888 Business Innovation Evidence: BAS, Turnover and Net Assets (2026)

For the Business Innovation stream of the Business Innovation and Investment (Permanent) visa (subclass 888), the financial tests in clause 888.225 of the Migration Regulations 1994 are proved over a single 12-month window, using two dated snapshots of the business rather than one year-end figure. This article works from the Department of Home Affairs page for the Business Innovation and Investment (Permanent) visa (subclass 888) and the Migration Regulations 1994 as published on the Federal Register of Legislation, together with the Department's PAM3 procedures guidance on how those clauses are assessed; thresholds and documentary requirements change, so every amount and form mentioned below should be checked against the current version of the Regulations before you lodge. The practical answer to "what evidence do I need for the 12 months" is therefore three bundled things: a start-date and end-date net asset position for the main business, a turnover figure rebuilt from the Business Activity Statements that fall inside the same window, and a funds trail showing the assets in those documents were lawfully acquired.

Which 12 months am I actually proving?

The financial criteria are not assessed over a financial year. PAM3 guidance records that the 12-month period for turnover (clause 888.225(5)) need not run from 1 July to 30 June, and the same window drives the asset and employment limbs, so you choose it first and then build everything else around it.

Pick the window deliberately, because it does three things at once. It fixes the two dates for your asset snapshots. It determines which BAS quarters or months feed the turnover figure. And the turnover figure it produces also determines which ownership percentage you needed to hold in the main business over the preceding 24 months: 51% where annual turnover is below AUD 400,000, 30% where turnover is at least AUD 400,000, and 10% for a publicly listed company.

What does the net asset snapshot actually contain?

The AUD 300,000 net business assets limb counts assets held in the main business only. It is a net figure, so liabilities come out: a business with AUD 500,000 of equipment and a AUD 250,000 loan secured against it does not clear this limb on the equipment alone.

You need documents showing the position at the beginning of the window and at the end of it, prepared on the same basis, so start-date and end-date pictures can be compared rather than reconciled by the decision-maker:

a balance sheet dated at each end of the window, using consistent valuation assumptions;
a statement of assets and liabilities (SALP) for the same two dates;
business bank statements covering the whole window, so cash movements between the two snapshots can be followed;
stock or inventory counts where stock forms a large part of the net position;
loan agreements, hire-purchase contracts and lender balance confirmations supporting every liability deducted.

Where separate asset valuations are used, each one should carry its own date and its own basis. An undated valuation placed next to a dated balance sheet invites a request for more information rather than answering one.

How is turnover rebuilt from BAS figures?

Turnover for clause 888.225(5) is taken from the sales figures in the BAS that fall inside the chosen 12 months. Where those sales figures include GST, PAM3 guidance applies a 10% reduction to arrive at the turnover figure, so the GST-inclusive total in the BAS is not itself the number you put forward.

Turnover then carries a second role that applicants often miss. Clause 888.225(1) requires at least two of the three limbs in subclauses (2) to (4) to be met and the turnover requirement in subclause (5) to be met, so turnover is not simply one alternative out of three — it sits alongside whatever pair you choose. Check the current Regulations for the turnover amount that applies to your application, and treat that figure as independent of the AUD 400,000 line used only for the ownership tier.

Build a one-page reconciliation showing each BAS in the window, the amount reported, whether GST was included, and the running total. Get the same turnover figure to agree with the financial statements and the business income tax return; three documents telling three different stories is what turns a straightforward file into a request for further evidence.

What counts for each of the three financial tests?

Test	Threshold recorded in PAM3 guidance	Where the number comes from	Where files commonly fail
Net business assets (888.225(2))	AUD 300,000 or more	Assets in the main business only, net of liabilities, evidenced at both ends of the window	Counting assets held outside the business, or leaving liabilities off the schedule
Employment (888.225(3))	At least 2 full-time employees	Continuous employment over the 12 months before application; employees must be Australian citizens, permanent residents or New Zealand citizens, and must not be you or your family members	Counting contractors, casual staff averaged across the year, or family members
Total net personal and business assets (888.225(4))	AUD 900,000 or more	The main business snapshots plus personal assets, which may include assets of other businesses you own	Valuations without dates, or a display of wealth with no trail showing how it arose

The same three denial grounds appear repeatedly in the PAM3 refusal list: ownership not held continuously for the 24 months at the required percentage, the two-out-of-three test not met, and turnover below the required amount without an exceptional circumstances finding.

How do I show the assets were lawfully acquired?

