Accountants & Advisors.

That combination of large funding at stake, personal VC certification, and specifications that change every year is exactly why HERDC deserves the same governance and control discipline as any other significant regulatory submission. And as research funding increasingly flows across borders, from Europe and the United States as well as Canberra, universities now face not one assurance obligation, but three.

Why the risk is rising

HERDC data is pulled together from Research Offices, Finance, Faculties, and Shared Services, drawing on multiple systems and interpretations of what counts as eligible R&D income. The specifications are updated annually, usually released in draft each December and confirmed the following February, so last year’s approach is rarely a safe guide to this year’s return.

The risks we see most often are:

• misclassification of income across the four HERDC categories
• inconsistent interpretation of eligibility, particularly around shared income, affiliates, and subsidiaries, an area the specifications have repeatedly clarified
• thin supporting evidence for income included in the return, reinforcing the principle that the contract is king, if it does not read as research, it is not
• manual, key-person dependent extraction and reconciliation processes
• limited executive visibility of where the real reporting risks sit.

Left unchecked, these translate directly into funding adjustments, audit findings, regulator challenges, and reputational exposure.

Our view

Leading universities now treat HERDC as a high-risk external reporting process, not simply a funding exercise. Management should be able to demonstrate clear accountability for HERDC decisions, consistent application of the specifications, effective controls over data integrity, robust audit trails behind eligibility calls, and genuine independent challenge before the Vice-Chancellor signs.

Independent assurance is what allows executive teams and Boards to say, with evidence, that reported research income is accurate, compliant, and defensible.

Three funding streams, three different assurance obligations

This is where universities often need help separating the mandatory audit from the broader assurance they may want, and where SW can support the full research funding picture. As research partnerships globalise, more institutions now carry all three of the obligations below at once.

HERDC audit — the mandatory compliance audit (Australian funding)

Every provider must obtain a Special Purpose Audit Report under ASA 800 certifying that Category 1–4 R&D income in the return is correct, attributed to genuine R&D and to the right category, and identified by transparent transactions. The report is due to the department by 30 June each year. SW audits HERDC for clients including Deakin University, La Trobe University, Swinburne University, and Victoria University, and also runs pre-submission preparation and staff training workshops to lift return quality before the audit even starts.

Horizon audits — certifying EU-funded research spend (European funding)

Where a university draws funding from the EU’s Horizon Europe (or legacy Horizon 2020) programme, a Certificate on the Financial Statements (CFS) becomes mandatory once the EU contribution to a single beneficiary reaches €430,000.

This is a different animal to HERDC as it certifies that declared costs are real, eligible, and properly supported, delivered as an agreed-upon-procedures engagement (ISRS 4400) rather than an ASA 800 income audit, and without it, the European Commission can withhold the final payment. With Australia’s association to Horizon Europe concluded in 2026 and direct Pillar II funding flowing from January 2027, far more Australian universities will soon cross the CFS threshold.

Uniform Guidance audits — acquitting US federal research dollars (United States funding)

Australian universities are significant recipients of US Government research funding, grants from agencies such as the NIH, the Department of Defense and the National Science Foundation, received directly or as pass-through funding.

Any institution that expends US$1m or more of these federal awards in a year must obtain a Single Audit under the US Office of Management and Budget’s Uniform Guidance (2 CFR Part 200, Subpart F) a threshold recently lifted from US$750,000. Unlike HERDC, this applies an unfamiliar US framework — US GAAP reporting, cost-eligibility, and internal-control testing under US auditing standards — to funds administered a long way from Washington.

SW is the Uniform Guidance auditor for leading universities across Australia and New Zealand, delivering each engagement locally, while leveraging the extensive expertise, methodologies, and practice aids of our US partner firm, which conducts more than 100 Uniform Guidance audits internationally each year.

In short, HERDC assures research income for Australian block-grant funding. A Horizon CFS assures research expenditure for EU grant funding, and a Uniform Guidance Single Audit assures research expenditure for US federal funding. Universities with strong international research partnerships increasingly need all three.

The Horizon market is about to open & universities will need help

Until now, Horizon audits have been a niche requirement for the handful of Australian universities drawing EU research funding under third-country rules, where entities typically had to self-fund their participation. That’s changing fast, and it changes the size of the opportunity.

In June 2026, the EU and Australia concluded negotiations on Australia’s association to Horizon Europe — the EU’s €93.5bn (≈A$155bn) research and innovation programme. Australia will associate to Pillar II, worth more than €53.5bn, covering digital and industry, space, climate and energy, health, food, and the bioeconomy, priorities that map directly onto Australia’s own National Science and Research Priorities. From January 2027, under a transitional arrangement, Australian universities move from third-country status to being treated as eligible entities from an associated country, meaning direct, routine EU funding on the same terms as EU member states, including the ability to lead consortia.

