Methodology and disclaimer

Authority: Tax Practitioners Board (TPB)

Method: Downloaded the complete TPB Public Register bulk dataset (CC-BY 4.0, 67,485 rows) from data.gov.au and ran case-insensitive substring matches across the Agent, Trading Name (Individual), and Trading Name (Organisation) columns for each vendor's legal entity.

Source: data.gov.au TPB bulk dataset · scripts/verify-tpb-au.py

Authority: HMRC

Method: HMRC's mandatory tax adviser registration regime under Part 7 of Finance Bill 2025-26 takes effect 18 May 2026. No comprehensive public register exists today; every UK row is therefore marked as unverified pending the effective date.

Source: HMRC Part 7 Finance Bill 2025-26 (future effective)

Authority: Bundessteuerberaterkammer

Method: Drove the Bundessteuerberaterkammer Steuerberaterverzeichnis search form and the separate § 3a EU cross-border register via headless Playwright (Python), submitting each vendor's legal entity names and scraping both the zero-hits indicator and the cascading filter dropdown. Verified on both registries.

Source: steuerberaterverzeichnis.berufs-org.de + eu-dienstleister-in-steuersachen.berufs-org.de · scripts/verify-de-steuerberater.py

Authority: Conseil National de l'Ordre des Experts-Comptables (CNOEC)

Method: Queried the official French business registry via recherche-entreprises.api.gouv.fr (SIRENE / INSEE). SIRENE cannot directly confirm inscription on the Tableau of the Ordre des Experts-Comptables, but a company registered under a non-accounting NAF code (e.g. 63.11Z data hosting, 47.91A retail) cannot be providing the regulated expert-comptable service.

Source: recherche-entreprises.api.gouv.fr + annuaire-entreprises.data.gouv.fr

Authority: Japan Federation of Certified Public Tax Accountants' Associations (Nichizeiren)

Method: Legal interpretation of the Zeirishi Act (Act No. 237 of 1951, Article 52). The Zeirishi exam is entirely in Japanese with no foreign-national pathway; no foreign SaaS vendor's own corporate entity can appear on the Nichizeiren registry by design.

Source: Nichizeiren Zeirishi Act (structural barrier)

Authority: Korean Association of Certified Public Tax Accountants (KACPTA)

Method: Legal interpretation of the Certified Tax Accountant Act. The two-stage semusa exam is entirely in Korean with no foreign tax consultant recognition pathway.

Source: KACPTA Certified Tax Accountant Act (structural barrier)

Authority: Canada Revenue Agency (CRA)

Method: CRA EFILE enrollment data is not publicly searchable. The regime requires Canadian residency and in-country filing; every CA row is marked as unverified unless the vendor has a Canadian-resident subsidiary that plausibly satisfies the residency test.

Source: CRA EFILE program (no public registry)

Authority: California Tax Education Council (CTEC)

Method: Legal interpretation of Cal. BPC §22250 (CTEC). CTEC applies only to preparers physically working within California and only to income tax preparation. Sales tax SaaS vendors are exempt regardless of staff location.

Source: California Business and Professions Code §22250

Authority: New York State Department of Taxation and Finance

Method: Queried the NY State Socrata dataset b7jj-bh4g (Registered Tax Return Preparers) for each vendor's legal entity via the full-text $q= operator and a case-insensitive LIKE pattern on business_name_if_listed_on_registration.

Source: data.ny.gov open data API

Authority: Singapore Chartered Tax Professionals (SCTP)

Method: Singapore has no mandatory government licensing regime for tax preparers. SCTP accreditation is voluntary and consent-based.

Source: Singapore Chartered Tax Professionals (voluntary)

Australian law requires anyone preparing or lodging BAS returns (GST, PAYG, FBT) for a fee to be a registered BAS agent or tax agent. Whether a specific SaaS vendor's service model falls within that requirement is a fact-specific judgment.

