Further JobKeeper 2.0 Clarity

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Insights From MCA Accountants

Further JobKeeper 2.0 Clarity

This follows our previous post which can be read at

Further clarification – but still not complete clarification – on the operation of JobKeeper 2.0 was released by the Government on 15 September 2020. Below is a short summary of those, plus what is still unknown.


Administrative Requirements:

  • Employers must notify the ATO in advance which employees and business participants qualify for the higher rate of payment, and which for the lower rate
  • Employers must notify employees and business participants within 7 days of the above
  • If a business participant actively worked more than 80 hours in the month of February 2020, they must sign a declaration and provide it to the business to enable them to claim the higher rate of payment
  • Businesses do not need to re-enroll, but will need to notify the above (it appears the monthly declaration will be altered for this)

80 Hours Worked Test:

  • Employees must have worked 80 hours in the last 4 weekly pay periods / 2 fortnightly pay periods ending before 1 March 2020 OR 1 July 2020 (i.e. choose whichever is higher). We note that this test is based on pay runs, so if a business has fortnightly payroll which ends on 2 March 2020, then the 28 day test period is the prior pay runs (21 January to 17 February)
  • Employees on a monthly (or longer) pay cycle need to use the last pay period ending before 1 March 2020 / 1 July 2020 and pro-rata back to 4 weeks. For a monthly pay run, this may be a calculation of hours worked, divided by 31 days in the month, multiplied by 28 days
  • The ATO has the power to vary the above test if need be
  • Hours worked by employees include paid leave and paid public holidays
  • Business participants must have been active in the business for 80 hours in the month of February only to get the higher rate of payment (business participants cannot test their June hours), and hours on leave or not working public holidays DO NOT count for business participants
  • Existing rules around businesses that have changed hands means employees can test their hours with the previous owner

Turnover Test:

  • The turnover test for JobKeeper 2.0 (October to December 2020) is an actual drop of 30% in turnover for the July to September 2020 quarter when compared to July to September 2019 (we note that businesses with turnover of $1bn need to satisfy a 50% drop, and ACNC registered charities only need a 15% drop – as per JobKeeper 1.0)
  • The turnover test for JobKeeper 3.0 (January to March 2021) is an actual drop of 30% in turnover for the October to December 2020 quarter when compared to October to December 2019 (again, same adjustement for large businesses and charities)
  • Businesses can access JobKeeper 2.0 or 3.0 even if they did not receive JobKeeper 1.0 (March to September 2020)
  • The ATO has the power to grant businesses additional time to enrol in JobKeeper 2.0 and 3.0 (if they were not receiving JobKeeper 1.0), and also to grant businesses additional time to top up employees (e.g. should the business not know if it met the actual decline in turnover test until later in October when the BAS is completed)

Still Unknown

We are still waiting on the following:

  • The ATO have indicated that businesses cannot choose to use the “cash” or “accrual” basis for measuring turnover and should use the method used for their BAS’s – but this has not been confirmed
  • Whether the existing alternative turnover tests (e.g. for rapidly growing businesses or those that don’t have a comparative period) will continue – either in their current form or at all. We suspect modified tests will be provided soon
  • Whether the ATO will actually grant businesses any administrative concessions (e.g. given JobKeeper 2.0 is based on actual turnover, many businesses will not know for certain if they qualify by the time they need to process their first payrun in the JobKeeper 2.0 period) – but we suspect they will
  • The actual process to claim JobKeeper 2.0 / 3.0 – we suspect the ATO will use the existing process and alter the monthly reporting forms
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