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Leo111(Master)Master
4 Dec 2025

Our company issues RCTIs to contractors based on the diary entries they submit through our online booking portal. Currently, contractors receive the RCTI, review it, and then approve it. If they don't approve, we don't pay.



We are considering changing the process so that the invoice is automatically accepted on their behalf, given that they are responsible for entering the diary information. Any required adjustments would be handled through a debit note applied to their invoices.


Would there be any compliance or legal issues with implementing this process and us accepting the invoice on their behalf, and if so, what would they be?


Thanks,

200 views
2 replies
200 views
2 replies

All replies

ATO Certified Response
NikkiATO(Community Moderator)Community Moderator
ATO Certified Response5 Dec 2025

Hi @Leo111,


There's no compliance issue with automatically accepting RCTIs on your contractors' behalf, as long as you meet the GST rules for recipient created tax invoices.


For RCTIs to be valid, you must ensure:

  • both you and your contractors are GST registered when the RCTI is issued
  • you have a written agreement that allows you to issue RCTIs
  • the RCTI contains all required information
  • you issue the original or copy to the contractor within 28 days of the sale date.

As the RCTI issuer, you need strong systems and checks to ensure compliance. It's expected that you check contractors are GST-registered before issuing your first RCTI and undertake periodic checks to ensure they remain registered. You can use ABN Lookup to verify GST registration status.


Your proposed process change from manual approval to automatic acceptance doesn't affect these core RCTI requirements. The contractors' diary entries through your booking portal can serve as the basis for creating valid RCTIs, and handling adjustments through debit notes is acceptable.


Review the RCTI requirements on our Tax invoices page and consider using the Recipient-created tax invoices form as a template. Ensure your systems include automated validation checks for contractor GST registration status to maintain compliance.

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