The signal is already there. Australian organisations have taken part in 239 Horizon Europe projects to date, with a 24.39% application success rate, close to one in four. The Group of Eight has stepped in to fund the association fee, and universities from Sydney to Melbourne have publicly welcomed the move. As direct funding flows from 2027, the number of Australian institutions crossing the €430,000 CFS threshold, the point at which an independent Certificate on the Financial Statements becomes mandatory before the EU releases final payment will grow materially.

What this means for universities

More EU funding is unambiguously good news, but it brings an assurance obligation many Australian research offices have not had to manage at scale before. A CFS is not a HERDC audit and not a standard financial statement opinion, it’s an agreed-upon-procedures engagement against the European Commission’s prescribed template, certifying that declared costs are actually incurred, properly recorded, and eligible under the grant agreement. Get the documentation wrong and final payment can be withheld or clawed back.

How SW can help with the Horizon opportunity

SW can help universities:

• get ahead of the threshold — flag likely CFS obligations early in a project’s life and budget for them (the audit cost is itself an eligible, reimbursable project cost), so certification isn’t a scramble at final reporting
• build cost-eligibility discipline up front — align time recording, cost allocation, and documentation to EU grant agreement rules from day one, rather than reconstructing evidence years later
• deliver the CFS itself — independent, APES 110–compliant certification against the Commission’s template, drawing on our existing Horizon and Uniform Guidance experience
• join the dots across research funding — few advisors can sit across HERDC, US Uniform Guidance, and EU Horizon assurance under one roof. We already do, which lets research-finance teams consolidate their external assurance with a single sector specialist.

The universities that plan for this now, ahead of the 2027 funding switch, will avoid the late-stage documentation problems that catch first-time EU grant recipients. That’s the conversation we should be starting with our Research Office and Research Finance contacts today, on the back of the HERDC relationships we already hold.

How we help with HERDC assurance

Our independent HERDC assurance review sits alongside, not instead of, the mandatory audit, and covers:

• governance and oversight — accountability, executive and committee oversight, certification process, and escalation
• compliance — alignment to current specifications, eligibility methodology, consistent categorisation, and supporting documentation
• controls and process — end-to-end reporting, review and approval, reconciliations, and audit readiness
• data integrity — source-to-submission traceability, data quality, manual adjustments, and the reliability of management reporting.

Why SW

We know research funding assurance because we live in this sector. Our dedicated Education Industry Group has more than 50 years’ experience and has worked with 35 of Australia’s major universities.

• Laura Toscano, Director — 17 years in internal audit, risk, and compliance, leading HERDC audits across Deakin University, Swinburne University, La Trobe University, and Victoria University. Laura is a 2026 finalist in the Women in Banking & Finance awards for Risk, Regulation & Compliance and is an APRA-approved independent expert on governance and risk remediation, the exact skill set HERDC governance assurance calls for.
• Matt Paull, Associate Director — 15 years specialising in education audit, with HERDC audits for Deakin University, La Trobe University, Victoria University, and Swinburne University, as well as HERDC preparation support and staff training workshops. Matthew also manages Uniform Guidance audits across Australia and New Zealand.
• Brent Sheers, Partner — Assurance & Advisory — 12+ years delivering external audit, assurance, and financial due diligence across the listed, education, and not-for-profit sectors, and the SW Engagement Partner on our Uniform Guidance and European Horizon audits for universities. A Registered Company Auditor with both ASIC and Fairwork, Brent also sits on the Board and Finance & Audit Committee as an independent director of both a Melbourne based disability services organisation and independent girl’s school, giving him a first-hand read on exactly what Boards and audit committees expect from their auditor.
• Steve Allan, Partner — 30 years advising the sector and National Chair of our Education Focus Group, providing commercial, tax, and structuring advice to more than 30 Australian universities. Steve’s deep relationships across research and finance leadership open the door for the assurance conversation.

We also stay close to the sector’s own forums, presenting HERDC and technical updates through ARMS, AUSFOG, and university CFO and tax manager networks, so our advice reflects where the specifications and the sector are actually heading, not just where they’ve been.

Contributors

Matthew Paull | Associate Director, Assurance and Advisory Services

The post Research income & research funding assurance appeared first on SW Accountants & Advisors.

When the case reached the Western Australian District Court in Mobius Group v Inoteq, the paying company was ordered to pay the legitimate invoice all over again because it hadn’t done enough to verify the change. It effectively paid twice for the same work, losing close to $200,000.

No firewall failed, it was just a convincing email and a verification process that stopped one step short.

Why this belongs on the Board agenda

Business Email Compromise (BEC), also called payment redirection or ‘CEO fraud’, occurs when a fraudster impersonates someone trusted to trick an employee into transferring funds or changing payment details. It looks legitimate, so it slips past controls that were never designed to catch a human being deceived.

In Australia, it’s getting worse. The ACCC’s National Anti-Scam Centre reported that payment redirection scams surged by 66.6% in 2024, with business losses exceeding $30m, and that’s only what’s reported.

It’s hitting the sectors our clients operate in

The Mobius v Inoteq case is a construction and infrastructure story, precisely the environment where large contractor payments change hands constantly, and where a single altered invoice can cost hundreds of thousands.

