The APES 225 valuation report checklist.
What a compliant valuation report must contain under APES 225 — for accountants and lawyers vetting a report before relying on it, and for owners commissioning one.
APES 225 Valuation Services is the professional standard binding CA ANZ, CPA Australia and IPA members who provide valuation services. A compliant report must disclose the engagement type (valuation, limited scope valuation or calculation), the standard and premise of value, the methods considered and rejected, key assumptions, scope limitations and reliance restrictions. Checking each of these disclosures lets accountants and lawyers vet a valuation report before relying on it.
Why this checklist matters before you rely on any valuation
APES 225 Valuation Services is the professional standard issued by the Accounting Professional & Ethical Standards Board (APESB) governing how members of CA ANZ, CPA Australia and the IPA perform and report valuation engagements. It does not tell a valuer what number to reach — it tells them what the report must disclose so a reader can see how the number was reached. That makes it the closest thing Australia has to a universal content standard for valuation reports. Whenever a valuation supports a position someone else may test — a small business CGT concession claim under Div 152, a market value substitution under s 116-30, a Subdiv 328-G restructure, a Division 7A transaction, a family law settlement or a shareholder exit — the report should pass this checklist before anyone relies on it. A report that cannot is harder to defend if the ATO or a court reviews the position.
The three engagement types — and what each must disclose
APES 225 recognises three types of valuation service, and the report must state which one it is. A Valuation Engagement gives the valuer freedom to select the approaches, methods and procedures appropriate to the circumstances, and expresses a Conclusion of Value. A Limited Scope Valuation Engagement restricts that freedom — the scope is limited by the client or the circumstances — and the report must disclose the limitation and that the conclusion might have differed without it. A Calculation Engagement applies methods and procedures agreed with the client and reports a Calculated Value: the report must make clear that this is not a conclusion of value and may have been different under a full valuation engagement. The distinction is not academic. In practice, many low-cost valuations are calculation engagements that never say so — which is itself a compliance failure, and a fair reason to question what else is missing.
The clause-by-clause report content checklist
Work through the report you have been handed. A compliant valuation report discloses every item below — where any are missing, ask why before relying on it.
- ·A statement that the report was prepared in accordance with APES 225, and the engagement type — valuation, limited scope valuation or calculation
- ·The party who engaged the valuer, and the purpose the report may be used for
- ·The business, entity, securities or asset being valued, and the valuation date
- ·The standard of value adopted — for tax matters, market value consistent with IVS 104 and the Spencer willing-but-not-anxious principle — and its definition
- ·The premise of value (typically going concern or orderly realisation) and why it applies
- ·The approaches and methods considered, the method or methods selected, and the reasoning for selecting them and for rejecting the alternatives
- ·The information and sources relied upon, and the extent to which they were verified
- ·Key assumptions, including any special assumptions, stated specifically enough to be tested
- ·Scope limitations and their effect on the conclusion
- ·Reliance restrictions — who may rely on the report and for what purpose
- ·The conclusion of value or calculated value, clearly identified as one or the other
- ·An independence disclosure and the qualifications of the person responsible for the valuation
- ·The date of the report and the signature of the valuer
Red flags that the report in front of you is non-compliant
- ·No engagement type stated anywhere — the most common failure, and it means you cannot tell whether you are holding a valuation or a calculation
- ·A single figure with no supportable range, no discussion of methods considered, and no reasoning for rejecting alternatives
- ·No standard or premise of value — the report asserts a value without defining what kind of value it is
- ·Assumptions missing, or stated so generically they could apply to any business
- ·No independence statement, or a fee arrangement contingent on the value concluded
- ·Template language with the client's name inserted — no evidence or analysis specific to the entity
- ·Silence on who may rely on the report — a compliant report restricts reliance; one that does not was usually not written with review in mind
Who APES 225 binds — and what it means when your valuer is not a member
APES 225 is mandatory for members of CA ANZ, CPA Australia and the IPA who provide valuation services in public practice. A valuer who is not a member of one of those bodies is not bound by it — departing from the standard is not a professional breach for them. That does not make the checklist irrelevant. The ATO's market valuation guidance and the courts assess whether a valuation is supportable regardless of who prepared it, and the APES 225 report content requirements are the best practical proxy for what a supportable report should disclose. If a non-member's report cannot pass the checklist, the question is not technical compliance — it is whether the report can defend the position at all. One boundary worth stating plainly: Prismi prepares independent valuations only. We are not a registered tax agent and do not provide tax or legal advice; how the valuation is applied to a tax or legal position is a matter for your accountant or lawyer.
