JobMaker Hiring Credit Reporting Obligations Instrument 2020

The instrument builds on several core concepts defined in the Rules and the Taxation Administration Act (the instrument explicitly imports definitions from s 4 of the Rules (s 5)). The principal concepts that structure the instrument are jobmaker period, jobmaker scheme, eligible additional employee, employer, baseline payroll amount, baseline headcount, and claim information (s 5). The instrument defines and operationalises "claim information" as the package of information a claimant must give the Commissioner to satisfy the reporting requirements for a jobmaker period (s 5; s 8).

Important operational concepts the instrument uses are:

• Single Touch Payroll (STP) reporting: the instrument treats compliance with STP notification obligations under s 389‑5 of Schedule 1 to the Taxation Administration Act 1953 as the primary channel for employers to notify employee-level data required for JobMaker claims (s 7(1)-(2)). The instrument explicitly notes the manner of notification under s 389‑5 is known as Single Touch Payroll (s 7(2) note).
• STP JobMaker Reporting Deadline: the instrument sets an STP reporting deadline for each jobmaker period (s 7(1) table). This is a separate timetable to the claim period and is relevant to employers required to notify under s 389‑5.
• Claim period: this is the window in which the employer must lodge its claim information for a corresponding jobmaker period (s 10(1) table). The instrument lists the claim period corresponding to each jobmaker period.
• Declaration and signature rules: the instrument mandates a short textual declaration (wording provided, s 8(4)) and allows three signature methods (digital signature via myGovID with Relationship Authorisation Manager, digital signature via myGov credentials, or identity verification procedures for phone lodgements as per the Chief Executive Instruction (CEI) Identity Management Policy) (s 8(4)-(5) and the signature table). These set who may sign and by what means the Commissioner will accept a claim as properly authorised.
• Immutable claim data: the instrument makes submitted claim information (other than bank account details provided under s 8(2)(h)) unchangeable after the claim period ends (s 10(2)). This fixes the data employers use to support an entitlement and allocates evidentiary risk to the claimant once the claim period closes.

The instrument also introduces administrative discretion and conditional relief:

• Commissioner satisfaction: the instrument allows the Commissioner to determine whether the STP-software limitation applies to an employer so that only TFN and full name need be provided via STP (s 7(2A)-(2B)). This creates a case-by-case discretion to accept incomplete STP data where software prevents otherwise.
• Exemption pathway tied to prior reporting: employers exempt from STP under the Taxation Administration Act can lodge by phone, but only if they have previously notified all amounts required under s 16‑150 Schedule 1 for the two-year period ending on the jobmaker period’s last day (s 7(3)-(4)). This channels lower-technology claimants into a prior-records verification requirement.

Conceptually the instrument is narrow and administrative. It does not itself define entitlement amounts, nor does it set eligibility criteria beyond requiring confirmation that each employee claimed is an eligible additional employee (s 8(2)(e)). The substantive eligibility definitions and monetary mechanics reside in the Rules and the Act; this instrument prescribes the data flows and authorisation processes the Commissioner will use to decide that the reporting requirement has been met (s 6, s 8).

The instrument applies to any employer participating in or seeking to participate in the JobMaker Hiring Credit scheme (s 4). That captures a wide functional category: employers who wish to claim the hiring credit for eligible additional employees and employers who must continue to meet STP reporting obligations under the Taxation Administration Act (s 7(1)). The following distinct groups of employers are affected differently.