It’s not confined to the private sector, either. In July 2025, the AFP charged a Sydney man over $3.5m fraudulently obtained from the Northern Territory Government, after the agency received an email, appearing to be from a construction company contractor, with a completed vendor form and updated bank details. The agency paid more than $3.58m to the fraudulent account before the scam was uncovered.

And the sums can be devastating for smaller organisations. A flood-damaged Victorian bowls club lost $120,000 after hackers monitored its emails, deleted a genuine builder’s invoice and replaced it with a near-identical one, changing only the BSB and account number.

The five scenarios we see most often

1. Supplier payment diversion

A supplier’s email is compromised and ‘updated’ bank details are sent through, referencing a genuine project and real invoice, exactly what happened in Mobius v Inoteq.

2. CEO (or ‘fake president’) fraud

An urgent, confidential request appears to come from a senior executive, using urgency and secrecy to discourage verification.

3. Conversation hijacking

Fraudsters monitor a genuine email thread, then insert amended payment instructions at the critical moment, common in property and construction transactions.

4. Payroll redirection

Payroll receives a legitimate-looking request to change an employee’s bank details, sending salary to a criminal account.

5. Adviser impersonation

Lawyers, consultants, or project managers are impersonated to lend credibility to a fraudulent request.

The warning signs your people can’t afford to miss

• Urgent payment requests that bypass normal processes.
• Requests for secrecy or confidentiality.
• Changes to bank account details.
• Unusual instructions ‘from’ senior executives.
• Requests made outside business hours.
• Slight variations in email domains.
• Reluctance to take part in independent verification.
• Inconsistencies between invoices, contracts, and payment details.
• Pressure to override approvals.

The lesson from the courts: Verification is now a legal duty

The most confronting takeaway from Mobius v Inoteq is that a phone call attempt wasn’t enough, the court expected the payer to actually complete independent verification before releasing funds.

As legal commentators noted, the decision means Australian businesses now carry a real duty of care to take reasonable steps against fraud, on both sides of a transaction. A follow-up ‘confirmation’ by email, to the very account that’s been compromised, offers no protection at all.

Seven questions every Board and executive team should ask

• When did we last assess fraud risk across our payment processes?
• Do we independently verify every supplier banking change — by phone, to a known number?
• Can a single person both initiate and approve a payment?
• Have we tested our controls against a realistic BEC scenario?
• Are suppliers and contractors held to the same controls as employees?
• How quickly could we actually detect and respond to a fraudulent payment?
• Do our people know how to escalate a suspected attempt?

If you suspect an incident, you should move fast

The first few hours are critical. Immediately contact your financial institution, report to Scamwatch and ReportCyber, secure affected accounts, preserve evidence, launch a forensic investigation, assess whether other payments are at risk, and fix the control failures. In the Mobius matter, only around $43,000 of the stolen funds was ever recovered.

The bottom line

Business Email Compromise extends beyond an IT problem, creating governance, fraud, and operational risks that now carry legal consequences for the party that pays. The organisations that stay ahead of it combine strong payment controls, staff awareness, rigorous supplier verification, and a tested incident response plan.

How SW can help

SW’s Fraud & Forensics team helps organisations prevent, detect, and respond to BEC and payment fraud through fraud risk assessments, payment process and control reviews, fraud control framework assessments, cyber and digital forensic investigations, incident response support, data analytics and transaction reviews, governance and control reviews, fraud awareness training, and supplier and third-party risk reviews.

For more information, you can also contact Anthony Hodgkinson directly. Anthony Hodgkinson has more than 30 years’ experience in fraud and corruption risk management, forensic investigations, financial crime, cyber and digital forensics, governance reviews, and fraud control frameworks.

The post The scam that made an Australian company pay twice appeared first on SW Accountants & Advisors.

The lesson was made plain in Victoria’s own backyard between 2013 and 2015, when a Warrnambool training company invoiced South West TAFE more than $1.8m for engineering training that was never delivered, with a parallel scheme netting a further $221,000 from Bendigo’s Kangan Institute. As government funding revenue fell from 55% in 2022 to 45.6% in 2024, dependence on fee and third‑party revenue has surged, concentrating both financial and integrity risk. For Boards and executives, fraud has moved beyond a peripheral concern to become a governance issue spanning admissions, research, payments, and payroll.

Why this requires robust oversight

Fraud in higher education rarely looks like a single large theft. It typically begins with a small control weakness nobody noticed, a provider who was never checked, a document that wasn’t verified, and an enrolment that was never real.

South West TAFE paid $1.8m for training that never happened because, as IBAC found, TAFE did not conduct any meaningful oversight of the training outsourced on its behalf, and an insider had recorded the unqualified provider as appropriately credentialled. Universities are complex, federated organisations where thousands of transactions, admissions, and grants flow through devolved faculties and third parties, each with their own processes. That complexity is precisely where fraudsters operate. The reputational damage and the misappropriation of public funds routinely exceed the immediate cash loss.

