This Commissioner’s Policy Statement is issued under the authority of the Commissioner and should be read together with the ACNC Policy Framework, which sets out the scope, context and definitions common to our policies.
This Commissioner’s Policy Statement sets out when the Commissioner will approve the use of reporting periods ending on a day other than 30 June (also known as substituted accounting periods) for charities under section 60-85 of the Australian Charities and Not-for-profits Commission Act 2012 (Cth) (ACNC Act).
A charity can apply for a substituted accounting period:
- at the time of applying for registration with the ACNC (or when re-applying for registration if the charity’s registration was previously revoked), or
- if already registered with the ACNC, at any time by submitting a request via the ACNC Charity Portal.
The ACNC Act gives the Commissioner discretion to approve substituted accounting periods. If a substituted accounting period is approved, the due date for submitting an Annual Information Statement (AIS) and annual financial report (if applicable) is six months after the end of the substituted accounting period (section 60-85).
Charities that have a substituted accounting period approved under the ACNC Act should be aware that the approval applies for the purposes of the ACNC Act only.
- Principle 1: Substituted accounting periods will be approved if there is a genuine need.
- Principle 2: Substituted accounting periods will not be approved, or conditions may apply, if public trust and confidence is affected.
Power to allow substituted accounting periods
- The Commissioner has a discretion to allow a charity to use a substituted accounting period (section 60-85) and may impose conditions on that approval (section 60-90). The charity must apply using the approved form.
Adoption of a substituted accounting period
- If a substituted accounting period is approved, it will apply to the financial year that starts after the charity adopts the new substituted accounting period (subsection 60-85(2)).
- The Commissioner may impose conditions on the approval of a substituted accounting period, either at the time of the application or at a later date (section 60-90). The conditions may include transitional reporting obligations which allow for the immediate adoption of the substituted accounting period and to ensure there are no gaps in charity reporting periods. The Commissioner can revoke the approval if the imposed conditions are not met.
- Approved substituted accounting periods always end later than the standard financial year-end 30 June (subsection 60-85(2)(a)). The year-end date of an approved substituted accounting period must be at least 1 day later than 30 June and no later than 29 June in the next standard financial year.
- For example, the information in the 2023 AIS reporting period for a charity with an approved 31 March year-end substituted accounting period covers the period from 1 April 2023 to 31 March 2024.
- The Commissioner will notify a charity of the approval of a substituted accounting period.
Principle 1: Substituted accounting periods will be approved if there is a genuine need
- The Commissioner will approve a substituted accounting period where a registered charity can demonstrate a genuine need to adopt such a period.
- Factors that the Commissioner will consider include:
- the current arrangements that apply to the charity, for example reporting to other regulators or grant-making bodies
- a history of reporting under a substituted accounting period
- references to the substituted accounting period in the charity’s governing documents, legal or internal reporting requirements, and
- the reporting period of related or associated charities.
Principle 2: Substituted accounting periods will not be approved, or conditions may apply, if public trust and confidence is affected
- The Commissioner will not approve a substituted accounting period where this might affect transparency and negatively impact on public trust and confidence in the sector.
- The Commissioner will not approve a substituted accounting period where this is contrary to the charity’s governing documents or legal reporting requirements.
- The Commissioner will not approve a substituted accounting period for a charity that is an ancillary fund. Under current ancillary fund guidelines, substituted accounting periods are not permitted.
- As noted above, the Commissioner may impose conditions on the approval of a substituted accounting period (section 60-90). To ensure a smooth transition from one reporting period to the next with no gaps in the charity’s reporting, the Commissioner may require a charity to use a transitional reporting period of more or less than 12 months, depending on the specific change to the charity’s reporting period.
- The transitional reporting period will start the day after the charity’s previous reporting period ends and will finish on the last day of the new substituted accounting period.
- For example, a charity may change its financial year end from 30 June to 31 December, so that its first substituted accounting period ends on 31 December 2023. In this case, the Commissioner would require the charity to submit its 2023 AIS and (if applicable, annual financial report) for an 18-month period from 1 July 2022 until 31 December 2023. After the end of this transition period, the charity’s subsequent statements and reports would be required for each 12-month period (see the ACNC’s Annual Information Statement policy).
- The transitional period imposed by the Commissioner will be consistent with the requirement that charities submit an AIS for each ACNC reporting period. Charities with approved substituted accounting periods cannot use a transitional reporting period that would skip an ACNC reporting period.
- The Commissioner has the power to impose other conditions when approving a substituted accounting period, taking into account factors that could affect public trust and confidence in the sector.
Revocation of a substituted accounting period
- If the Commissioner has evidence that a registered charity has not complied with the conditions for approval of a substituted accounting period, the Commissioner may revoke the approval of the substituted accounting period (subsection 60-90(3)). If this occurs, the default reporting period (financial year ending on 30 June) will apply to the registered charity.
- A registered charity may also seek to return to the default reporting period (financial year ending 30 June), or apply for an alternative substituted accounting period, if the Commissioner has previously approved a substituted accounting period. The charity can apply via the ACNC Charity Portal, providing reasons for revoking their approved substituted accounting period and the proposed reporting arrangements for the future reporting periods. In assessing the application, the Commissioner will have regard to the principles referred to above.
- In determining the reporting requirements that arise from returning to the default reporting period, the Commissioner may also impose conditions so that the ACNC reporting obligations will align with the charity’s reporting arrangements. The ACNC will ensure that there are no gaps in the time periods covered by reports submitted and to be submitted by the charity.
- For example, a charity may change its existing approved substituted accounting period ending 31 December back to a standard financial year ending 30 June, with the first standard financial year ending 30 June 2024. In this case, the ACNC would require the charity to submit an AIS and (if applicable, an annual financial report) for a 6-month period starting on 1 January 2024 and ending 30 June 2024. After the end of this transition period, the charity’s subsequent statements and reports would be required for each 12-month period. Note that in this example, the charity could not use a transitional period of 18 months, such as 1 January 2023 to 30 June 2024, because this would result in the charity skipping the 2023 reporting period.
|Version||Date of effect||Brief summary of change|
|Version 1 – initial policy||03/12/2012||Initial policy endorsed by the Commissioner on 06/12/12.|
|Version 2 – revised policy||11/11/2013||Removal of references to transitional arrangements, clarifications in relation to review and application to 2013 and 2014 reporting periods.|
|Version 3 – revised policy||02/06/2014||Clarification on conditions imposed on approval of substituted accounting period and applying for revocation of substituted accounting period.|
|Version 4 – revised policy||28/05/2018||Removal of references to 2013 and 2014 reporting periods and ability to seek internal review. Referencing to registration process and clarification on the transitional year.|
|Version 5 – revised policy||30/03/2021||Added additional guidance to address frequently asked questions and explanatory examples.|
|Version 6 – revised policy||14/09/2023||Updated acronyms and date references to reflect current periods. Added governing documents and ancillary funds as criteria of SAP refusal.|