• Employers required to notify under s 389‑5 Schedule 1 TAA 1953 and who already use STP-capable software: these employers must ensure their STP reports include the employee-level fields set out in s 7(2) by the STP JobMaker Reporting Deadline for each jobmaker period (s 7(1)-(2)). They also must lodge claim information during the claim period (s 10(1), s 8).
• Employers who use payroll software that cannot be updated to supply all required STP fields: the instrument recognises that some software providers cannot update their STP feeds to include the additional fields required for JobMaker reporting. If the Commissioner is satisfied of that inability, the employer is only required to notify TFN and full name via STP for the affected jobmaker period and subsequent jobmaker periods (s 7(2A)-(2B)). However, the instrument then requires those employers to provide the rest of the per-employee details when making their claim (s 8(3), (3A)). The Commissioner’s satisfaction is an administrative filter that can shift data collection off STP and onto claim-time processes.
• Employers exempt from STP reporting under s 389‑10(3) Schedule 1 TAA 1953: these employers may use the phone route to provide claim information (s 9(2)) but face an additional condition. Before using the phone route, they must have notified all amounts required under s 16‑150 Schedule 1 TAA 1953 that were required to be notified in the two years ending on the last day of the jobmaker period (s 7(3)-(4)). This affects employers who are small, not using STP, or otherwise exempt from digital pay‑as‑you‑go withholding reporting: they must demonstrate a two-year reporting history before they can use the phone route to claim.
• Authorised agents: the instrument contemplates authorised agents lodging on behalf of employers. The declaration wording for authorised agents requires a statement that the agent prepared the document using information supplied by the entity and that the agent has received a written declaration from the entity that the information is true and correct (s 8(4)(b)). This affects tax agents and advisers; the instrument places an express documentation requirement on agents to obtain a written declaration from their client.
• Payroll and software providers indirectly affected: while not the instrument’s legal addressee, payroll software that cannot supply the required fields creates a practical compliance issue for the employer-users of that software. The instrument’s 7(2B) recognition of software limitations and the Commissioner’s discretion under 7(2A) make software capability a de facto determinant of an employer’s data‑flow obligations. Employers who rely on third-party payroll providers must ensure those providers can meet STP requirements or be prepared to supply missing fields at claim time.

Who pays: the immediate administrative cost falls on employers (and their payroll providers/agents) who must prepare and lodge the specified data on the timetable set by the instrument. Who decides: the Commissioner decides whether an employer is excused from providing certain STP fields due to software constraints (s 7(2A)-(2B)), and the Commissioner accepts claim lodgements via prescribed channels (s 9). What behaviour changes: employers must ensure timely STP updates, may need to obtain or retain written declarations from employees or clients, may need to obtain myGovID/RA Manager credentials for authorised signatory signatures, and may need to assemble per-employee evidence for claims if STP cannot supply it.

The instrument imposes specific duties on employers and provides narrow procedural rights to claimants. These duties and rights are administrative rather than substantive entitlements.

Primary duties created by the instrument

• Duty to provide required employee data by the STP JobMaker Reporting Deadline where the employer is required to notify amounts under s 389‑5 Schedule 1 TAA 1953 (s 7(1)-(2)). The specific fields required via STP are TFN, date of birth, full name, dates of employment commencement and cessation if occurring in the jobmaker period, and whether the employee met the average hours requirement (s 7(2)).
• Duty to lodge full claim information during the claim period via ATO online channels or via phone for employers exempt from STP (s 8; s 9). The claim information includes quantitative payroll and headcount fields, confirmation of eligible additional employees, a declaration, a signature conforming to specified methods, and bank account details (s 8(2)(a)-(h)).
• Duty on authorised agents to hold a written declaration from the entity confirming truthfulness if the agent lodges on the employer’s behalf (s 8(4)(b)). The agent must include specific declaratory wording when lodging.
• Duty on exempt employers who lodge by phone to have previously notified amounts under s 16‑150 Schedule 1 TAA 1953 for the prior two years up to the jobmaker period end date before providing claim information (s 7(3)-(4)). The instrument requires that notification to have occurred before the employer provides claim information.

Procedural rights and tolerances

• Right to use the Commissioner’s discretion where STP software cannot transmit all fields: if the Commissioner is satisfied the software prevents complete reporting, the employer need only notify TFN and full name via STP (s 7(2A)-(2B)). This is a conditional permission, not an automatic exemption.
• Right to lodge claim information through specified digital channels: employers may use ATO Online Services for Individuals, ATO Online Services for Business, Online Services for Agents, or the Business Portal (s 9(1)). This right centralises digital lodgements.
• Right to update bank account details after the claim period: s 10(2) freezes claim information submitted during the claim period except for information covered by paragraph 8(2)(h) , bank account details , which by implication may be updated after the claim period. The instrument therefore treats bank account details as mutable relative to other lodged claim information.
• Right to use different signature authentication methods: the instrument gives employers options for signing claims , myGovID with Relationship Authorisation Manager, myGov credentials, or phone identity verification consistent with the CEI Identity Management Policy (s 8(5) and signature table). Each method carries setup obligations for the signing person or their organisation.

