Accountants Trust Account Audit NSW: Reliable & Affordable
Trusted NSW Accountants: Expert, Reliable & Affordable Account Audits You Can Count On.
Free Consultation
If you handle client money as a public practice accountant in New South Wales, you are required to have your trust account audited every year. This is not a suggestion. It is a mandatory obligation under APES 310 Client Monies, enforced by CPA Australia, Chartered Accountants Australia and New Zealand (CA ANZ), and the Institute of Public Accountants (IPA).
At Number Solutions Tax & Accounting, we specialise in accountant trust account audits across NSW. Based in Liverpool, South West Sydney, our qualified team helps accounting practices of all sizes meet their compliance obligations on time, every time.
Whether you receive ATO tax refunds on behalf of clients or hold advance payments in trust, we handle the full audit process so you can focus on running your practice.
How APES 310 Affects Your Trust Account Audit Obligations
APES 310 Client Monies is the professional standard that governs how Australian accountants deal with client funds. It was first issued by the Accounting Professional and Ethical Standards Board (APESB) in December 2010 and has been revised multiple times since then. The most recent revision was finalised in October 2024 and applies to engagements starting on or after 1 April 2025.
The standard applies to every member in public practice who deals with client monies or acts as an auditor of client monies. That includes members of CPA Australia, CA ANZ, and IPA.
When Does APES 310 Apply to You?
Many accountants are unsure whether APES 310 covers their specific situation. According to CA ANZ, the standard applies when you or your staff:
- Receive client tax refunds from the Australian Taxation Office into a trust account
- Request deposits or advance payments from clients before providing services
- Act as a signatory on a client’s bank account (sole or joint)
- Have access to a client’s accounting software and pay creditors from their bank account
- Handle any form of client money through a trust account or client bank account
Even bookkeepers who pay invoices and wages on behalf of clients may trigger APES 310 obligations if they have transactional authority over client funds.
Key Obligations Under the Standard
APES 310 requires you to:
- Handle all client monies through a separate trust account or client bank account only
- Keep client funds completely separate from your business operating funds
- Implement internal controls and procedures for trust account operations
- Maintain detailed records of all transactions involving client money
- Issue year-end statements to clients within 30 business days of the applicable year-end date
- Appoint an independent auditor and have your compliance audited annually
One practical update in the revised standard: if your bank cannot open an account with the words “trust account” in the name, you can now use the alternative term “client account.” National Australia Bank (NAB) has also developed a compliant APES 310 product specifically for CA ANZ members.
What APES 310 Does Not Cover
The standard does not apply when you act as a trustee under a trust deed or operate under a power of attorney. In those situations, you are not acting in a client relationship, and separate obligations apply.
We help NSW public practice accountants stay compliant and audit-ready with an affordable, independent trust account audit.
- Dedicated trust account audit for NSW accounting practices
- Fast and straightforward
- Clear, practical fixes explained simply
Who Can Audit an Accountant's Trust Account in NSW?
Your trust account auditor must hold a current practising certificate issued by one of three recognised professional bodies:
- CPA Australia
- Chartered Accountants Australia and New Zealand (CA ANZ)
- Institute of Public Accountants (IPA)
Here is a common misconception: you do not need a Registered Company Auditor to conduct an APES 310 trust account audit. CA ANZ confirms this clearly. The audit is a compliance engagement, not a financial statement audit, so the Corporations Act 2001 registration requirements for company auditors do not apply here.
Independence Requirements
Your auditor must be independent of your practice. Specifically, they must not have:
- Been employed by your firm or been a partner within the past two years
- Any material financial interest in your business
- Acted as the auditor of your trust account while you audit theirs (reciprocal auditing is not allowed)
You must also notify your professional body when you appoint a new auditor. CA ANZ requires this to discourage “opinion shopping,” where firms switch auditors to find a more favourable outcome.
Can Your Own Accountant Do It?
Only if they meet the independence criteria above. If they have any connection to your practice, even indirectly through a shared business interest, they are disqualified. At Number Solutions, we serve as an independent third-party auditor for accounting firms across NSW, keeping the process clean and compliant.
Audit Period Dates for NSW Accountant Trust Accounts
The audit period for accountant trust accounts is not the same as the standard financial year used for real estate or conveyancer audits. Your deadlines depend on when you opened your trust account.
Accounts Opened Before 1 July 2011
If your trust account was opened before 1 July 2011, the applicable year-end date is 31 March each year. Your audit must be completed within three months of that date, making your deadline 30 June.
Accounts Opened After 1 July 2011
If you opened your trust account after 1 July 2011, you can choose your own year-end date. It must fall within 12 months of the month-end following the date you opened the account or obtained transactional authority.
For example, if you opened your trust account on 15 August 2023, the month-end following that is 31 August 2023. Your chosen year-end must fall within 12 months of that date, so no later than 31 August 2024.