The fraud risks we see most in the sector

Admissions & qualification fraud

Just as South West TAFE never verified its provider’s credentials, universities face forged qualifications at the front door. In December 2025, authorities uncovered a nationwide fraudulent degree ring in India, seizing almost 100,000 fake degrees linked to 22 universities; Home Affairs subsequently raised four South Asian countries to Evidence Level 3, citing ‘emerging integrity issues.’ The University of Sydney detected more than 250 fraudulent applications in a single year up from just 15, many using fake diplomas and forged English language tests.

Third‑party delivery, ‘ghost colleges’ & visa‑fee rorting

The South West TAFE scam is an archetype, government money paid for training that was never confirmed to have taken place by using falsified enrolment forms and assessment workbooks the operators themselves called a ‘sausage factory.’ The same ‘pay‑without‑verify’ gap drove the VET FEE‑HELP disaster (an estimated $1.2bn in loans issued improperly across 2014–2015) and today’s ‘ghost colleges.’ As of late 2025, ASQA was handling 174 serious matters, 68% involving fraud including cash‑for‑qualifications schemes and fabricated assessments.

‘Ghost students’ & financial‑aid fraud

TayTell enrolled real people including already qualified Jetstar engineers without their knowledge to justify invoices. The modern equivalent fictitious or non‑attending identities created to extract funding is accelerating with online enrolment, with overseas regulators uncovering tens of millions in fraudulent aid and penalties running from $500,000 to over $10m per institution.

Research & grant fraud

In Australia’s first criminal convictions for academic fraud, University of Queensland researchers Bruce Murdoch and Caroline Barwood fabricated research that was never carried out, then used it as the basis for fraudulent grant applications; UQ was forced to return funds and retract publications. ‘Publish or perish’ pressure remains a key driver of data manipulation and fabrication.

Procurement fraud & conflicts of interest

The South West TAFE case turned on an insider who processed an unqualified provider through the system. Devolved purchasing and heavy consultant spending create fertile ground; the ANU spent around $54m on consultants in 2023, with contracts later revealed to have gone to a firm run by a friend of the Chancellor. Victorian audits have separately identified supplier-related fraud, such as false invoices and altered bank details, as well as undeclared conflicts of interest, contributing to multi-million-dollar losses where data analytics was not used to detect red flags.

Payroll & insider fraud

Universities employ tens of thousands of staff, and payroll remains a classic area of exposure. Ghost employees, unauthorised bank-detail changes, fictitious overtime, and payroll redirection can all occur when insiders who understand the controls exploit gaps in the system.

Contract cheating & blackmail

In February 2026, TEQSA warned all providers of aggressive commercial cheating services now operating on campus, coercing students through blackmail and exposing them to identity theft, a fraud and welfare risk combined.

Warning signs boards and executives shouldn’t ignore

• Third‑party or subcontracted delivery paid without independent confirmation it occurred.
• Providers, trainers, or staff whose qualifications were never verified.
• Enrolments with no genuine student engagement or attendance.
• An insider processing approvals, records, or database entries without oversight.
• Pressure to secure agreements or hit targets in the wake of funding cuts.
• Supplier or staff bank‑account changes processed without independent verification.
• Anomalies surfaced by outside parties (students, suppliers) rather than internal controls.

Questions every university board and executive team should ask

• Do we independently verify that outsourced or subcontracted training actually took place before paying?
• How do we confirm the qualifications of providers, trainers, and staff, and who checks the checker?
• Can a single insider award, record, or approve without independent review?
• Are admissions, enrolments, and student identities genuinely validated?
• Do we use data analytics proactively to detect red flags before funds or contracts are committed?
• When did we last run a fraud risk assessment across admissions, third‑party delivery, research, procurement, and payroll?

How SW can help

SW’s forensic specialists provide independent, experienced, and objective investigations that stand up to scrutiny. We work collaboratively with People & Culture, in-house legal, and external advisors to deliver timely, robust, and fair outcomes, no matter how sensitive the matter. Our support includes:

• independent workplace investigations and serious employee misconduct reviews
• bullying, harassment, and discrimination investigations
• conflict of interest and nepotism reviews
• misuse of corporate IT systems and social media reviews
• whistleblower and protected disclosure investigations
• code of conduct and ethics breach reviews
• fraud risk assessments, control reviews, and investigation training for in-house teams.

Talk to us

Anthony Hodgkinson, Partner – Fraud & Forensics, has more than 30 years’ experience in fraud and corruption risk management and forensic investigations. To discuss how SW can support your team, reach out to your SW advisor or contact Anthony directly.

The post Fraud in higher education: Why Australia’s universities & higher education providers are a prime target appeared first on SW Accountants & Advisors.

Australia’s hotel and pub sector remains one of the most active parts of the real estate market. Capital continues to flow, portfolios are being reshaped, and operator appetite for well-located venues remains strong. But underneath the transaction activity, the risk profile of owning and operating hospitality real estate is changing quickly.

Tax, rising costs, gaming, workforce, governance, and financial crime settings are all shifting at once — and Victoria’s recent changes provide a useful lens on the direction the rest of the country is heading.