Limits and missing duties

• No penalty provisions are included in the instrument itself. The instrument does not set fines, civil penalties, or criminal offences for incorrect reporting; it limits itself to defining the content, manner and timing of reporting, and the Commissioner’s satisfaction in respect of STP limitations (s 6, s 7, s 8, s 9, s 10). Any civil or criminal consequences for false or misleading statements must therefore derive from other laws and are not specified in this instrument.
• No administrative appeal mechanism is provided in the instrument. The instrument prescribes eligibility-related reporting steps; it does not specify an internal review or merits-review pathway for a Commissioner decision under s 7(2A) or for the acceptance or refusal of a claim. Those procedural rights, if any, will depend on the Rules, the Act, or other administrative law provisions outside this instrument.

In short, the instrument converts reporting obligations into specific, timebound duties with specified authentication steps. Employers’ rights are largely procedural: to lodge via specified channels and to seek the Commissioner’s satisfaction where software prevents STP reporting of all fields. The instrument places document and authentication duties on employers and authorised agents which shift evidentiary burden to claimants at lodgement time.

The instrument itself does not create express statutory penalties or specify enforcement sanctions. Its enforcement architecture is administrative: meeting the instrument’s reporting requirements is a condition for satisfying the reporting element of the JobMaker Rules (s 6). The practical enforcement mechanisms and potential consequences follow from that administrative link rather than from express penalty clauses in the instrument.

Key enforcement-relevant provisions in the instrument

• Condition precedent to reporting satisfaction: s 6 states that an employer meets the reporting requirements for a jobmaker period for the purposes of paragraph 27(1)(h) of the Rules only if the employer has given the information set out in the instrument by the time and in the manner specified. This makes timely and properly lodged reporting a de facto precondition for the Commissioner to consider that the Rules’ reporting requirement is satisfied.
• Immutable claim data after claim period: s 10(2) makes claim information submitted in accordance with s 9 (except bank account details) unchangeable after the claim period closes. The immutability of submitted data raises administrative enforcement effects: errors or misstatements cannot be corrected after the claim window, which increases the risk that disputed or incorrect claims will be processed on the basis of unamendable lodged data or be subject to later administrative action.
• Commissioner discretion: the Commissioner is given power to determine whether STP software constraints apply so that the employer need only provide TFN and name via STP (s 7(2A)-(2B)). That discretion is an enforcement lever; the Commissioner’s decision alters how compliance is measured for a given employer.
• Identity verification and signatures: the instrument prescribes accepted signature/authentication methods (s 8(5) and signature table). The Commissioner’s acceptance of a signature method functions as a checkpoint for authorised lodgements and is part of the instrument’s enforcement architecture.

What the instrument does not do , and the implications

• It does not identify or specify civil or criminal penalties for providing false or misleading information in a JobMaker claim. The instrument’s silence means any legal consequences for false statements are to be found in other statutes (for example, in taxation or general criminal laws), but the instrument itself does not state those consequences.
• It does not set out audit, recovery, or debt-raising procedures for overpayments. The instrument specifies the information a claimant must lodge, but it does not describe how the Commissioner will pursue overpayments or incorrect payments. Those processes are likely covered by the Rules, the Act, or general ATO administrative procedures, not in this instrument.
• It does not provide an internal dispute-resolution or merits-review path for Commissioner decisions under s 7(2A) or for decisions to accept or reject claims. Employers facing an adverse administrative decision need to look to other parts of the law for review rights.

Practical enforcement risks for employers

• Rejected or delayed payments: failure to meet STP deadlines or to provide required claim information in the claim period may mean the Commissioner cannot treat the employer as meeting the reporting requirement under the Rules (s 6). That has the practical effect of jeopardising payment entitlement until compliance is achieved.
• Data immutability amplifies the cost of mistakes: because claim information (other than bank details) cannot be altered after the claim period (s 10(2)), employers risk being locked into incorrect lodged data, which may create later administrative recovery or dispute risk.
• Reliance on Commissioner discretion adds uncertainty: the ability to rely on a relaxation where payroll software cannot supply certain fields depends on the Commissioner’s satisfaction (s 7(2A)). Employers using older or non‑compliant payroll software face uncertainty about whether they will qualify for the relaxation and when that determination will be made.

In summary, enforcement under this instrument is administrative and operates by conditioning the Rules’ reporting satisfaction on completion of the instrument’s tasks. The instrument does not itself prescribe penalties but it creates time and data constraints that, if not met, will affect an employer’s entitlement to the JobMaker payment and create administrative risk.