Once you set this date, you cannot change it without written approval from your professional body. For CA ANZ members, you submit a change request directly to them.
Lodgement Rules
Here is something many accountants do not realise: unqualified audit reports (meaning no issues were found) do not need to be lodged with your professional body. However, you must keep them on file. They can be reviewed during CPA Australia’s Best Practice Program or CA ANZ’s compliance reviews.
Qualified reports, where the auditor identifies breaches or discrepancies, must be reported to the relevant professional body and may trigger further investigation or disciplinary action.
Scenario | Year-End Date | Audit Deadline |
Trust account opened before 1 July 2011 | 31 March | 30 June |
Trust account opened after 1 July 2011 | Chosen date (within 12 months of opening) | 3 months after the chosen year-end |
Trust Account Record-Keeping Requirements for NSW Accountants
Strong record-keeping is the single most important factor in a smooth audit. Your auditor will assess your compliance with every documentation requirement set out in APES 310.
Make sure you have the following ready before your audit:
- Trust account bank statements covering the full audit period
- Client ledger cards showing deposits, withdrawals, and disbursements for each client
- Monthly bank reconciliation reports completed on time and without unexplained adjustments
- Client engagement letters authorising you to handle their funds
- Disbursement records with clear documentation of where money was sent and why
- Client notification logs showing year-end statements were issued within 30 business days
- Interest records for any interest earned on trust account balances
Common Mistakes That Trigger Audit Issues
Based on patterns reported by auditors and professional body compliance teams, the most common problems include:
- Missing reconciliations. Not completing monthly bank reconciliations is the number one issue flagged during trust account audits. It suggests a lack of oversight over client funds.
- Mixing funds. Using your trust account for business expenses or transferring client money through a non-trust account is a serious breach and a direct violation of APES 310.
- No written client authority. Deducting your professional fees from a client’s tax refund without their written consent is specifically addressed in the standard. Always get it in writing.
- Poor notification records. If you cannot show that year-end statements were sent to clients, auditors will flag this as non-compliance even if the statements were actually issued.
Keeping records current throughout the year avoids last-minute panic and reduces your audit costs.
Ready to make your trust account audit simple?
Book your FREE 15-minute consultation today and we’ll confirm what’s required, your timeline, and the smoothest path to a compliant, audit-ready outcome.
Why Choose Number Solutions for Your Accountant's Trust Account Audit?
Number Solutions has been delivering trust account audits for NSW accounting practices for over five years. We understand the specific requirements of APES 310 and work closely with practices of all sizes to keep the process simple.
- APES 310 specialists. We do not treat accountant trust audits like generic compliance work. Our team knows the standard inside out, including the October 2024 revisions.
- Fixed, transparent pricing. You will know the cost before we start. No surprises and no hidden charges. Remember, your audit fee is a business expense and cannot be paid from the trust account itself.
- Complete audit support. From initial document collection to final report preparation, we handle every step. If issues come up during the year, our team is available at no extra cost to answer your questions.
- Fast turnaround. We respect your deadlines and prioritise timely completion so you never risk a late submission to your professional body.
- Year-round compliance guidance. Beyond the annual audit, we help you set up internal controls, fix record-keeping gaps, and prepare for Best Practice Program reviews.
FAQs
APS 10 was the older trust account standard issued by the Institute of Chartered Accountants in Australia (ICAA). It applied only to ICAA members. APES 310 Client Monies replaced APS 10 in December 2010 as a unified standard issued by APESB. Unlike APS 10, APES 310 applies to members of all three professional bodies (CPA Australia, CA ANZ, and IPA) and covers a broader scope, including client bank accounts where accountants have signatory authority.
No. A trust account audit under APES 310 is a compliance engagement, not a financial statement audit. Your auditor needs a current practising certificate from CPA Australia, CA ANZ, or IPA. Registration as a company auditor under the Corporations Act 2001 is not required. What matters is that your auditor is independent and has the relevant experience in trust account compliance work.
Only with written approval from your professional body. If you are a CA ANZ member, you submit a request directly to CA ANZ. CPA Australia has its own approval process. Once your year-end date is set, it stays locked unless approval is granted. This rule exists to maintain consistency in audit reporting and prevent manipulation of audit timelines.
No. They are fundamentally different engagements. A trust account audit under APES 310 is conducted as a compliance engagement under ASAE 3100 Compliance Engagements. It assesses whether your practice has followed the specific requirements of the standard in handling client monies. A financial statement audit, by contrast, examines whether your overall business financial reports present a true and fair view. They have different scopes, different standards, and different reporting outcomes.
APES 310 does not prescribe specific software. However, your system must support proper fund separation, individual client ledger tracking, reconciliation reporting, and a clear audit trail. General accounting platforms can work if they allow you to maintain a trust account as a completely separate entity from your business accounts. Speak with your auditor to confirm that your current setup meets the requirements before your next audit period.