A tougher operating environment for venues

Wage growth, energy costs, food and beverage input costs, insurance premiums, and interest expense have all reset venue P&Ls over the last three years. Margin pressure means small issues in cost control, procurement, roster management, or supplier arrangements now translate into materially larger financial impacts than they did pre-2022.

For owners running multi-venue portfolios, this is amplifying the importance of:

• consistent operating models across sites
• clear procurement and supplier controls
• disciplined capex and refurbishment governance
• accurate performance reporting at venue level
• accurate data for lender, investor, and Board reporting.

The venues that can demonstrate operational discipline are the ones commanding stronger valuations and better funding terms.

Gaming — the fastest-moving risk area

Gaming remains one of the most complex and rapidly evolving parts of the sector.

Victoria has been at the forefront of change, with mandatory carded play, load-up limits, spin rate changes, closure periods, and enhanced pre-commitment settings progressively coming into effect, together with heightened expectations around responsible gambling, staff training and record-keeping.

Other states are watching closely. NSW has been progressing cashless gaming trials and reform discussions; QLD, WA, and SA are each managing their own settings around harm minimisation, advertising, and venue obligations. The direction of travel is consistent even if the pace differs.

For hotel and pub owners, this creates a set of practical questions:

• Are gaming compliance controls documented, tested, and evidenced?
• Can we demonstrate to the regulator how staff are trained and supervised?
• Are cash-handling, reconciliation, and reporting controls robust?
• Do we have visibility across venues, or does compliance rely on individual managers?

Regulators are increasingly focused on whether venues can prove that their policies are working effectively in practice, rather than simply having them in place.

Tax — a compounding cost, not just a compliance issue

Tax is now a strategic consideration for hospitality real estate, shaping decisions well beyond the preparation and lodgement of returns.

Key pressure points include:

• Land tax — Victoria’s expanded settings, including the COVID debt levy and absentee owner surcharges, have materially reshaped hold economics for many venues. NSW, QLD, and WA each have their own settings, with land tax now a genuine driver of portfolio decisions
• Payroll tax — cross-border operators are increasingly navigating grouping rules, contractor provisions, and thresholds that vary meaningfully by state
• Windfall Gains Tax (VIC) — impacting rezoning-led development and repositioning strategies
• Duty and foreign purchaser surcharges — relevant for offshore capital and joint venture structures
• GST margin scheme and going concern — regularly under scrutiny in venue transactions
• Division 7A, trust distribution and Section 100A issues — relevant for many privately owned venue groups.

For owners looking at acquisitions, disposals, refurbishment, or repositioning, tax is now embedded in the deal thesis rather than a post-completion consideration.

Capital gains tax & restructuring considerations

The Federal Government’s proposed changes to the taxation of superannuation balances above $3m, together with ongoing scrutiny of trust, succession, and asset-holding structures, are prompting many hospitality business owners to reconsider how hotel and pub assets are owned.

For a sector where venue wealth is often held through family groups, trusts, self-managed superannuation funds, and long-term investment structures, any future changes affecting capital growth, intergenerational transfers, or exit strategies have the potential to influence acquisition, disposal, and restructuring decisions.

As venue values continue to appreciate across many markets, owners are increasingly seeking advice on capital gains tax exposure, succession planning, asset protection, and the tax implications of transferring hospitality real estate between ownership structures. This is becoming less about tax compliance and more about preserving long-term enterprise value and maintaining flexibility for future transactions and capital events.

Governance expectations are rising

Boards, lenders, and investors are asking harder questions of hospitality operators, particularly as portfolios institutionalise and private capital moves into the sector.

Areas increasingly under the spotlight:

• Risk frameworks and Board reporting — venue-level operating risks are expected to roll up into a coherent enterprise view
• Internal audit and assurance — larger groups are being asked to demonstrate independent assurance over gaming, cash, payroll, procurement, and safety controls
• Whistleblower and speak-up programs — expected across groups of any material scale, not just listed entities
• Workplace conduct — wage compliance, workplace safety, and cultural risk are now board-level topics
• Cyber and payment fraud — venues are attractive targets given the volume of daily transactions and third-party payments.

For groups eyeing capital raises, refinancing, or IPO pathways, governance maturity has become an important valuation input alongside its role in meeting compliance obligations.

AML/CTF is arriving in the real estate sector — from multiple directions

From 1 July 2026, AML/CTF obligations extended to real estate businesses, including property developers and agents. For the hospitality industry, AML/CTF now touches the sector at three levels:

1. Gaming operations — long-standing AUSTRAC obligations for gaming venues, with continued regulatory focus on cash movement, and suspicious matter reporting.
2. Property transactions — new obligations for property developers and real estate agents involved in the sale, purchase, or transfer of real estate.
3. Funds management structures — where venues sit inside managed funds, trusts, or investor syndicates, the AML/CTF governance expectations of the fund may be monitored through to the underlying operating environment.