This instrument is deliberately limited and explicitly interlocks with other statutes and instruments. It imports definitions, relies on STP reporting obligations established in the Taxation Administration Act 1953 and its Schedule 1, and references the Rules and the parent Act for substantive eligibility. The key interactions set up by the instrument are the following.

• Dependence on the Coronavirus Economic Response Package (Payments and Benefits) Rules 2020: the instrument repeatedly relies on definitions and the substantive framework set in the Rules (s 5). It makes compliance with the instrument a route to satisfy paragraph 27(1)(h) of the Rules (s 6). This creates a layered legal relationship: the Rules set the eligibility architecture and the instrument prescribes the reporting mechanics required by the Rules.
• Reliance on the Taxation Administration Act 1953 reporting architecture: the instrument treats STP reporting obligations under s 389‑5 of Schedule 1 to that Act as the primary method for employers to notify employee-level fields required to support JobMaker claims (s 7 note; s 7(1)-(2)). It uses stated exemptions under s 389‑10(3) Schedule 1 TAA 1953 to determine who may lodge by phone and imposes a two-year prior-notification requirement under s 16‑150 Schedule 1 TAA 1953 for such employers (s 7(3)-(4); s 9(2)). Thus, the instrument is operationally grafted onto the pre-existing PAYG/STP reporting regime.
• Interaction with ATO identity and authentication procedures: the instrument adopts approved identity and authentication methods, such as myGovID with Relationship Authorisation Manager and the CEI Identity Management Policy for phone lodgement verification (s 8(5) and signature table). This links the instrument to administrative identity-verification frameworks maintained by the ATO and other government online services.
• Administrative discretion by the Commissioner: the instrument explicitly grants the Commissioner a gatekeeping role in assessing whether STP software limitations justify reduced STP reporting (s 7(2A)-(2B)). That discretion interacts with the Commissioner’s broader statutory functions under taxation law and the Rules, although the instrument does not specify appeal or review routes for such discretionary determinations.
• Implicit links to offences and recovery regimes outside the instrument: the instrument does not itself create offences or recovery mechanisms, so any consequences for false statements, misconduct, or the recovery of overpayments will depend on the Act, the Rules, the Taxation Administration Act, and other administrative law provisions. The instrument’s silence on sanctions makes it necessary to consult those other instruments to understand the full legal exposure for non‑compliance or misstatement.
• Procedural interaction with authorised agents and recordkeeping: the instrument places an express duty on authorised agents to obtain a written declaration from the entity before lodging (s 8(4)(b)). That interacts with broader obligations agents have under taxation law and professional regulatory standards governing documentation and client instructions.

Operationally the instrument delegates much of the substantive legal architecture to other instruments and statutes while prescribing technical reporting mechanics. Employers must therefore consider the instrument together with the Rules, the Act, and the Taxation Administration Act to understand the full legal and administrative context in which a JobMaker claim sits. The instrument is not standalone; it is a compliance overlay that depends on, and references, existing reporting systems and administrative regimes.

The compilation includes the original instrument and an amendment made in 2021. The document's endnotes provide the formal amendment and compilation record.

• Original registration and commencement: the JobMaker Hiring Credit Reporting Obligations Instrument 2020 was registered on 4 December 2020 (F2020L01535) and commenced on 4 December 2020 (endnote 3).
• Amendment instrument: JobMaker Hiring Credit Reporting Obligations Amendment Instrument 2021 (F2021L00466) is included in the compilation up to 21 April 2021 (compilation date) and the amendment instrument itself has a registration and commencement date recorded as 21 April 2021 (endnote 3).
• Compilation details: the instrument in this compilation includes amendments up to the 2021 amendment instrument and the compilation number is 1, compilation date 21 April 2021 (cover page and endnotes).
• Amendment-level annotation: endnote 4 lists that provisions affected include s 2, s 5, s 7, s 8, and s 10, indicating these provisions were amended by the 2021 instrument (endnote 4 table). The endnote does not set out the textual history beyond indicating which provisions were amended; the compilation text reflects the instrument as amended to the compilation date.
• Uncommenced amendments and modifications: the instrument’s front matter warns that uncommenced amendments are not reflected in the compiled text and modifications are not shown in compiled text where another law modifies the instrument (prefatory notes). It indicates that any uncommenced amendments up to the compilation date are underlined in the endnotes and that the series page on the Federal Register of Legislation provides further details (prefatory notes).

