Early insights from the new reporting framework.
Almost a month has passed since reports under the reformed Payment Times Reporting Scheme were due on 30 June. While the full impact of the changes will emerge over time, early trends are already offering valuable signals for big businesses.
An initial glean of new reporting reveals two major changes — the ease of comparing payment practices, and the emergence of new benchmarks tied to payment reliability.
Consolidation Illuminates New Realities
A simple comparison of Australia's two largest supermarkets highlights how much reporting has changed.
Prior to reforms, Coles submitted reports for 9 of the group's 45 entities, while Woolworths reported on just 4 of its 166 entities. The result was significant gaps in reporting and an inability to meaningfully compare the two groups.
Fast forward to the new consolidated reporting, and not only is comparison easy — it is powerful.
Assuming compliant reporting (more on this below), it is easy to identify Coles being ahead of Woolworths in paying small businesses at an enterprise level, with faster payment terms as well as average and median payment times.
Table 1: Payments to small business suppliers for the 6 months ending 31 December 2024
| Reporting measure | Coles Group Ltd | Woolworths Group Ltd |
|---|---|---|
| Range of payment terms | 7–30 days | 30–90 days |
| Most common payment term | 30 days | 30 days |
| Payments made on time | 95.5% | 91.4% |
| Average payment time | 22.53 days | 29.79 days |
| Median payment time | 19 days | 24 days |
| 80% of payments made within | 28 days | 44 days |
| 95% of payments made within | 30 days | 69 days |
Source: Payment Times Reporting Register (as of 22 July 2025)
This ease of comparison marks a new phase for the scheme — one with clearer insights and greater analytical reach.
Some large businesses once comfortable operating as outliers, obscured within fragmented datasets that split large groups into individual reporting subsidiaries, may find the spotlight beginning to shine on them a little brighter.
New Benchmarks and a Clearer Picture
Large businesses should pay close attention to new reporting measures gaining traction. Historically, the focus of the Payment Times Reporting Regulator centred on payment terms and payment time intervals (e.g. 30 days, 45 days, 60+ days). But with new reported data, payment reliability will likely be a more dominant benchmark.
The limitations of earlier payment times data were identified by Dr Emerson in his 2023 review of the scheme, which described the information as confusing, clunky and cluttered, noting that it failed to provide basic insights such as average payment times and instances of late payment.
This is no longer the case.
Not only does new reporting include average times and late payments, but a much clearer picture on payment reliability with percentile measures indicating how long it takes to make 80% and 95% of payments to small business suppliers.
Together, the new metrics give a comprehensive view of payment practices. Payment terms reveal how large businesses may be leveraging their bargaining power over smaller suppliers, while average and median payment times indicate overall performance. The addition of late payment data and percentile indicators completes the picture with payment reliability.
Users of payment times data, including small businesses, will be better equipped to assess the likelihood and extent of delayed payment — crucial information when navigating working capital pressures and planning effectively.
Table 2: Evolution of the Scheme's Focus
| Focus Area | Previous Indicators | New Indicators |
|---|---|---|
| Bargaining Power | Payment terms | Payment terms; Forecast payment terms; Payment v receivables gap* |
| Payment Performance | Payment intervals (days) | Payment intervals (days); Average payment time; Median payment time |
| Payment Reliability | N/A | Payments on time; 80th & 95th percentile metrics |
* This measure has entities compare their payment terms and receivable terms.
The insights available from these new benchmarks are evident in our supermarket comparison. Looking only at common payment terms and average and median payment times, both Coles and Woolworths appear to pay within 30 days or better.
However, a closer look reveals important differences.
At an enterprise level, Woolworths presents a greater risk of delayed payments, with 8.6 per cent made late — nearly double the 4.5 per cent reported by Coles. Furthermore, 95 per cent of Woolworths' payments are made within 69 days, while Coles reaches the same threshold within just 30 days.
Particular attention should be given to this 95th percentile benchmark. In future reporting cycles, it will be used to identify fast and slow payers and is likely to play a key role in future reporting and comparisons.
For large businesses managing payment times by averages and medians, it is a good time to consider the causes and potential remedies for outliers and late payments — these will carry greater weight in how payment practices are assessed going forward.
Not Yet the Full Picture: Compliance Gaps
It's tempting to draw early conclusions from new payment times data, but the picture remains incomplete.
Before the reforms, around 10,000 individual entities reported under the scheme. Under consolidated reporting, that figure is expected to drop closer to the 5,000 large businesses represented by these entities.
To date, approximately 3,500 reports have been submitted, with more expected as several hundred businesses are likely to have extended reporting timelines. According to the Regulator's latest release on 27 June 2025, 115 businesses were granted extensions — though that number has likely increased since.
There may also be accuracy issues for the Regulator to resolve. In our supermarket example, both Coles and Woolworths disclose performance of operating segments in their financial statements, yet only one (Coles) has included segment-level data in its payment times submission — a new requirement for some entities under the reforms.
The Regulator's next update, expected at the end of the month, will be a key opportunity to clarify its position on data accuracy and how it intends for these issues to be addressed in existing and future reporting.
Navigating the New Landscape
Need support preparing or amending your payment times report?
RGC Advisory is a leading authority on payment times reporting, with deep expertise in scheme compliance and risk management. Our Founder and Principal, Owen Rayner, played a key role in shaping the 2024 reforms, bringing unparalleled insight into how regulatory data will be applied. We provide strategic support to clients — helping them meet obligations, mitigate risk, and stay ahead of regulatory scrutiny. Get in touch to find out how we can help.