Tax, Structure & Compliance · 28 September 2027
A genuine, easily missed compliance gap sits precisely at the intersection of two regulatory systems most associations are simultaneously subject to. Confirming your ACNC size category alone is not enough to know whether your financial report requires an audit or review, if your association is also incorporated under state legislation carrying its own, different thresholds.
The Current Acnc Thresholds, Which Have Shifted Over Time
For reporting periods from the 2024 Annual Information Statement onwards, the ACNC classifies a charity as small with annual revenue under $500,000, medium between $500,000 and $3 million, and large at $3 million or more. Small charities face no ACNC audit or review requirement at all. Medium charities must have their financial report either reviewed or audited, the organisation's choice. Large charities must have theirs audited. These thresholds have increased over recent years, meaning an association relying on a figure it learned some years ago may be working from an outdated threshold entirely.
The Genuine Gap Most Dual-Registered Associations Miss
Here is the specific point worth understanding. An association incorporated under state incorporated associations legislation, in addition to being ACNC-registered, may face different size tiers and audit thresholds under that state legislation, and these do not automatically align with the current ACNC figures. Some state frameworks require a review or audit at revenue levels considerably lower than the ACNC's own medium threshold. An association correctly concluding it falls below the ACNC's audit requirement may still be legally required to have its financial statements reviewed or audited under the separate state incorporation regime it is also registered under. Checking only the ACNC threshold and concluding no audit is required is checking half the picture for any association also incorporated under state legislation. The two regimes were not designed to align, and an association needs to check both separately.
Two Further Layers Worth Confirming Directly
Beyond the two regulatory thresholds, an association's own constitution may independently require an annual audit regardless of size, a genuine, self-imposed obligation that persists even where neither the ACNC nor state legislation would otherwise require it, connecting directly to the constitutional discipline discussed throughout this series. Separately, a funding agreement or grant contract may impose its own audit requirement as a specific condition of funding, independent of both regulatory frameworks entirely. A complete answer to whether your association needs an audit checks all four possible sources, ACNC size, state incorporation tier, the constitution, and any funding agreements, not just the first one that comes to mind.
- Confirm your association's current ACNC size classification against the current thresholds directly, given these have increased in recent years and an outdated figure produces the wrong answer.
- Separately check your association's size tier and audit requirement under any state incorporated associations legislation it is also registered under, since these thresholds may differ meaningfully from the ACNC's own.
- Review your constitution specifically for any self-imposed audit requirement that applies regardless of size, connecting directly to the constitutional discipline discussed throughout this series.
- Check every current funding agreement or grant contract for an independent audit condition, since this obligation exists entirely separately from both regulatory size thresholds.
- Reassess this full picture whenever your association's revenue changes meaningfully, rather than assuming a status confirmed several years ago still applies today.
A complete answer to whether your association needs an audited or reviewed financial report requires checking four potentially independent sources, not one. An association that checks only its ACNC size classification and stops there has answered an incomplete question with unwarranted confidence.
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— Annie