What the amendment history concretely signals for practitioners

• The instrument has already been amended at least once within months of first registration. The endnote identification of specific provisions amended (s 2, s 5, s 7, s 8, s 10) means that those provisions have had textual change between the original instrument and the 2021 amendment. For precise drafting differences practitioners should consult the amending instrument (F2021L00466) and the Federal Register of Legislation series page for full amendment text and any associated commencement or transitional provisions.
• The compilation date of 21 April 2021 means the version of the instrument in this deep dive includes changes effected by the 2021 amendment up to that date. Any changes registered after that date or uncommenced amendments are not reflected in the compiled text and must be checked separately.
• The instrument’s own notes caution about uncommenced amendments and modification-by-other-laws not shown in the compiled text. Practitioners should therefore verify the current status of the instrument and any amendments or modifications on the Federal Register of Legislation before advising clients or relying on the instrument’s text.

In practice, the amendment history shows that the instrument was subject to early post-enactment modification, which is not uncommon for instruments that operate with rapidly evolving administrative arrangements. The compilation indicates which sections were amended but not the precise nature of each change; for that, the amending instrument text and the register entry should be examined.

The compilation and the instrument itself do not record any case law or litigation history. The instrument names no cases and the endnotes contain no reference to judicial decisions or challenges. The instrument’s endnotes focus on registration and amendment history only (endnotes 3 and 4).

What this means practically

• There is no litigation precedent arising from this instrument recorded in the instrument’s own compilation. Practitioners cannot rely on any judicial interpretation of the instrument from the document itself because none is provided.
• Any disputes about the instrument’s application, the Commissioner’s exercise of discretion under s 7(2A), or the administrative processes for accepting or rejecting claims would currently (based solely on this source) be decided against the broader statutory and administrative law framework rather than on any prior construing of this instrument by courts.
• Because the instrument interacts with the Rules, the Act, and taxation reporting obligations under the Taxation Administration Act, litigation touching on JobMaker claims may arise in multiple legal contexts. However, none of those possible proceedings are reported in this instrument’s compilation.

Recommended practice given the absence of litigation history

• Where there is statutory ambiguity or where Commissioner discretion under s 7(2A) is exercised, employers and agents should preserve evidence of communications with the Commissioner and document why a given STP software constraint exists. Recordkeeping will be useful in any administrative review or tribunal proceeding even though none has been recorded here.
• If a contentious decision is made by the Commissioner about whether the employer satisfied the instrument’s requirements, the appropriate avenues for review will lie in the Act, the Rules, the Taxation Administration Act, or general administrative law, not in this instrument. Practitioners should identify relevant appeal or review pathways in those instruments when advising clients.

In short, the instrument contains no litigation history in its endnotes or text. Any legal challenges or interpretive litigation must be sought in external databases or in subsequent legal developments not recorded in this compilation.

The instrument contains several provisions that create operational risks, timing traps, or hidden compliance costs. Below are practical "gotchas" drawn directly from the instrument’s text.

1. Two distinct timetables: STP JobMaker Reporting Deadline vs claim period (s 7(1) table; s 10(1) table)

   • Employers must meet STP reporting deadlines for employee-level data by specified STP JobMaker Reporting Deadlines for each jobmaker period (s 7(1) table). Separate from that, employers must lodge claim information during the claim period corresponding to the jobmaker period (s 10(1) table). Missing the STP deadline may affect the Commissioner’s ability to accept employee-level data prior to the claim window. Administrative timing is therefore two-stage and misalignment can cause non-compliance.

2. Immutable claim data after the claim period (s 10(2))

   • Claim information submitted through the online channels cannot be amended after the claim period ends, except for bank account details (s 10(2) and s 8(2)(h)). Mistakes or omissions discovered after the claim period may be hard to correct and could affect payment entitlements or trigger later recovery processes handled under other instruments.

3. Dependence on payroll software capability and Commissioner satisfaction (s 7(2A)-(2B))

   • If payroll software cannot transmit all required STP fields, the Commissioner may accept only TFN and full name via STP for that jobmaker period (s 7(2A)-(2B)). That comfort requires the Commissioner’s satisfaction, which is discretionary. Employers relying on legacy payroll systems face uncertainty and should secure documentary proof from their software provider or otherwise engage the Commissioner early.