The TPB public register is maintained under the Tax Agent Services Act 2009. Statutory penalties exist for unregistered provision of tax agent services, but their application to cloud-based calculation and filing platforms depends on the specific contracting structure and remains unsettled in case law.

Mandatory registration from 18 May 2026 under Part 7 of Finance Bill 2025-26. HMRC's policy paper states the requirement applies 'whether UK based or overseas.' Requires UK AML supervision — a significant hurdle for overseas advisers.

Effective date: 2026-05-18

Tax advisory is a reserved activity under the Steuerberatungsgesetz (StBerG). Licensed Steuerberater, Rechtsanwälte, or Wirtschaftsprüfer may provide commercial tax advisory services. Whether a specific SaaS vendor's service model falls within the reserved activity is a fact-specific judgment.

The full Steuerberaterverzeichnis is maintained by the Bundessteuerberaterkammer under § 86b StBerG, with a separate § 3a register for EU-established cross-border temporary service providers. Statutory consequences exist under the StBerG for unauthorized practice, but their application to pure calculation engines versus direct filing services is unsettled and depends on the specific service model.

Registration on the Tableau of the Ordre des Experts-Comptables is required under Ordonnance n° 45-2138 for commercial tax advisory services. Whether a specific SaaS vendor's service model falls within that requirement is a fact-specific judgment.

The public SIRENE registry (annuaire-entreprises.data.gouv.fr) records every French business and its NAF activity code; NAF 69.20Z identifies accounting activities. Tableau inscription is maintained separately by the Ordre des Experts-Comptables. Statutory consequences exist for unauthorized practice of the regulated expert-comptable activity under Ordonnance n° 45-2138, but their application to specific cross-border SaaS vendors depends on contracting structure and the nature of the service provided.

Under the Zeirishi Act (Act No. 237 of 1951), only certified public tax accountants (税理士) may perform tax representation, document preparation, or tax consultation for compensation. No foreign tax accountant recognition pathway exists and the licensing exam is entirely in Japanese.

Because there is no foreign pathway to Zeirishi status, no foreign SaaS vendor's own corporate entity can appear on the Nichizeiren registry. Vendors that support Japanese consumption tax typically route filings through a local licensed Zeirishi; the vendor itself is not the licensed filer. Statutory consequences exist under the Zeirishi Act for unauthorized practice, but whether a given vendor's business model constitutes 'tax representation' for compensation under the Act is a fact-specific judgment.

Under the Certified Tax Accountant Act, semusa (세무사) may file returns for compensation in South Korea. The two-stage national exam is entirely in Korean and no foreign tax consultant recognition pathway exists.

Because there is no foreign pathway to semusa status, no foreign SaaS vendor's own corporate entity can appear on the KACPTA registry. Vendors supporting Korean tax filings typically route through a local semusa partner. Statutory consequences exist under the Certified Tax Accountant Act for unauthorized practice, but their application to SaaS vendors whose role is characterised as calculation or data processing rather than 'tax representation' is a fact-specific judgment.

CRA EFILE program requires Canadian residency: the individual applicant or the person with management and control must be a Canadian resident. Returns must be 'prepared in and filed from Canada.' Subcontracting overseas is explicitly prohibited. No public registry exists.

CTEC applies ONLY to preparers physically working within California. An out-of-state or foreign preparer who prepares California returns remotely does not need CTEC registration. First-offence penalty is $2,500 (waivable if corrected within 90 days). Covers income tax only — no registration requirement for sales tax preparers.

Tax Law §32 registration applies to ANY preparer located anywhere who prepares New York returns for compensation. This extraterritorial reach means foreign SaaS vendors filing NY returns must register. NYTPRIN must appear on every NY return filed. Posting violations reach $10,000 per calendar year.

No mandatory government licensing exists. Anyone can commercially prepare and file tax returns. SCTP offers voluntary accreditation; the ACAP and ASK programmes create de facto gatekeeping for specific IRAS reviews but not for filing generally.