Section 33 of the Code of Conduct contains two obligations about time, and they are not the same obligation.
An agent must be aware of the times by which, under law, any relevant application must be made, any response must be given, or any other relevant thing must be done. And an agent must have regard to the consequences of a thing not being done by the relevant time.
Most deadline systems serve the first. A date goes into a calendar, an alert fires, someone acts. Almost none serve the second, because a calendar entry records when without recording what happens if not — and that second fact is what should determine how hard the system pushes.
Consequence is a property of the deadline
A missed date in migration work can mean anything from a mild inconvenience to the permanent loss of a right. Treating those identically is what produces the classic failure: the reminder fires, someone is busy, it gets deferred, and the deferral is unremarkable because nothing on the screen said it was different.
Capture the consequence with the date. Four broad classes cover most work:
- Irrecoverable. A review period that cannot be extended, a visa that ceases, an age or time threshold. Missing it ends something.
- Recoverable at cost. A response deadline where a late submission may still be accepted, or a lapse that can be cured with a further application and a further charge.
- Consequential for the client's status. Not fatal to the application, but the client's work rights, study or travel change.
- Administrative. Internal or courtesy dates with no external effect.
The class should drive the escalation, not the person's judgment on the day. Our guide to ART review deadlines covers the category where this matters most.
Two calendars, deliberately independent
The argument for a second calendar is not redundancy for its own sake. It is that most deadline failures are capture failures, not reminder failures — the date was never entered, so no system had it.
Independence is what makes a second capture worth anything. Two calendars fed by the same person reading the same email are one calendar with extra steps.
The matter calendar holds dates derived from the matter itself: statutory periods, the date on a request for further information, the date a bridging visa ceases. These are properties of the file and should be recorded on it.
The practice calendar is the aggregated view, sorted by consequence, that someone looks at daily and weekly. It exists to answer "what is at risk this week" across everyone.
The second capture should come from a different source than the first: departmental correspondence read by someone other than the person managing the matter, or a systematic sweep for dates in incoming mail. If both entries come from the same reading of the same document, one omission removes both.
Verification is a separate step from capture
A deadline entered wrongly is more dangerous than one not entered, because it creates confidence.
Verification means someone checks the date against the source document, not against the entry. It takes seconds and catches the errors that matter: a period counted from the wrong event, a date transcribed with the month and day transposed, and — the one that recurs — a deadline calculated in the wrong time zone for a client offshore.
Reminders that do not train people to ignore them
A reminder system with one setting produces alert fatigue and, eventually, an inbox rule. The fix is to make frequency proportionate.
- Administrative dates: one reminder, on the day.
- Recoverable dates: a reminder at a fortnight and again at three days.
- Status-affecting dates: a month, a fortnight, a week, and daily in the final three days.
- Irrecoverable dates: the above, plus a reminder to someone other than the person responsible.
Two design points matter more than the intervals. A reminder that can be dismissed without an action being recorded is a notification, not a control — dismissal should require saying what was done or when it will be. And reminders should be attached to the matter rather than to a person, so that a colleague's absence does not silence them.
Escalation is what makes the system real
Everything above still relies on one person acting. Escalation is the part that survives that person having a bad fortnight.
The rule worth adopting: an irrecoverable deadline inside seven days with no recorded action escalates to someone else automatically. Not as a reprimand — as a design feature. The escalation exists precisely for the weeks when someone is overloaded, unwell or on leave, which are exactly the weeks deadlines get missed.
Escalation also needs somewhere to go. In a solo practice, that means a nominated colleague and a reciprocal arrangement. In a small firm, it means the supervising agent. OMARA's guidance on practice management duties lists reviewing applications before lodgement among the supervisory arrangements a practice should have, and a deadline escalation is the same instinct applied earlier.
Where the client's own delay fits
Many deadlines are missed not because the practice was slow but because the client did not provide something.
Section 33 also requires you to act in the client's legitimate interests and respond in a timely manner, and section 40 prohibits acting in a way that causes, or is reasonably likely to cause, unnecessary expense or delay. Neither is discharged by having asked once.
Practically, three things protect both the client and you:
- Write the consequence down, to the client, early. Not "please send this soon" but what happens if it is not received by a stated date.
- Record the request and the response as a file note. Where the client is told orally, section 55 requires a contemporaneous written record.
- Set an internal date ahead of the real one, so there is room to act when the client is late — and treat the internal date as the one the reminder fires on.
The deadline audit
Take the ten matters with the nearest external dates:
- Is every date recorded on the matter, not only in someone's calendar?
- Does each carry its consequence class?
- Was each verified against the source document by a second reading?
- Which dates were captured from only one source?
- What happens to a reminder if the responsible person is on leave?
- Is there an escalation for the irrecoverable ones, and to whom?
- For any date depending on the client, has the consequence been put in writing to them?
Where a system helps
Deadline management fails at the joins. The date lives in Outlook, the file lives on a drive, the departmental email lives in a mailbox, and nothing connects them — so leaving the practice, going on leave, or reassigning a matter silently drops the thread.
A system where deadlines are properties of the matter fixes the structural part: reminders survive staff changes, the practice-wide view is a query rather than a compilation, escalation has somewhere to go, and the record of what was done sits next to the date it relates to. Our guides to ImmiAccount workflow and growing from solo to a team cover the surrounding practice.
LodgeHQ attaches deadlines, reminders and escalations to matters rather than to people. Start a free trial and find out how many of your live dates exist in exactly one place.
Verify before you rely on it
Statutory periods change, and the consequence of missing one is a matter of law rather than practice. Verify every period against the current legislation and departmental material for the specific visa or review, not against a template.
This is general information for migration practices, not legal advice. If a deadline has been missed, get advice on that matter immediately — the available remedies are usually time-limited themselves.