4. Exempt employers face a two-year prior-notification requirement to use phone lodgement (s 7(3)-(4), s 9(2))

   • Employers exempt under s 389‑10(3) Schedule 1 TAA 1953 may lodge by phone, but only if they have previously notified all amounts required under s 16‑150 Schedule 1 TAA 1953 in the two years ending on the jobmaker period’s last day (s 7(3)-(4)). The requirement that notification must have occurred before providing claim information places a chronological constraint on lower-technology employers.

5. Agent obligations and declarations impose documentary burdens (s 8(4)(b))

   • Agents must have a written declaration from the entity confirming the truth and correctness of the information if lodging on behalf of a client (s 8(4)(b)). Agents must therefore secure written client confirmations before lodging to avoid non‑compliance.

6. Signature/authentication setup costs and procedural dependencies (s 8(5))

   • Accepted signature methods include myGovID with Relationship Authorisation Manager and myGov credentials, both of which require setup and verification steps. Organisations must ensure authorised persons have appropriate credentials and relationships set up in the RA Manager to use the myGovID option.

7. Partial data submission route creates extra work at claim time (s 7(2A)-(3), s 8(3), (3A))

   • Where STP cannot accommodate all fields, the instrument moves the remainder of required per-employee details to the claim submission process (s 8(3), (3A)). That shifts data collection from real-time payroll reporting to periodic claims, creating heavier work at lodgement time and potential for mismatches between payroll records and claim data.

8. Bank account details treated differently (s 8(2)(h); s 10(2))

   • Bank account details are required as part of the claim information but are explicitly carved out from the immutability rule (s 8(2)(h); s 10(2) exception). That means late changes to account details are allowed while other claim fields are fixed. Employers should be mindful which fields can be corrected and maintain records of any post-claim period changes.

9. No explicit penalty provisions in the instrument

   • The instrument does not specify consequences for false statements or late reporting. This creates uncertainty about enforcement processes and means employers must consult the Act, Rules, and taxation laws to understand consequences for misstatements or non‑compliance.

10. Narrow declaration wording required (s 8(4))

    • The instrument prescribes exact declaration text that must be used by employers and authorised agents (s 8(4)). Deviation from the exact wording may delay acceptance of the claim or raise questions about authorisation.

11. Commissioner satisfaction is a single point of administrative discretion (s 7(2A))

    • Because the Commissioner decides whether the STP software limitation applies, employers cannot unilaterally determine that they are excused from providing full STP data. Early engagement and documentation showing the software limitation will be important to obtain the Commissioner’s satisfaction.

12. The instrument relies on external identity-verification policies

    • Phone lodgements rely on 'Proof of record ownership' procedures prepared under the CEI Identity Management Policy (s 8(5) table). Employers using the phone route should familiarise themselves with these identity procedures as they stand with the ATO.

Each of these "gotchas" increases the administrative risk for employers and their agents. Practitioners should build checklists that map STP deadlines against claim periods, confirm payroll software capabilities well before the STP JobMaker Reporting Deadline, obtain written client declarations, and ensure authorised signatories have the required digital credentials in place.

This section sets out practical, source‑grounded steps an employer or authorised agent should follow to comply with the instrument’s requirements. The steps track the instrument’s mechanics and deadlines.

1. Determine whether the instrument applies to you (s 3-4)

   • Confirm that the jobmaker periods for which you propose to claim commence on or after 7 October 2020 (s 3).
   • Confirm you are an employer participating or seeking to participate in the jobmaker scheme, as the instrument applies to such employers (s 4).

2. Map the relevant jobmaker period to its STP JobMaker Reporting Deadline and claim period (s 7(1) table; s 10(1) table)

   • For each jobmaker period you intend to claim, identify the STP JobMaker Reporting Deadline (s 7(1) table) and the claim period during which you must submit the claim information (s 10(1) table).
   • Build a calendar that treats the STP reporting deadline and the claim period as distinct obligations.