Both asset limbs carry a requirement that the assets were lawfully acquired, and where that is not clear from the documents the case officer may ask for more information before deciding. Lawfulness is shown with a money path, not with a single certificate.

Order the trail chronologically. Start with the funds arriving: bank statements showing the source and the date. Move to the acquisition itself: contract, invoice, settlement statement or share transfer. Finish with valuation support for anything carried into the snapshot at a revalued amount. Where a step in that path is thin — cash introduced over several years, a related-party transfer, a legacy holding — an auditor's report or a legal statement explaining origin and ownership is the kind of independent document that closes the gap.

Take a hypothetical applicant who bought the business four months into the chosen window. The start-date snapshot must already include the acquired assets at their purchase value, and the funds trail must show the purchase money existing and moving before that date. A snapshot taken after the purchase, with no money trail behind it, reads as an unexplained jump in net assets rather than as evidence.

One structural trap sits behind this requirement. Clause 888.222(2) prevents ownership of a main business acquired from another subclass 888 or Business Skills visa applicant from counting, unless you both held at least 30% and did so jointly for at least 12 months. A purchase that looks clean on paper fails outright if the seller was another applicant, so the seller's status belongs in the acquisition file.

What will the officer expect from the BAS themselves?

Clauses 888.223 and 888.224 require the main business to hold an ABN and to have lodged the corresponding BAS, and PAM3 guidance refers to at least two years of BAS being examined. Three checks get applied in practice: the ABN sits in the name of the main business; each BAS was printed after lodgement and shows "Processed"; and the BAS totals line up with the financial statements.

If the originals have already gone to the Australian Taxation Office, a printed copy showing "Processed" is used, and an ATO-provided copy on request. If a business claims it was not required to lodge a BAS, that claim needs to be backed by an ATO statement rather than by the applicant's own explanation.

Tax compliance does not stop at lodgement. Clause 888.214 requires a satisfactory record of compliance with federal and state laws including tax, superannuation and industrial relations. A late or missed income tax return, unpaid superannuation or an underpayment of wages can undo an otherwise complete asset package; outcomes here depend on the circumstances, and repeat or uncorrected issues are the pattern that attracts refusal.

Assembling the file, step by step

Choose the 12-month window first. Write down the two snapshot dates. Pull the balance sheet and SALP for the start date. Pull the balance sheet and SALP for the end date. List every BAS that falls inside the window. Deduct GST at 10% where the sales figure includes it. Total the adjusted figures. Write the one-page reconciliation. Compare the turnover result against the required amount in the current Regulations. Match the same turnover figure to the ownership percentage tier and confirm the two years of documents behind it. Attach the ownership register, shareholder agreement and board or director resolutions. Attach the funds trail for every significant asset in the snapshots. Finally, list any tax or workplace compliance issue and evidence of how it was fixed.

This is general commentary on published rules rather than advice on any individual case, and since the thresholds here are monetary and date-sensitive, amounts and procedures should be confirmed against the current Regulations and the Department's current page, and discussed with a registered migration professional where the outcome matters.

Frequently Asked Questions

Do I have to use a financial year for the 12-month period?

No. The 12-month period used for the turnover test need not be a financial year, but it must be one continuous 12-month window that you can cover with matching asset snapshots, BAS and payroll records. Mixed periods are what create inconsistencies between documents.

Can personal assets count toward the AUD 900,000 test?

Yes. The AUD 300,000 net business assets limb is confined to assets in the main business, while the AUD 900,000 net personal and business assets limb can include personal assets, including assets of other businesses you own. Both limbs still require the assets to have been lawfully acquired.

Is the GST-inclusive figure on my BAS the turnover figure?

No, not where GST is included. The guidance applies a 10% reduction to GST-inclusive BAS sales figures when calculating turnover. The reduced figure should also reconcile with the financial statements and the income tax return for the business.

What if my business was not required to lodge BAS?

Lodging BAS is tied to clauses 888.223 and 888.224 for a main business with an ABN, and a claim that no BAS was due needs support from the Australian Taxation Office rather than from your own statement. Where a BAS was lodged but you no longer hold the original, a printed copy showing "Processed" can be used.

How do I prove assets were lawfully acquired?

Show the money path: how the funds arose, when they arrived, and what was bought with them, supported by bank statements, contracts or settlement documents and valuations. Where any step is unclear, independent support such as an auditor's report or legal statement helps, because unexplained jumps in the snapshot invite further information requests.

What happens if I cannot meet two of the three tests?

Clause 888.226 allows the nominating State or Territory government agency to determine that exceptional circumstances apply. That determination belongs to the nominating agency, not to the applicant or the Department.