The Payment Times Reporting Regulator has entered a new phase of active enforcement under the amended Payment Times Reporting Scheme. With infringement notices now being issued, reports being corrected at the Regulator's direction, and slow small business payers being identified for potential Ministerial directions, reporting entities face a materially different compliance risk environment, one where non-compliance carries tangible financial, regulatory and reputational consequences.
A clear shift from education to enforcement
The Regulator has moved decisively from an educative posture to active enforcement under the amended Payment Times Reporting (PTR) Scheme. Reporting entities that have historically treated the Scheme as a relatively low-risk compliance obligation now face a materially different environment, in which the Regulator is actively exercising the expanded powers available to it under the Payment Times Reporting Act 2020 (Cth), as strengthened by the 2024 reforms.
Recent enforcement activity by the Regulator includes:
- Issuing infringement notices of $99,000 for non-compliance with reporting obligations;
- Directly engaging with reporting entities to require correction of inaccurate or incomplete reports previously lodged; and
- Identifying slow small business payers who may be subject to formal directions to improve their payment performance.
For reporting entities, the cost of inaction, whether in the form of late reports, inaccurate data, or poor payment performance, is becoming increasingly significant.
The Regulator's expanded powers in practice
The 2024 reforms substantially broadened the Regulator's enforcement toolkit, and the Regulator's most recent compliance update confirms that these powers are being actively applied across the reporting population. The Regulator's powers now span the full compliance lifecycle, from initial engagement through to formal penalty action, and includes:
Reminder and warning letters to prompt entities to report or to correct identified issues;
Infringement notices, with details of paid penalties published on the Regulator's register;
Required corrections and revisions to previously lodged reports and Entity Information Forms;
Public identification of non-compliance, including withholding reports from the Payment Times Reports Register;
Directions to entities with poor payment performance to small business suppliers, which can require public disclosure of slow payer status across a company's website and procurement, ESG-related and other documents;
Audits of reporting data, systems and processes; and
Civil penalties for serious or repeated contraventions.
The Regulator's 2025–26 Compliance and Enforcement Priorities further reinforce this trajectory, with a continuing focus on failure to report on time, false or misleading reports and/or conduct, and failures to comply with directions issued by the Regulator or the Minister.
In short, these powers are no longer theoretical. Reporting entities should not assume that past tolerance of minor non-compliance will continue, as the Regulator has made clear that non-engagement is no longer a viable compliance strategy.
Slow small business payer directions
One of the most significant powers introduced under the amended PTR Scheme is the Minister's ability to issue a direction to an entity that has been classified as a slow small business payer (i.e. fallen within the slowest 20% of small business payers overall or within its industry division) for two consecutive reporting cycles, or that was a slow payer in one cycle and failed to submit a report in the cycle before or after.
With the lodgment of reports for the reporting period ending 31 December 2025 now complete, the Regulator will, for the first time, hold the data needed to identify entities meeting these criteria. While no specific timeline has been indicated, letters and potential directions could be issued in the coming months once the Regulator has completed its review of the 31 December 2025 lodgements.
The consequences of receiving a direction are significant. A direction may require a business to publicly disclose its status as a slow small business payer across its company website, invoices, procurement, ESG-related and other documents, with material reputational and commercial implications for customer, supplier, investor and broader stakeholder relationships.
Reporting entities that estimate they may fall within the slowest 20% for two consecutive periods should consider proactive engagement with the Regulator, rather than waiting to be contacted. Early engagement can help manage the risk of escalation and demonstrate a constructive compliance posture.
Key areas of exposure for reporting entities
In light of the Regulator's more assertive posture, reporting entities should be particularly alert to risks arising in the following areas:
Timeliness of reporting – late or missed reports remain the most direct trigger for enforcement action.
Accuracy and completeness of data – including correct identification of small business suppliers, appropriate use of the Small Business Identification (SBI) Tool, and integrity of data extracted from source systems.
Small business payer direction – entities whose 95th percentile payment time falls within the slowest 20% overall or within their industry division for two consecutive reporting cycles face heightened exposure, including the risk of a formal direction requiring public disclosure of their slow payer status.
Governance and oversight – including the adequacy of review and sign-off processes, clarity of accountabilities, and executive and board visibility over reporting outcomes.
Responsiveness to Regulator engagement – prompt and complete responses to Regulator correspondence are essential to managing downstream compliance risk.
Taking a proactive and structured response
Given the Regulator's heightened expectations, reporting entities should take a proactive and structured approach to managing their risks. Entities should consider:
Reviewing the integrity of reporting data, systems and methodologies, including the appropriate use of the SBI Tool;
Assessing previously lodged reports for accuracy and completeness, and considering proactive revisions where appropriate;
Benchmarking payment performance against peers, including modelling your 95th percentile payment time and estimated ranking to assess the risk of falling within the slowest 20% overall or within your industry division;
Strengthening governance frameworks over the reporting process, including documented controls, clear accountabilities and board oversight; and
Preparing for potential Regulator engagement, including the possibility of infringement notices, directions, published non-compliance or audits.
By analysing your reporting data and processes, PwC can help you identify the areas of greatest compliance risk and the most effective actions to address them (further details are set out below).
How PwC can help you
Compliance health check
PwC can assess the maturity of your Payment Times Reporting compliance framework, including data, systems, methodology, governance and controls, against the Regulator's expectations and current enforcement focus. This provides an early warning of areas of potential exposure and a clear roadmap for remediation before issues attract regulatory attention.
Historical report review and remediation
We can review your previously lodged reports and Entity Information Forms for accuracy and completeness and support you to submit proactive corrections where appropriate. Taking the initiative to remediate issues is typically viewed more favourably than waiting for the Regulator to require action.
Slow small business payer risk assessment, benchmarking and payment performance analytics
Using our interactive analytics dashboard, PwC benchmarks a client’s payment performance against peers and the broader reporting population based on Regulator-published data. We can help assess whether your business is likely to fall within the slowest 20% of small business payers, overall or within your industry division, and pinpoint the factors most affecting your 95th percentile payment time. This enables you to identify targeted improvements most likely to reduce your risk of being identified as a slow small business payer.
Streamlined reporting and automation
Our Payment Times Reporting Solution automates the full PTR reporting workflow, from data transformation and quality review through to final report generation. Combined with our team of technical specialists, we can help you reduce manual effort, minimise compliance risk, and ensure your reports align with the specific requirements of the amended Scheme.
Regulator engagement support
Where the Regulator has made contact, whether through a reminder letter, warning letter, request for correction, infringement notice or direction, PwC can support you to respond effectively, manage the underlying issues and reduce the risk of escalation.
By combining regulatory insight, analytics, and automation, PwC helps clients not only meet their reporting obligations under a more assertive regulatory environment, but also protect their reputation, strengthen supplier relationships, and maintain a competitive position in the market.
For more information, visit PwC's main Payment Times Reporting webpage.
Sean Lee
Partner, Tax Reporting and Innovation, PwC Australia
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