Submission to the ACNC Implementation Design Discussion Paper

This submission responds to the discussion paper on the implementation design of the Australian Charities and Not-for-profits Commission (ACNC), answering most of its fifteen consultation questions. Research Australia supports the proposed Charity Passport as a way to reduce reporting obligations, while noting that its value depends on greater standardisation of reporting and governance requirements across Commonwealth, State and Territory agencies, which the ACNC is well placed to drive. Its main argument concerns data: there is no reliable source of information on how much charities contribute to health and medical research or which areas they fund. Citing Australian Bureau of Statistics (ABS) figures showing that not-for-profit entities, excluding higher education institutions, spent $560 million on health and medical research in 2008–09, and the Productivity Commission’s 2010 findings on deficiencies in sector data, it recommends that the ACNC work with the ABS and the not-for-profit sector finalise the ABS Information Development Plan and then consider what further data to collect and publish through the annual return. It also maintains that the Commissioner’s approval should not be required to change an accounting period, proposing notification instead, consistent with the Corporations Act 2001. It supports optional narrative reporting of outcomes, the Standard Business Reporting taxonomy, AUSkey authentication and a broad education role for the ACNC.