Governance · Compliance
Operating document — adopted by resolution, reviewed annually

Compliance Calendar Y1–Y3

The single reference document that tells the Board, the Secretary, and the CEO what is due, when, to whom, and under which section of which Act — from the moment "Life Without Debt Ltd" is incorporated through to the end of Year 3. Structured as a month-by-month calendar plus a per-obligation reference index, so nothing is missed and every entry has a legislative anchor.

DRAFT v1.0 · For adoption at First Board Meeting alongside the Board Charter and Risk Register
How this calendar works

Life Without Debt Ltd will be a public company limited by guarantee, registered as a charity with the ACNC, endorsed as a Public Benevolent Institution, and endorsed for DGR item 4.1.1. Each of those overlays a different set of obligations — plus corporate law, tax, employment, insurance, state fundraising, and (from Year 2) consumer credit. This calendar collapses them into a single quarter-by-quarter timeline. Every line references the exact section or regulator that creates the obligation.

Legend: Statutory (hard deadline, penalty attached) · Regulatory (soft deadline, consequence attached) · Operational (best-practice cadence).

Part A · Assumptions and anchor dates

The calendar assumes the following anchor points. Where an anchor is uncertain, the placeholder is shown; the Secretary should confirm all dates at adoption.

Anchor Assumed date Basis / source
Company incorporation date (ASIC Form 201 lodged and accepted) [Q1 Y1 — target month] Corporations Act 2001 (Cth) s.117 — registration of company. Creates the ACN and the review date.
Financial year end (FYE) 30 June each year Corporations Act s.323D + Constitution cl.29. Charities Act deemed reporting period aligns.
ASIC annual review date Anniversary of incorporation each year Corporations Act s.345A. Review fee waived for ACNC-registered charities under Corporations (Fees) Regulations.
ACNC registration effective date Same date as incorporation (backdated on request) ACNC Act 2012 (Cth) s.30-15. Lodge within 60 days of incorporation for backdating.
DGR endorsement effective date Target: same as ACNC effective date ITAA 1997 s.30-125 + s.30-130. Request DGR endorsement effective from the date of registration on the ACNC form.
First Board meeting Within 14 days of incorporation First Directors' Resolutions Item 1 + Board Charter §3.1. Adopts constitution, opens registers, appoints officers.
First Annual General Meeting Within 18 months of incorporation, and thereafter within 5 months of FYE Corporations Act s.250N. As a public company LWD must hold an AGM.

Part B · Quarter-by-quarter timeline

Year 1 — Formation and first-year compliance

Y1 focus

Get incorporated, get registered, open the registers, put insurance and payroll in place, run the first AGM as early as prudent, and reach FYE with clean books and a full Governance Standards paper trail.

