In an online update, the ATO said that in early September this year, it commenced its SAN misuse mailout for the 2019 income year.
“This is now completed and all SMSF auditors should have a list of clients that have reported to us that they were the ones to conduct an audit on the clients’ SMSF,” it said.
“The mailout aims to identify instances of SMSF auditor details being incorrectly reported on the SMSF annual return (SAR), or where the SAR is being lodged prior to audit completion.”
The ATO is encouraging auditors to check their lists carefully and report to the ATO whether their SAN has been misreported on a 2019 SMSF annual return, and whether the audit completion date on record is correct.
“If all the information on your client list is correct, we still encourage you to let us know,” it stated.
The date of completion is a new item that the ATO added to the mailout this year to try and identify instances where trustees and tax agents have lodged returns before the completion of the audit report.
Super Sphere director Belinda Aisbett previously told SMSF Adviser that while it will take time for auditors to check through lists and check all the audit dates, it will help ensure the administrative side of the system is working as it should.
“As soon as we tell the ATO that, yes, that person is on our list, but they said the audit is finished on date X, and we didn’t actually finish it till date Y, that will flag that fund for correspondence from the ATO,” she warned.



The PLS validation on the annual return will come back with an error if there is no audit date (or an audit date after the date the validation procedure is run) in the annual return, so some accountants probably insert a dummy date to validate the return meets ATO specs prior to sending to the auditor, and then forget to change it to the actual audit date prior to lodgement.
It was an interesting exercise, in relation to the reported dates. While I encountered none that were lodged prior to the audit date, I was surprised at how many had an incorrect audit date reported.