3. Ensure STP reporting where required (s 7(1)-(2))

   • If your organisation is required to notify amounts under s 389‑5 Schedule 1 TAA 1953, confirm your STP feed includes the fields required by s 7(2): TFN, date of birth, full name, date employment commenced (if in the jobmaker period), date employment ceased (if in the jobmaker period), and whether the employee met the average hours requirement.
   • Make the STP submissions in time for the STP JobMaker Reporting Deadline for the relevant jobmaker period.

4. If payroll software cannot supply required STP fields, engage with the Commissioner early (s 7(2A)-(2B))

   • If your payroll software cannot transmit some of the required STP fields, gather evidence from the software provider that the software cannot be updated. Early contact with the Commissioner to seek satisfaction under s 7(2A) is advisable because only the Commissioner’s satisfaction will relieve you of the full STP field requirement.
   • If the Commissioner is satisfied, you are only required to notify TFN and full name via STP for that jobmaker period and any subsequent jobmaker periods (s 7(2A)-(2B)). However, you will still need to supply the remaining per-employee information as part of the claim submission (s 8(3) and (3A)).

5. For employers exempt from STP reporting, ensure the two-year prior-notification precondition is met for phone lodgement (s 7(3)-(4), s 9(2))

   • If you are exempt under s 389‑10(3) Schedule 1 TAA 1953 and intend to use the phone lodgement route, confirm that you have notified all amounts required under s 16‑150 Schedule 1 TAA 1953 in the two years that end on the last day of the jobmaker period (s 7(3)-(4)).
   • Ensure all required STP or s 16‑150 notifications were made before providing claim information.

6. Prepare the claim information package and declare accuracy (s 8(2)-(5))

   • For each jobmaker period, assemble the claim information required by s 8(2): total payroll expenses, baseline payroll amount, total headcount at period end, baseline headcount, confirmation that each employee claimed is an eligible additional employee, the prescribed declaration wording, the required signature, and the employer’s bank account details.
   • If you lodge by phone or are affected by STP software limitations, also prepare per-employee details required by s 8(3) and (3A): TFN, date of birth, full name, start/finish dates if in the jobmaker period, and whether the employee met the average hours test.
   • Use the exact declaration text prescribed in s 8(4) depending on whether you are lodging as the employer or as an authorised agent. If lodged by an agent, obtain and retain the written declaration from the entity confirming the truth of the information (s 8(4)(b)).

7. Ensure authorised signatory authentication is in place (s 8(5))

   • Confirm authorised signatories have one of the accepted signature authentication methods: myGovID plus Relationship Authorisation Manager verification; myGov identity credentials for ATO Online Services; or, for phone lodgements, identity verification in accordance with the CEI Identity Management Policy (s 8(5) and signature table).
   • If using myGovID with RA Manager, ensure the entity relationship is established so the digital signature will be accepted by the ATO.

8. Lodge via the prescribed channels during the claim period (s 9(1)-(2))

   • Lodge the claim information via ATO Online Services for Individuals, ATO Online Services for Business, Online Services for Agents, or the Business Portal during the claim period corresponding to the jobmaker period (s 9(1); s 10(1) table).
   • Exempt employers who meet the prior-notification requirement may lodge by phone (s 9(2)).

9. Recordkeeping and documentary evidence

   • Retain evidence supporting the submitted claim information (payroll records, headcount records, written employee declarations where applicable, agent client declarations, correspondence with software providers, and any communications with the Commissioner regarding STP software limitations).
   • While the instrument does not specify record-retention periods, the need to substantiate claims and the immutability of lodged data (s 10(2)) make retaining contemporaneous records a practical necessity.

10. Post-lodgement monitoring and correction

• Be aware that, apart from bank account details (s 8(2)(h)), claim information submitted during the claim period cannot be changed after the claim period ends (s 10(2)). Therefore, verify all fields carefully before submission.
• If you discover a pre-claim-period omission, consider whether you can correct it before the claim period closes or whether you should contact the Commissioner to disclose and seek guidance.

11. Engage advisors early

• Where uncertainty exists about the Commissioner’s likely approach to STP software limitations, agent declarations, or the sufficiency of evidence for eligible additional employees, engage tax advisers or legal counsel to ensure claims are documented consistent with s 8 requirements.

These steps follow directly from the instrument’s text. The central compliance principle is to treat the instrument as a prescriptive checklist that must be completed in the specific windows set by the STP JobMaker Reporting Deadlines and the claim periods, to secure the procedural element of eligibility under the Rules (s 6).