Commission’s 2025-2026 regulatory focus

The ACNC’s 2025-26 focus highlights the critical importance of good record-keeping and the commission’s work to educate charities about their obligations.

Updated guidance states that appropriate and effective record-keeping is generally reflective of good governance, decision making, financial management, and risk management.

Financial records should explain how a charity receives and spends its money and other assets, a charity’s financial position, and performance, and allow for true and fair financial statements to be prepared, and audited or reviewed.

Operational records must show how a charity is entitled to be registered as a charity, to be registered with its subtype, meet tax-law obligations and other obligations under the act.

Guidance includes checklists and examples that will support charities of all sizes and types in transparency efforts and record-keeping, including 'Keeping charity records', 'Record-keeping checklist', and examples of financial and other records.

The commission will support Australia’s compliance with the Financial Action Task Force obligations, beginning with compliance reviews and consultation with charities that work overseas.

It will help to ensure that charities working overseas understand the risks of being misused for terrorism financing and how to protect themselves.

The focus will be to ensure charities:

  • Understand the risks they face due to their operating locations and activities
  • Have strong governance arrangements, including appropriate financial controls, as well as robust risk management
  • Have established appropriate due diligence measures, including oversight and monitoring of their partners, their overseas projects, and funds sent overseas
  • Keep appropriate records and report annually to the ACNC, and
  • Recognise that clear and accurate records are the foundation of good governance and risk management.

Guidance includes a checklist to guard against terrorism financing and governance help for charities operating in complex structures.

Operating within a complex structure – sometimes also known as operating as a ‘group’ – typically involves several entities that might have varying structures, purposes, and operations. They might comprise a variety of organisations – trusts, incorporated associations, unincorporated bodies, companies limited by guarantee, and private companies.

They may be set up to help charities manage risk, focus on different programs, and operate across many locations. Sometimes separate entities may be required to operate different services. Greater structural complexity can also create governance and operational complexity. This may result in confusion about roles, responsibilities, and obligations.

Charities within complex structures need to focus on:

  • Policies and procedures
  • Record-keeping
  • Common boards and directorships
  • Board meetings
  • Roles within complex structures
  • Conflicts of interest, and
  • Related-party transactions.

ACNC commissioner Sue Woodward said that without clear systems and good communication it can be harder to meet the commission’s governance and external-conduct standards.

‘While operating within a complex structure is not in itself a problem – and the ACNC recognises there are often good and legitimate reasons for charities to do so – it is important that any charity operating within such a structure takes extra care’, she said.

‘The ACNC’s new guidance on good governance in complex structures is part of our education-first approach. This approach sees us provide practical information to help charities, and the people involved in running them, to get things right […].’

Charities, especially those with shared boards and governance arrangements, are encouraged to read the guidance and seek professional advice if needed.

The guidance may be found on the ACNC website.



General Advice Warning
The information provided in this article is for general information purposes only and is not intended to and does not constitute formal taxation, financial or accounting advice. McConachie Stedman does not give any guarantee, warranty or make any representation that the information is fit for a particular purpose. As such, you should not make any investment or other financial decision in reliance upon the information set out in this correspondence and should seek professional advice on the financial, legal and taxation implications before making any such decisions.