Further to our recent alert, submissions closed last Friday on the revised Exposure draft for the establishment of the ACNC.
Given the short consultation period, our submission focused on the following key areas:
- Our recommendation that the Report Once Use Often objective of the ACNC be incorporated into its legislation as a key limb of its establishment and ongoing activities
- The reporting framework be included in the Bill itself with strong liaison between the AASB and ACNC to ensure that the accounting standards meet the needs of the sector.
- We welcomed the introduction of collective and joint reporting, however identified the need for further consultation in this area with the sector and the development of a uniform approach to the granting of this type of reporting to enable consistency and comparability of the data being collected.
- We supported the narrower definition of Responsible Entity from Responsible Individual however, we noted that the mechanism for committee members of unincorporated associations to be sued to provide recovery of fines and penalties could be refined.
- We supported the introduction of the concept of Basic Religious Charities (BRC) and sought further refinements to provide a consistent application across religious structures.
- We drew attention to the lack of clarity regarding subsequent registration of additional subtypes and the need to provide clear guidance to the sector regarding where registrations may conflict.
- We welcomed additional guidance on the Governance arrangements but strongly encouraged the Government to release draft regulations to enable the Sector to have adequate time to consider any required changes to existing governance arrangements.
Please find below the link to our submission on the parliament website.
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