ACNC Annual Reporting Requirements for Churches

If your Church is a registered charity, the ACNC is part of your world whether you think about it often or not. The good news is that reporting for Churches is usually lighter than for other charities, and a particular category, the Basic Religious Charity, carries reduced  obligations compared to other  charity subtypes. Understanding where your Church sits can save your board a considerable amount of work.

The one thing every registered charity must do

Every charity registered with the ACNC has to lodge an Annual Information Statement each year. This is the ACNC's core accountability tool. It asks about your Church's activities, size and, for most charities, its finances. It is due six months after the end of your reporting period. For a Church with a 30 June year end, that means the statement is due by 31 December.

Lodging the statement is not optional, and repeatedly missing it can put your charity registration, and the tax concessions that come with it, at risk. It is the single most important compliance date in a Church's year.

How your Church's size changes what you lodge

Beyond the Annual Information Statement, financial reporting depends on your revenue. The ACNC groups charities into three sizes:

• Small: annual revenue under $500,000.

• Medium: annual revenue of $500,000 to just under $3 million.

• Large: annual revenue of $3 million or more.

Small charities generally do not have to submit a financial report alongside their AIS submission, though they can choose to. Medium charities must submit a financial report that is at least reviewed by an auditor. Large charities must submit an audited financial report. So as your Church grows, the level of assurance the ACNC expects grows with it.

The Basic Religious Charity: the exemption many Churches qualify for

This is where Churches are treated differently from almost every other kind of charity. A Basic Religious Charity, or BRC, does not have to answer the financial questions in its Annual Information Statement, does not have to submit financial reports regardless of its size, and does not have to comply with the ACNC Governance Standards. It still has to lodge the Annual Information Statement each year, but the financial reporting burden largely falls away.

It sounds generous because it is. It is also narrow. Your Church has to meet all six of the following criteria to qualify.

The six criteria for Basic Religious Charity status

• It is registered only with the charity subtype of advancing religion. Running a separate school, for example, usually creates a second charitable purpose and breaks this criterion.

• It is not a body corporate registered under the Corporations Act (such as a company limited by guarantee) and not incorporated under a state or territory associations incorporation law.

• It has not received government grants of $100,000 or more in the current reporting period or either of the previous two.

• It has not been approved by the ACNC to report as part of a group for that period.

• It is not, as a whole entity, endorsed as a deductible gift recipient. Being a DGR only for a specific fund is allowed, provided total revenue from those funds is under $250,000 for the period.

• It meets the National Redress Scheme requirement, meaning it has not been identified in a redress matter and then failed to join the Scheme.

The structural trade-off worth understanding early

Notice the second criterion. The moment a Church incorporates, either as an incorporated association or a company limited by guarantee, it stops being a Basic Religious Charity and picks up the full financial reporting and governance obligations. Incorporation brings real benefits, chiefly limited liability for your leaders, so this is not an argument against it. It is simply a decision to make with your eyes open, because the reporting consequences are significant and often overlooked.

What Basic Religious Charities still need to do

The exemptions exist, but they are not a free pass. A BRC must still lodge its Annual Information Statement every year, keep proper records, notify the ACNC of changes to key details such as its Responsible People or governing document, and comply with the External Conduct Standards if it operates or sends funds overseas. Good record-keeping remains the foundation of a healthy Church, exemption or not.

A note for denominations and multi-site Churches

If your Church is part of a wider denomination or network, group reporting or bulk lodgement arrangements may apply, often coordinated by a central administration office. Non-government schools that are registered charities also have their own streamlined reporting arrangements with the ACNC. If this is you, it is worth confirming exactly who lodges what, so nothing falls through the gap between entities.

Working out your Church's size, your reporting tier, and whether you qualify as a Basic Religious Charity is the kind of clarity we bring to Kingdom organisations every day. If you would like a hand mapping your obligations, we would love to help. Get in touch with us to learn more about how we can support you.