INSIGHT · FINANCE & TAX RECORDS

The TPAR is not written in August.
It is written one payment at a time.

28 September 2026

The Australian Taxation Office (ATO) states that a business primarily in building and construction, with an ABN, that pays contractors for building and construction services must lodge a Taxable payments annual report (TPAR) by 28 August each year, reporting payments made on or before 30 June. Applied to 2025-26 (our application of that rule, not an ATO-printed date), the due date was 28 August 2026. Per contractor, the ATO asks for ABN, name, address, gross amount paid including GST, and GST paid: facts about individual payments, cheapest to capture on the day each is made.

Two sheets of paper marked PAID and DUE beside a calculator and a pair of glasses

Analysed 28 September 2026 · ATO TPAR guidance pages last updated between 14 March 2022 and 17 July 2026 · tax time 2026 pre-fill notice last updated 2 July 2026 · TPAR penalties notice published 9 March 2026 · all pages read 28 September 2026.

Key takeaways

The ATO's test for building and construction is "primarily", not 10%: The ATO describes a 10% of business income test for businesses providing a mix of reportable and other services, and states of that test: "This doesn't apply to building and construction services you provide." For building and construction it describes a business "primarily in the building and construction industry", measured by three 50% limbs.
The report is per contractor; the facts are per payment: The ATO asks for each ABN (every ABN, if it changed during the year), name, address, gross amount paid including GST and any tax withheld, total GST paid, and tax withheld where no ABN was quoted. Its own record-keeping worksheet has one row per payment, starting with the date paid.
Two dates on every invoice, and only one of them counts: The ATO excludes "unpaid invoices after 30 June" and states that "TPAR information is reported on a cash basis". The invoice date and the payment date are different fields.
The report follows the entity that pays: The ATO's worked examples attach the obligation to the entity making the payments, including a property developer's separate project entity. For significant global entities, the ATO states that "TPARs must be lodged by each entity, individually".
We would capture the TPAR fields at the moment of payment, in the entity that pays: A system-design recommendation, not a statement of what the law requires of any business.

Who the ATO says reports,
and the test that does not apply.

The ATO's building and construction page (last updated 23 April 2024) states that a business "primarily in the building and construction industry" must lodge a TPAR if it makes "payments to contractors or subcontractors for building and construction services" and has an Australian business number (ABN). It adds: "Payments made to employees are not reported in your TPAR."

Three 50% limbs, any one of which applies: In the current financial year, 50% or more of business income is earned from building and construction services; or 50% or more of business activity relates to them; or, in the immediately preceding financial year, 50% or more of business income was earned from them. The third limb carries one year's mix into the next: the ATO's cabinet-maker example still reports in a year below 50% because the year before was above it.
The 10% test belongs to other services: The ATO's work-out page describes a percentage test against business income for businesses where reportable services are only part of what they provide, with a 10% threshold. The same page states it "doesn't apply to building and construction services you provide". Which test is being applied is a question to settle with an adviser rather than assume.
"The definition of building and construction services is broad": The ATO's examples include architectural work including drafting and design, engineering, surveying, project management, construction management, and plumbing and electrical inspection. Its example of a builder paying a certifier for inspections and an occupancy permit concludes the builder "must report the total payments it made". Equipment hire with an operator is described as a building and construction service; testing and tagging of tools is described as not one.

What goes in, what stays out,
and what the ATO asks for.

The ATO's contractor details page (last updated 23 April 2024) states that for each contractor paid, the TPAR must include: ABN, if known, and "if a contractor's ABN changed during the year, include each ABN for that contractor"; name; address; and, for the financial year, the "gross amount paid, including goods and services tax (GST) and any tax withheld", the "total GST you paid them" and the "total tax withheld where an ABN was not quoted". Its payments page sets out what is in and out.

Payment	As the ATO states it
Invoice with labour and materials	"Report the total payment amount if an invoice you receive from a contractor includes both labour and materials."
Materials only	Listed as not reported: "payments for materials only".
Labour incidental to materials	"Exclude the labour amount for invoices that list both materials and labour. Do this if the labour is incidental to the supply of materials."
Invoice unpaid at 30 June	"only report payments you made on or before 30 June each year".
Labour hire and PAYG withholding payments	Listed as not reported; employee payments go through the PAYG withholding annual report or Single Touch Payroll.
Payments inside a consolidated group	"you don't need to report payments made to another member of that same group."
Contractor who did not quote an ABN	Listed as not reported, with amounts withheld reported in either the TPAR or the separate NAT 3448 form: "Only report this information in one of these annual reports, not both."

The ATO's own worksheet is one row per payment: The Taxable payments reporting worksheet (NAT 75101-09.2018) has five columns: "Date paid", "Details (eg invoice number, labour and materials, etc)", "Total tax withheld where ABN not quoted", "GST amount paid" and "Total amount paid (including GST)". The ATO states it is for the business's own records and is not sent to the ATO. None of its columns can be read off a year-end supplier balance.
The ABN is checked per invoice: The ATO tells a payer receiving an invoice to "check that the ABN on the invoice matches the ABN on your record for that contractor" and to create a new contractor record if necessary.