How a Prismi report maps to every checklist item
Prismi reports are structured so the checklist can be worked through on the face of the document. The engagement type is stated in the opening pages. The standard of value (market value, consistent with IVS 104) and the premise of value are defined before any analysis begins. The methodology section documents the methods considered, the methods selected and the reasoning for rejecting alternatives — the same reasoning that identifies the most supportable position within the supportable range. Assumptions, scope limitations and reliance restrictions each have a dedicated section. Every report carries an independence statement and is signed by a senior reviewer with named qualifications, the working file is retained for ten years, and fees are fixed at engagement — never contingent on the outcome. Where a client asks for a report to reach a target value, we will say so and decline the engagement on those terms.
Which engagement tier fits the standard of report you need
Essential (from $1,495 + GST, 10–14 business days) suits straightforward single-entity matters where a concise, compliant report is sufficient. Comprehensive (from $3,995 + GST, 15–25 business days) is the right fit for most tax-purpose engagements — multiple methodologies tested, full checklist depth, and the reasoning documented with ATO market valuation expectations in mind. The Defensible Valuation File (from $8,995 + GST, 25–35 business days) is built for matters where review or dispute is likely and every checklist item needs the deepest evidence trail behind it. Where the question is how the position moves under different scenarios, the Valuation Range & Scenario Review is the premium engagement. Retrospective valuation dates attract a $495 surcharge per historical date, additional entities are $750 each, and urgent matters can be accelerated at +30% of the base fee, subject to capacity.
Common questions.
What does APES 225 require in a valuation report?+
APES 225 requires the report to disclose the engagement type, the party engaging the valuer, the purpose, the entity and valuation date, the standard and premise of value, the methods considered and selected (with reasoning), the information relied upon, key assumptions, scope limitations, reliance restrictions, and the conclusion of value or calculated value. The checklist on this page works through each item.
What is the difference between a valuation engagement and a calculation engagement?+
In a valuation engagement, the valuer selects the methods and procedures appropriate to the circumstances and expresses a conclusion of value. In a calculation engagement, the valuer applies methods agreed with the client and reports a calculated value — expressly not a conclusion of value. A calculation engagement is cheaper but carries materially less weight if the position is reviewed.
Does the ATO require an APES 225 compliant valuation?+
No — the ATO's market valuation guidance is a separate, principles-based framework and does not mandate APES 225. In practice the two overlap heavily: reasoned methodology selection, documented evidence, stated assumptions and disclosed limitations. A report that fails the APES 225 checklist is unlikely to meet the ATO's expectations either.
Is a business valuation valid if the valuer is not a CA or CPA?+
It can be. APES 225 binds only members of CA ANZ, CPA Australia and the IPA — a non-member is not required to comply with it. What the ATO and the courts assess is whether the valuation is supportable: appropriate methodology, documented evidence, reasonable assumptions. The checklist remains a useful vetting proxy regardless of the valuer's memberships.
Can I rely on a calculation engagement for a small business CGT concession claim?+
You can, but it is a weaker foundation. A calculated value is expressly not a conclusion of value, and Div 152 eligibility often turns on market value thresholds that may be tested. Most advisers commission a full valuation engagement for concession claims so the report expresses a conclusion of value with the methodology reasoning behind it. Whether a given report is sufficient for a claim is a question for your accountant.
