Statutory Review of the Payment Times Reporting Act 2020: KPMG Submission

Statutory review

As a leading professional services firm, KPMG is committed to meeting the requirements of all our stakeholders – not only the organisations we audit and advise, but also employees, governments, regulators and the wider community. We strive to contribute to the debate that is shaping the Australian economy and welcome the opportunity to provide a submission in response to the Statutory Review of the Payment Times Reporting Act 2020 (the Review).

KPMG has assisted many reporting groups with the Payment Times Reporting Act 2020 (PTR Scheme) since late 2020. This submission has been informed by the experiences that our technical experts have gathered through this work with key Australian businesses. For the avoidance of any doubt, KPMG is not advocating on behalf of our client base in this submission, but rather advocating for sensible reforms that seek to lower the cost of compliance and create better policy outcomes for small business.

Whilst initial data analysis indicates minimal improvement, KPMG strongly believes that the PTR Scheme has significantly improved the payment terms provided to small business suppliers across Australia’s largest reporting entities. The PTR Scheme has driven real cultural change and the prompt payment of small business suppliers is now receiving board and director level attention. However, there is always room for improvement.

KPMG has provided 11 recommendations in this submission where we believe the scheme could be improved to address compliance costs and to ensure the PTR Regulator (the Regulator) is more responsive to industry.

Several recommendations also consider other measures that the Review could consider putting further downwards pressure on payment periods, including:

better usability/comparability functions developed as part of the PTR Scheme website
stabilisation of the Guidance Material to ensure comparability between like-firms and prior reporting periods
recognition of Reporting Entities that sign on to voluntary payment codes
consideration of the development of a government run voluntary 30-day payment code, based on the UK scheme, where entities can be struck off for non-compliance
the addition of new mandatory reporting fields in the PTR Scheme i.e. whether an entity is eInvoicing/Peppol enabled; and/or whether the Reporting Entity has signed up to a voluntary payment code
targeting of industries/entities with poor payment terms through education and awareness campaigns.

We appreciate the opportunity to participate in the Review and we look forward to working with the government on sensible reforms to ensure the PTR Scheme is functioning efficiently and effectively.