Three dates, and what changed
around the 2025-26 report.

The payment date, the due date and the non-lodgment date are separate. Around the 2025-26 report the ATO also began pre-filling TPAR data for individuals in business: the figure a payer reports for a sole trader or contractor is now pre-filled in that contractor's own return.

Applied to the 2025-26 financial year, the ATO's annual rule gives a cut-off of 30 June 2026 and a due date of 28 August 2026. That pairing is our application of the rule.

Date	As the ATO states it
The payment date	Only payments made on or before 30 June are reported; "TPAR information is reported on a cash basis" (contractors page, last updated 17 July 2026).
The due date	"A TPAR must be lodged by 28 August each year." The registered agent due-date page (last updated 1 July 2026) states the report "is due for lodgment by 28 August".
The non-lodgment date	"TPARs and NLA forms are due by 28 August each year" (ATO notice, 9 March 2026). NLA is the TPAR Non-lodgment advice form.

Electronic lodgment only: "TPAR paper lodgments are no longer accepted after 28 August 2025." The ATO's 3 August 2026 final reminder repeats: "All TPAR lodgments must be made through electronic channels."
Pre-fill into contractors' returns: The ATO's tax time 2026 notice states that "payments reported to us through TPAR by payers will now be pre-filled in your tax return", and that "Most TPAR data will be available after 28 August each year, after payers lodge their reports." The ATO states a contractor can check and change pre-filled amounts, and that a contractor on an accruals basis may see a mismatch because TPAR is on a cash basis.
A penalty notice and a new penalty unit: On 9 March 2026 the ATO stated it would apply failure to lodge penalties to those issued "three non-lodgment letters about their overdue TPAR" who had not lodged their TPAR from 2025 or previous years, adding: "Last year, we issued just over $5 million in penalties." Its penalty unit table lists $364 for infringements on or after 1 July 2026 ($330 from 7 November 2024 to 30 June 2026).
How the ATO describes the penalty: The base penalty is "one penalty unit for every 28 days (or part thereof) that the document is overdue, up to a maximum of 5 penalty units", multiplied by 2 for a medium withholder, 5 for a large withholder and 500 for a significant global entity. The ATO names the TPAR as a "third-party data report", outside its general practice of not issuing a penalty notice where a late lodgment results in a refund or nil result.

One group, several reports.

Residential construction is often run through more than one entity: a building company, a development entity per project, sometimes a separate installation business. The ATO's worked examples consistently attach the obligation to the entity that pays.

For a group, "which entity paid this contractor" bears on which report the payment belongs in, whether it sits inside a consolidated group, and whether the paying entity is one the ATO would describe as primarily in building and construction for that year.

A developer's project entity: The ATO describes a property developer that "has created a separate entity called Upmarket Apartments. This entity manages the project and construction of the apartments." The ATO states that this entity "must report payments to contractors for providing building and construction services", because 50% or more of its business activity relates to them.
A separate installation entity: In the ATO's hardware retailer example, the retailer is primarily in retail and does not report; the separate installation entity it sets up does report, because all of that entity's income is from building and construction services.
A subcontract chain: The principal contractor reports its payments to the first subcontractor. The first subcontractor reports its payments to a second, if it is itself carrying on a business primarily in building and construction services.
Consolidated groups and significant global entities: Members of a consolidated or multiple entry consolidated group "don't need to report payments made to another member of that same group". For significant global entities, the ATO's 8 October 2025 bulletin states: "TPARs must be lodged by each entity, individually. A head entity can't lodge on behalf of group members."

Why reconstruction in August
is where errors come from.

A TPAR prepared in August from a general ledger starts from supplier totals. A ledger reliably holds the amount and the supplier. Whether it also holds the facts the ATO's guidance turns on depends on what was entered when each invoice was paid.

Labour or materials: A supplier coded to materials may have issued some invoices with installation included. On the ATO's guidance, a mixed invoice is reported at its total, a materials-only invoice is not reported, and incidental labour is excluded. The split is visible on the invoice, on the day.
Paid date versus invoice date: An invoice dated in June and paid in July falls into the next year's report on the ATO's 30 June rule. A ledger report run by invoice date puts it in the wrong year.
ABN at the time: The ATO asks for each ABN if a contractor's ABN changed during the year. A single supplier card overwritten in March loses the first ABN.
Which entity paid: Where one entity pays on behalf of another, the paying entity and the entity that engaged the contractor can differ.
Corrections are not free: The ATO states an amendment "may take up to 28 days to process", that payee details "must be exactly as they appeared in your original lodgment, except the amended amounts", and that adding a payee requires lodging another TPAR.

What we would put in a system

Where agents help is narrow. A finance agent can read a contractor invoice, extract the ABN, invoice number, GST and any labour and materials lines, compare the ABN with the contractor record, and draft the payment record with a proposed composition. A person confirms it before it is relied on. No agent decides whether a business has to lodge a TPAR, whether a service is a building and construction service, whether labour is incidental, or whether a payment is reportable. Those are matters for the business, the ATO and its tax adviser.