AUSTRAC’s 2026 money laundering update also highlights the growing use of AI-enabled identity fraud, fake documentation, and impersonation, which is increasing risks and testing the control environment.

The critical question is no longer, “Do we have a policy?” It is: “Can we demonstrate that our AML/CTF controls actually work in the venue, in the transaction, and across the ownership structure?”

Capital flows are still there — but the bar is higher

Domestic and offshore capital continues to target Australian hospitality real estate, attracted by long-dated income, freehold-going-concern structures, and the perceived durability of well-located venues.

However, the diligence bar has risen. Buyers are asking sharper questions on:

• gaming compliance and revenue sustainability
• workforce and wage compliance
• tax structuring and land tax exposure
• AML/CTF and cash controls
• capex requirements and asset condition
• governance and reporting maturity.

Sellers who can front-foot these questions — with clean data, defensible controls, and clear governance — are the ones transacting at strong pricing. Those who can’t are seeing longer processes, more conditions, and greater price adjustment.

The Victorian lens

Victoria has moved earlier and further on several of these fronts — gaming reform, land tax, windfall gains, planning, and workforce settings. Whether or not other states follow the same pace, the pattern is consistent: more disclosure, more assurance, and more scrutiny.

For operators and owners, the practical implication is that the operating and governance discipline being asked of Victorian venues today is a reasonable proxy for what will be asked nationally in the next 12–24 months.

That’s the conversation on the table at the Hospitality Real Estate Summit, and the one Tim and Matthew will unpack in their fireside chat on 9 September.

How SW can help

SW’s tourism, hospitality, and gaming (THG) practice works with hotel and pub owners, operators, developers, and investors across the country, supported by specialist capability in internal audit and risk advisory, AML/CTF independent reviews, fraud and financial crime, audit, tax structuring, transactions, and corporate advisory.

If you’re grappling with any of the issues above — from gaming compliance uplift, to pre-transaction due diligence, to AML/CTF assurance, to internal audit and governance maturity — we’d welcome a conversation before or after the summit.

The post Hotels under pressure: The issues shaping the sector ahead of the Hospitality Real Estate Summit appeared first on SW Accountants & Advisors.

The proposals are particularly relevant for entities preparing Tier 2 general purpose financial statements, including subsidiaries of Tier 1 groups. While the proposed mandatory effective date for the AASB 1060 amendments is still some time away, the changes may affect how Tier 2 entities present their primary financial statements and how they plan for transition.

Why this matters

AASB 18 introduces a more structured way of presenting financial statements for Tier 1 entities. The AASB is now proposing to update AASB 1060 so that Tier 2 entities follow similar classification and presentation principles, particularly in the primary financial statements.

This is a practical development for groups with both Tier 1 and Tier 2 reporters. It should help improve consistency across group reporting packs and financial statements, especially where a Tier 1 parent is preparing to apply AASB 18.

Timing and early adoption

The proposed effective date is the annual reporting periods beginning on or after 1 July 2030. For entities with a 30 June year end, this would generally mean the first affected annual financial statements would be for the year ending 30 June 2031. For entities with a 31 December year end, this would generally be the year ending 31 December 2031.

Early application is proposed to be permitted. This may be useful for Tier 2 subsidiaries that want to align their financial statement presentation with a Tier 1 parent applying AASB 18 earlier.

However, the amendments to AASB 1060 have not yet been finalised. This means Tier 2 entities cannot yet early adopt the proposed AASB 1060 changes. Groups considering early adoption should monitor the progress of the Exposure Draft and avoid assuming that Tier 2 subsidiaries can automatically follow the parent’s AASB 18 presentation before the amendments are issued.

What is proposed to change?

The main focus of the Exposure Draft is alignment of classification and presentation requirements. In plain terms, this means changes to how information is organised and presented in the primary financial statements, including the statement of profit or loss.

A key change is the proposed requirement to present income and expenses using defined categories — operating, investing, and financing. In simple terms, this is intended to make the statement of profit or loss easier to compare between entities by showing the results of day-to-day business activities separately from returns on investments and the cost of financing.

What should Tier 2 reporters do now?

Comments on the Exposure Draft are due to the AASB by 24 August 2026. Tier 2 entities that may be affected, particularly subsidiaries in Tier 1 groups, should consider whether they want to provide feedback or raise practical implementation concerns.

How SW can help

For some entities, implementation may simply involve remapping the chart of accounts and strengthening supporting documentation. For more complex entities, particularly those involved in investing or providing finance, implementation will require more careful analysis.

We can help Tier 1 and Tier 2 reporters prepare for AASB 18 and the proposed AASB 1060 amendments by providing practical support, including:

• assessing the potential impact of AASB 18 and the proposed AASB 1060 amendments on financial statements, reporting packs, and group reporting processes
• reviewing existing financial statement templates and identifying presentation changes that may be required
• mapping income and expense line items to the new operating, investing, and financing categories
• helping management identify available presentation choices and industry-specific considerations
• supporting Tier 1 groups to align reporting instructions and subsidiary reporting packs with AASB 18
• updating accounting policies, finance team guidance, and implementation plans so the transition is managed in a structured way.

