New ATO SBSCH BACKGROUND
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- Jack Gibson
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1 Australian Taxation Office as at 7 August 2017
2 New ATO SBSCH BACKGROUND In late 2016, as part of a Machinery of Government change, staff within the SBSCH program transferred from the Department of Human Services (DHS) to the Australian Taxation Office (ATO). The current SBSCH system resides within DHS and ATO SBSCH program staff access it via a DHS CITRIX solution. The ATO is progressing the design and build of its own SBSCH system scheduled for implementation in January The move provides an opportunity to improve the service and integrate with current ATO systems, leveraging off existing functionality. There will be a short period in December where registrations and contributions will not be possible due to the migration of existing data and scheduled system deployment. All external access to the current system will cease, around the 16 th December From January 2018 it is expected that gateways will use the ATO ABN.
3 New ATO SBSCH (cont) KEY DATES Formal notification to industry via the Gateway Operator s Meeting 20 July 2017 ATO preparation for gateway testing July to September 2017 Gateway testing September to December 2017 External access ceases 16 December 2017 ATO internal processing only December 2017 New SBSCH system accessible - early January 2018 Finalise BDV testing (including end-to-end testing) mid-january 2018 *The DHS SBSCH will continue to receive response messaging for any registrations/contributions made in that system until 31 March 2018.
4 New ATO SBSCH (cont) STAKEHOLDERS All employers currently using the SBSCH Intermediaries acting on behalf of employers APRA regulated funds SMSFs Gateways The Department of Human Services The Australian Taxation Office
5 Fund Impact ACCESS TO PAYMENT REPORTS Super funds will no longer have access to the SBSCH. Any APRA fund wishing to access reports/download statements will be encouraged to use their Superstream data elements to reconcile their payments moving forward. Any SMSF wishing to access reports/download statements will be encouraged to register with an ESA and use the data element reports provided to that service to reconcile their payments.
6 Fund Impact Access to SBSCH ACCESS TO SBSCH SYSTEM The SBSCH will be taken offline on 16 December 2017 to allow for conversion of data into the new system. We will begin communicating this to users in September 2017, to allow them to prepare accordingly. We will also use data to identify monthly lodgers, particularly those who have an obligation to lodge in December, to ensure they are aware of the truncated access window in December. Funds who require employers to lodge in December may be contacted during this period if they miss the 16 December deadline.
7 Fund Impact Employer onboarding strategy The bulk of existing users will need to access the new SBSCH via the Portals. This will require them to register for an AUSkey. We acknowledge current user sentiment around AUSkey and are expecting some employers to resist the change. We have a comprehensive onboarding strategy for employers but anticipate the following scenarios may have a downstream impact on funds: Employer is unwilling to register for an AUSkey and they contact their funds to find an alternative solution. Employer tries to access the SBSCH after shutdown and they contact their funds directly to make a contribution. Employer is contacted directly by ATO about transitioning to AUSkey and they are given alternative, SuperStream compliant channels through which they can meet their obligations. This could involve contacting their fund.
8 Fund Impact - SuperStream As part of the Small Business Super Clearing House (SBSCH) migration from DHS to ATO there will be some changes in how and where to transmit messages. Proposed changes in the ebms3 solution are: Connectivity between Gateways and SBSCH Messages sent from SBSCH to Gateways Messages sent from Gateways to SBSCH The ATO s ABN will be used as the message sender in the payload and as the FROM PartyID in the ebms header. Therefore the ATO ABN needs to be used in TO PartyID in the response. These changes need to be to assess by funds to understand their impact.
9 Connectivity to SBSCH Before Message exchanged between Superstream Gateways and SBSCH via established DHS SSL connections After Message exchanged between Superstream Gateways and SBSCH via established ATO SSL connections Currently all Superstream Gateways have established connections with ATO SBR ebms3 so will have to start using those connections to send/receive SBSCH messages.
10 Messages sent from SBSCH to gateways Before Member Registration Request (MRR) and Contribution Transaction Request (CTR) messages were signed by DHS credential After Member Registration Request (MRR) and Contribution Transaction Request (CTR) messages will be signed by ATO credential As the SBSCH ownership is changing from DHS to ATO, the ATO Outbound messages will be signed using an ATO credential. Gateways might need to update their authentication/authorisation solutions within their systems to allow those messages to be received from the ATO.
11 Messages sent from gateways to SBSCH Before Superstream Gateways sent messages to DHS via established DHS SSL connections using the DHS URL. After Messages will need to be sent by Superstream Gateways via established ATO SSL connections to an ATO URL Outbound messages from the Gateways will need to be sent to the ATO SBR ebms3 endpoints instead of DHS endpoints.
12 Gateway Impact - Testing The ATO s intention is to perform end-to-end testing including willing employers to ensure the transition to the new SBSCH system is seamless. The ATO will provide an External Vendor Testing Environment (EVTE) to the superannuation industry to allow Gateways, Intermediaries and Funds to undertake interoperability and ATO to Fund or Peer to Peer testing prior to the release. There are three phases of testing that will be conducted between September and December 2017: Integration Testing between APRA funds and their solutions providers Interoperability Testing between the gateway operators and ATO and Peer to Peer Testing between funds and the ATO. NB: Responsibility for scheduling integration testing rests with the funds and MUST be completed before ATO/Fund or Peer to Peer testing can commence. Principles The artefacts to support Contributions v1 Testing suite including the conformance test guide, sample message instances etc. will be made available on the software developers website.
13 Gateway Impact - Testing GENERAL Test scenarios and test data to be used during Peer to Peer testing or ATO to fund testing, will be provided. Funds are responsible for ensuring that this test data is configured into their test environments and personnel are ready to commence P2P testing with the ATO. Funds are required to confirm ABN/USI details to be used during testing. ATO will schedule funds for testing based on the readiness notification dates provided and also based on the type of registry system in use.
14 Decommissioning the DHS SBSCH While the DHS SBSCH will be taken offline for all external users on 16 December 2017, the back-end part of the system, including the messaging, will remain in operation for a period of time after this. Specifically, the messaging system will still need to be able to receive MRORs and CTERs for at least 55 days after the last MRR/CTR is sent. We encourage funds to quickly process any returns, within the data standards, so the system can be eventually decommissioned.
15 QUESTIONS?
16 Contacts Tania McFaul, SBSCH Transition Project Lead (07) Danielle White, SBSCH Transition Project Manager and BAU Owner (08) Danny Parker, Small Business Superannuation Clearing House (02)
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