Field	Why it is load-bearing
Paying entity	The ATO's examples attach reporting to the entity that pays, and payments within a consolidated group are treated differently. Recorded on the payment, not inferred from a project code.
Contractor ABN as at the invoice	The ATO asks for each ABN if it changed during the year, and tells payers to check the invoice ABN against the record. Stored per payment, so a change does not overwrite history.
Date paid, separate from invoice date	Only payments made on or before 30 June are reported, on a cash basis.
Composition of the invoice	Labour and materials, materials only, or labour incidental to materials: proposed at entry, confirmed by a person, with the invoice attached.
GST, gross paid and any amount withheld	The ATO asks for gross amount paid including GST and any tax withheld, total GST, and tax withheld where no ABN was quoted.

Questions worth asking
of your own records

For a builder: for a supplier who sometimes supplies and installs, can you tell which payments were materials only, which were labour and materials, and where labour was incidental?

If the answer lives only on the PDF invoices, the figure for that supplier is rebuilt by hand each August. The ATO's guidance treats each of those three cases differently.

For a construction group's finance lead: which entities in the group made contractor payments in 2025-26, and which of them sit inside the same consolidated group?

The ATO's examples attach reporting to the paying entity, and it states that payments to another member of the same consolidated group are not reported. Both facts have to be on the payment record to be queried.

For a developer running project entities: did each project entity's contractor payments sit in that entity's own records, or were some paid from a parent account?

The ATO's own example is a developer's separate project entity that manages the project and construction, and that reports its payments to contractors.

For a trade business that subcontracts: do you record the date each subcontractor was paid, separately from the invoice date?

The ATO's 30 June rule and cash basis turn on the payment date, and a payer's reported figure is now pre-filled into the return of a subcontractor who is an individual in business.

For whoever prepares the TPAR: when a contractor's ABN changed during the year, does the record keep both?

The ATO asks for each ABN. A supplier record that is overwritten when the ABN changes cannot answer that question later.

What this analysis
does and does not show.

Evidence note

What it shows: How the ATO, as read on 28 September 2026, describes the TPAR for building and construction: who it describes as reporting, the three 50% limbs, which payments are included and excluded, the contractor details required, the 28 August due date and 30 June cut-off, and the changes and notices published around the 2025-26 report.
Key facts quoted: TPAR due by 28 August each year; only payments made on or before 30 June reported; cash basis; 10% test "doesn't apply to building and construction services"; three 50% limbs; mixed labour and materials invoices reported in total; materials only excluded; each ABN if changed during the year; paper lodgments not accepted after 28 August 2025; TPAR pre-fill for tax time 2026; penalty unit $364 on or after 1 July 2026.

We read ATO guidance pages, not the legislation. The ATO's building and construction page refers to Subregulation 64(6) of the Taxation Administration Amendment Regulation 2012 (No. 1); we did not read or characterise it.
Several core ATO pages were last updated on 23 April 2024. We report them as read on 28 September 2026 and did not test whether any statement has changed in law since.
The 2025-26 cut-off and due date (30 June 2026 and 28 August 2026) are our application of the ATO's annual rule.
The explicit statement that TPARs must be lodged "by each entity, individually" comes from an ATO bulletin addressed to significant global entities. For other groups we rely on the ATO's worked examples, which attach reporting to the paying entity.
We do not cover the government entity or grant parts of the TPAR, or other reportable services such as cleaning, courier, IT or security.
This is general information about Australian federal tax guidance. It is not tax advice, and it does not determine whether any business must lodge, whether any payment is reportable, or whether any penalty applies.

What to watch next

30 June 2027 and 28 August 2027: The ATO states that only payments made on or before 30 June each year are reported and that the TPAR is due by 28 August each year. Applied to the 2026-27 year, which began on 1 July 2026, those are the next cut-off and due date (our application of the ATO's annual rule).
Pre-fill after 28 August: The ATO states that most TPAR data will be available for pre-fill after 28 August each year, after payers lodge their reports.
The penalty unit: The ATO lists $364 per penalty unit for infringements on or after 1 July 2026.

Bring us one entity's contractor payments.

Bring us one year of contractor payments from one entity. We will show you which of the fields the ATO asks for were captured at the time of payment, and which would have to be reconstructed.

General information only, about Australian Taxation Office guidance as read on 28 September 2026. Not tax, legal or financial advice. It does not determine whether any business must lodge a TPAR, whether any payment is reportable, or whether any penalty applies. Australian federal guidance only.

Send us the payments · For construction companies

Sources

Suggested citation: Australian Taxation Office, Taxable payments annual report guidance pages, as read 28 September 2026. No figures are calculated. The 2025-26 cut-off and due date (30 June 2026 and 28 August 2026) and the 2026-27 dates (30 June 2027 and 28 August 2027) are our application of the ATO's "each year" rule rather than dates printed for those years.

The TPAR is not written in August. It is written one payment at a time.