If you would like to understand how the proposed changes may affect your organisation, please contact your SW advisor to discuss the practical implications and next steps.

Contributors

Jimmy Cao | Associate Director – IFRS Advisory, Assurance and Advisory Services

The post What Tier 2 reporters need to know about the AASB 1060 Exposure Draft appeared first on SW Accountants & Advisors.

A rising challenge for employers

Workplace misconduct matters are increasing in both volume and complexity, and the growing number of cases before the Fair Work Commission shows how much is at stake when an internal investigation is poorly run. Employers who fail to apply procedural fairness and natural justice, or appoint investigators without the right skills and experience, can face adverse findings, unfair dismissal claims, and reputational damage.

The matters most often landing on People & Culture’s desk include:

• bullying, harassment, and discrimination
• serious employee misconduct
• conflicts of interest and nepotism
• misuse of corporate IT systems and social media
• substance abuse in the workplace
• whistleblower and protected disclosure complaints.

Where fraud & human resources overlap

Fraud rarely starts with a large theft; it usually starts with a small control weakness nobody noticed. Some of the most common exposures sit within human resources and payroll, where insiders understand the controls and know where the gaps are. Some examples are:

• ghost employees and payroll manipulation
• unauthorised changes to employee bank account details
• fictitious overtime or allowances
• misuse of company funds and expense claims.

Payroll redirection is also a growing fraud tactic, where People & Culture or payroll receives a legitimate-looking request to change an employee’s bank details, sending salary to criminal-controlled accounts. Strong prevention starts with segregation of duties, regular payroll and employee audits, independent review of bank account changes, and a culture that encourages people to speak up.

The role of external auditors

External auditors are often the first to surface an anomaly or an unexpected variance, a control that isn’t operating as intended, or a transaction that doesn’t reconcile. However, a statutory audit is not designed to investigate fraud or misconduct, and an audit finding is only the starting point.

When something is flagged, People & Culture and management require specialist forensic support to determine what happened, preserve evidence properly, and respond in a way that stands up if the matter escalates. SW works alongside your external audit process, picking up where the audit ends to test the underlying issue, quantify any loss, and turn a red flag into a defensible outcome.

Working with risk, compliance & internal audit to strengthen controls

The most effective organisations focus less on catching fraud and more on eliminating the opportunities that allow it to occur. That means treating each incident as a chance to fix the underlying process, not just close a file.

SW works with risk, compliance, and internal audit teams to conduct fraud risk assessments, risk and control assessments, and fraud program and procedure audits, identifying where residual risk is high or emerging, and where controls need to be tightened. After an investigation, we prepare root cause analysis and recommend corrective measures, so the same weakness isn’t exploited again, and we can build periodic reviews into your internal audit program to keep controls working as intended over time.

Why independence matters

A common mistake an organisation makes when running their own investigations is failing to pay proper attention to procedural fairness. Internal teams are rarely set up to run these matters at arm’s length, and the stakes are too high to learn on the job.

There is real value in appointing someone who does this every day, a specialist who knows how to collect, preserve, interpret and present evidence, how to plan and conduct interviews, and how to keep a matter confidential and defensible from the first allegation. That experience protects both the employee and the employer, and while it may cost more initially, expert investigators have the potential to save employers money and stress in the longer term.

Working with general counsel

Sensitive matters almost always have a legal dimension, and the best outcomes come from investigators and lawyers working in step.

Anthony and the SW forensic team work collaboratively with in-house legal, general counsel, and external legal advisors aligning on scope, evidence integrity, and privilege from the outset, so findings are legally sound and ready to support any disciplinary, regulatory, or court processes.

Having worked as a trusted advisor on highly complex investigations across government, corporates, and the banking sector, Anthony understands how to structure an investigation, so it supports, rather than complicates, the legal position.

How SW can help

SW’s forensic specialists provide independent, experienced and objective workplace investigations that stand up to scrutiny. We work collaboratively with People & Culture, in-house legal, and external advisors to deliver timely, robust, and fair outcomes, no matter how sensitive the matter. Our support includes:

• independent workplace investigations and serious employee misconduct reviews
• bullying, harassment, and discrimination investigations
• conflict of interest and nepotism reviews
• misuse of corporate IT systems and social media reviews
• whistleblower and protected disclosure investigations
• code of conduct and ethics breach reviews
• fraud risk assessments, control reviews, and investigation training for in-house teams.

Talk to us

Anthony Hodgkinson, Partner – Fraud & Forensics, has more than 30 years’ experience in fraud and corruption risk management and forensic investigations. To discuss how SW can support your team, reach out to your SW advisor or contact Anthony directly.

The post Managing fraud & inappropriate workplace behaviour: What People & Culture teams need to get right appeared first on SW Accountants & Advisors.

