The clock should start when the invoice arrives

To the Cashflow Council,

I support CF-001. I ask you to amend it before it goes to ballot. Fifteen days is a useful promise, but a promise needs a clock that both sides can read and a practical way to stop the clock being pushed back.

On 2 February this year, I sent an invoice for A$8,640 to a large buyer. The work had been completed and accepted. Our agreed payment term was 30 days, so the invoice was due on 4 March. There was no disagreement about the work or the amount. The invoice went through the buyer’s online portal, which showed it as received.

On 6 March I asked when payment would be made. I was told it was “in process.” On 16 March I followed up again. This time I was asked to upload the invoice once more because it could not be located in the payment system. I did that the same day. On 30 March I asked for a firm payment date. I received no date, only another assurance that the invoice was being handled. The money arrived on 20 April: 47 days after the agreed due date.

The delay was not a catastrophe, but it was not harmless. I had to manage the gap between money already spent to complete the work and money that should have arrived weeks earlier. I moved funds I had set aside for other expenses and delayed paying myself. The buyer did not have to explain the cost of that delay; I did.

I tried the ordinary steps first: checking the portal, resending the invoice, writing reminders and asking for a payment date. I considered seeking help through the Australian Small Business and Family Enterprise Ombudsman’s dispute-support route, but a small unpaid invoice can demand more time and attention to pursue than a small business can spare. I also had no agreed late-interest term in this contract. Australia does not give every small supplier a universal 15-day statutory payment deadline or automatic interest right for every private-sector invoice. The Payment Times Reporting Scheme makes payment practices more visible for covered large businesses and

government enterprises, but reporting is not the same as a right to be paid promptly on this invoice.

What I ask you to amend

Please make the start of the 15-day period objective. It should run from the buyer’s receipt of an invoice that meets the agreed, published invoicing requirements—not from the date a buyer later chooses to approve it in an internal system. A portal outage, a lost upload or an internal hand-off should not quietly restart the clock.

Give buyers a short, defined time to raise a genuine dispute. For instance, require a written notice within five calendar days that identifies the particular amount and reason in dispute. If the buyer disputes one line, the undisputed balance should still be paid within 15 days. A vague “query,” a request to upload the same document again, or silence should not turn an undisputed invoice into a disputed one.

Make the records simple enough for a small supplier to use. The buyer should provide a receipt date, a named or trackable contact for invoice queries, and a payment date. If an invoice is rejected, the buyer should give the reason promptly and specifically. When it is corrected, the clock should resume from the original receipt date unless the correction changes the amount or essential information needed to verify the claim. That distinction prevents clerical friction from becoming a free extension of credit.

I also support automatic interest when payment is late, but the standard should say exactly how it is calculated and when it begins. I suggest interest accruing from day 16 on the overdue amount, at the Reserve Bank of Australia cash rate plus eight percentage points, or another clearly stated rate adopted by the Assembly. It should not depend on the supplier sending a second invoice or making a separate demand. The buyer should show the interest calculation with the payment. That gives both sides a predictable rule without pretending that an Australian supplier already has this particular entitlement under general law.

Finally, publish results in a form that makes performance comparable without asking small suppliers to do the reporting. A buyer could report the share of undisputed small-supplier invoices paid within 15 days, the median payment time, and the share paid late. Publish the reporting period, define what counts as a small supplier, and explain any

exclusions. A single average can hide the experience of suppliers whose invoices sit unpaid for a long time.

These are amendments to make the standard workable, not reasons to weaken it. A buyer can set up a receipt timestamp, a short dispute window and a basic payment-time report. A small supplier should not have to become an investigator to find out whether an invoice has arrived or why it has not been paid.