For many domestic builders, the practical impact is the introduction of a new set of financial measures that must be monitored on an ongoing basis:

• Adjusted Net Tangible Assets (ANTA)
• Maximum Construction Capacity (MCC)
• ANTA Threshold
• Total Value of Domestic Building Work (TVDW)

Key requirements

The Minimum Financial Requirements (MFRs) introduced by the Building and Plumbing Commission are centred around two core concepts: Maximum Construction Capacity (MCC) and Adjusted Net Tangible Assets (ANTA).

A registered domestic builder must ensure at all times that the Total Value of Domestic Building Work being undertaken does not exceed its MCC, and that its ANTA does not fall below the ANTA Threshold required to support that MCC.

The regime also introduces a number of financial monitoring and reporting obligations for domestic builders. These include:

• Quarterly Internal Management Accounts where the builder’s MCC is $2m or greater. These must be prepared within 30 days of each quarter-end and include a profit and loss statement, balance sheet, cash flow statement, and aged debtors and creditors report (unless waived by the BPC).
• Notification obligations to the BPC, requiring builders to notify the BPC within seven days if they become aware they are likely to breach, or have breached, the MFR requirements.
• Information requests from the BPC, with builders required to provide financial information and supporting documentation within 14 days of a request.

It is worth noting that the requirements to monitor and maintain the required MFR ratios are continuous. The quarterly reporting requirement does not mean compliance is tested quarterly. Builders must maintain MCC and ANTA requirements on an ongoing basis and as noted above notify the BPC within 7 days if they become aware they are likely to breach the MFR requirements.

Accordingly, the practical compliance requirements for most domestic builders are to understand their MCC, monitor their ANTA, ensure they remain within their approved construction capacity, prepare management accounts where required, and maintain sufficient records to demonstrate compliance if requested by the BPC.

Effective dates and transitional rules

Existing domestic builders with an active Letter of Eligibility (from their designated insurer) on 30 June 2026 automatically transitioned into the MFR framework. Their existing Total Construction Limit became their Maximum Construction Capacity and they were not required to reapply to the BPC on 1 July 2026. These builders automatically became subject to the ongoing MFR obligations administered by the BPC.

New applicants for domestic builder registration and existing builders seeking to increase their MCC must engage directly with the BPC under the MFR framework. This requires the submission of an MFR Application or Change Application, together with financial information that enables the BPC to assess the builder’s financial capacity, determine its ANTA, and establish an appropriate MCC.

Builders seeking increased capacity must apply to the BPC before entering into contracts that would cause them to exceed their approved MCC. Where the requested capacity exceeds $2m, certain financial information must be verified by an independent qualified accountant.

Maximum Construction Capacity

Maximum Construction Capacity (MCC) represents the maximum value of domestic building work a builder can have underway at any point in time.

The legislation provides the following formula with two MCC thresholds:

Worked examples of MCC calculations

Adjusted Net Tangible Assets

Adjusted Net Tangible Assets (ANTA) is calculated as:

ANTA = Assets − Liabilities − Disallowed Assets

Total Value of Domestic Building Work (TVDW)

A builder’s Total Value of Domestic Building Work (TVDW) is calculated as the sum of:

1. The Contract Price under every Insurable Domestic Building Contract entered into by the builder, excluding contracts where either:

• the Completion Date has occurred
• the contract has been terminated.

Plus

2. The market value of all Speculative Domestic Building Work carried out by the builder where Home Warranty cover has commenced, excluding speculative projects that have reached Completion Date.

What happens if a builder breaches the MFRs?

Failure to comply with the MFR requirements may result in:

• disciplinary action under the Building Act 1993
• immediate suspension of registration
• requests for further information from the BPC
• entry into an MFR Agreement with the BPC to restore compliance.

The BPC must immediately suspend a builder’s registration if it reasonably believes the builder has ceased to meet the MFRs.

Proposed requirements removed from the final framework

Several features discussed during the consultation phase were not included in the final framework. It is important for builders and advisers to distinguish between the consultation proposals and the requirements that ultimately commenced from 1 July 2026. 

In particular, the following proposed measures did not form part of the final regime:

Key takeaway

For many domestic builders, the MFR regime does not replace existing insurer, banking, or commercial reporting requirements. Instead, it introduces a new layer of financial compliance focused on:

• maintaining ANTA
• staying within MCC limits
• monitoring Total Value of Domestic Building Work
• preparing quarterly management accounts (where required)
• demonstrating ongoing compliance to the BPC.

How SW can help

The new MFR regime introduces a number of new financial concepts and compliance obligations for domestic builders, including MCC, ANTA, ANTA Thresholds, and ongoing monitoring requirements.

SW can help builders understand these requirements, calculate ANTA and MCC, prepare Internal Management Accounts, assess compliance risks, and implement practical reporting processes to monitor their position throughout the year. We can also assist with BPC information requests, capacity increase applications, and strategic planning to support future growth.

Our focus is on translating the technical requirements into practical business advice, allowing builders to focus on building while maintaining confidence in their compliance obligations.

The post Victoria’s new Minimum Financial Requirements for domestic builders appeared first on SW Accountants & Advisors.