Quarter Event / obligation Owner Anchor / authority
Y1 Q1
Formation quarter
Lodge ASIC Form 201 → obtain ACN → obtain Certificate of Registration Founders / Secretary Corporations Act s.117
Apply for ABN, TFN, GST registration (if turnover expected >$150k) via ATO Secretary / CoSai (CFO) A New Tax System (ABN) Act 1999 · ITAA 1936 s.202B · GST Act s.23-15
First Board meeting: adopt Constitution · appoint Chair, Secretary, Treasurer · open registers · adopt Board Charter · adopt this Compliance Calendar All Directors First Directors' Resolutions · Board Charter §3
Lodge ACNC registration (charity + PBI subtype) within 60 days for backdated effect Secretary + solicitor ACNC Act s.30-15 · Charities Act 2013 s.5 & s.15
Apply for DGR endorsement (item 4.1.1 PBI) via same ACNC form Secretary + solicitor ITAA 1997 s.30-45 item 4.1.1 · s.30-125 · s.30-130
Open dedicated charity bank account (two signatories per DAS §5.7) Treasurer / CEO Board Charter DAS §5.7
Bind D&O insurance, public liability, professional indemnity, cyber Secretary Board Charter §7 · Risk Register
Consent-to-Act forms filed for all Directors; Register of Interests opened with pre-filled standing declarations Secretary Corporations Act s.201D · ss.191–192
Y1 Q2
Bedding-in
ACNC confirmation of charity + PBI + DGR expected (allow 6–10 weeks after lodgement) Secretary follows up ACNC Act s.30-20
If any employee engaged: register for PAYG withholding, workers compensation (state-based), Fair Work compliance Secretary / CoSai TAA 1953 Sch 1 · state Workers Compensation Acts · Fair Work Act 2009
If any employee: superannuation guarantee established (11.5% FY25, 12% FY26) Secretary / CoSai Superannuation Guarantee (Administration) Act 1992
State fundraising authorities: assess and apply where required — NSW · Vic · Qld · SA · WA · Tas · ACT · NT (see Part D) Secretary + solicitor State fundraising / charitable-collections Acts (see Part D)
Board meeting #2 — quarterly cadence begins Chair Board Charter §3.1
Adopt operating policies: Conflicts, Related-Party, Reserves, Direct Relief, Privacy, Risk (see Part E) Board ACNC Governance Standards 1–6 · Board Charter §5
Y1 Q3
Operationalising
Board meeting #3 — mid-year progress review Chair Board Charter §3.1
First sub-committee cycles: Audit & Risk, Nominations & Remuneration, Beneficiary Services (per Board Charter §6) Sub-committee Chairs Board Charter §6
Half-year management accounts + reserves tracking review Treasurer / CoSai (CFO) Reserves Policy · Board Charter DAS §5.3
Cyber/data privacy stocktake; APP compliance check Secretary + IT provider Privacy Act 1988 (Cth) — APPs (if threshold met or voluntary opt-in)
Y1 Q4
Financial year-end
Financial year ends 30 June — close books, run stocktake, freeze registers Treasurer / CoSai Corporations Act s.323D · Constitution cl.29
Annual financial statements prepared (special-purpose or general-purpose per size) Treasurer / CoSai Corporations Act ss.292–298 · ACNC size thresholds
Directors' Report and Directors' Declaration signed Board Corporations Act s.298 · s.295(4)
External review or audit engaged if revenue thresholds met (Medium ≥ $500k → review; Large ≥ $3m → audit) Audit & Risk Committee ACNC Act ss.60-15/60-20 · ACNC size thresholds
First AGM planning begins (must be held within 18 months of incorporation) Chair / Secretary Corporations Act s.250N
Annual review of Board Charter, Delegated Authorities Schedule, Risk Register, Reserves Policy, Direct Relief Policy Board Board Charter §9 (policy review cadence)

Year 2 — First full-year reporting and consumer-credit prep

Y2 focus

File the first full-year ACNC AIS and ASIC annual review, run the first AGM, and — if the direct-payoff / hardship-negotiation activities scale into engagement with credit providers on behalf of beneficiaries — assess whether the Australian Credit Licence (ACL) trigger is met and, if so, lodge the ACL application. See ACL Application Package for the assessment.

Quarter Event / obligation Owner Anchor / authority
Y2 Q1
Jul–Sep
First AGM held — present financials, table Directors' Report, appoint/re-appoint reviewer/auditor Chair Corporations Act s.250N · s.250R · Constitution cl.20
ACNC Annual Information Statement (AIS) due within 6 months of FYE = 31 December Secretary + Treasurer ACNC Act s.60-5 · s.60-10
Annual Financial Report (AFR) lodged with AIS if Medium/Large Treasurer + reviewer/auditor ACNC Act s.60-15
Fringe Benefits Tax return (if any FBT-eligible fringe benefits provided) CoSai FBTAA 1986
DGR annual review — check gift-fund records are auditable and use of receipted funds is exclusively on DGR-purpose activities Treasurer ITAA 1997 s.30-125(6) · s.30-125(7)(b)(iii)
Board meeting #5 (annual cadence: 4 board + 4 committee cycles per year) Chair Board Charter §3.1
Y2 Q2
Oct–Dec
31 Dec — ACNC AIS deadline (hard) Secretary ACNC Act s.60-5
ASIC annual review — anniversary of incorporation. Confirm details, pay fee (waived for registered charities) Secretary Corporations Act s.345A · Corporations (Fees) Regulations reg 3
Insurance renewals cycle (D&O · PL · PI · cyber · fidelity) Secretary Board Charter §7
ACL trigger assessment — has volume/scope of consumer-credit assistance to beneficiaries crossed the NCCP threshold? Document assessment either way CEO + solicitor NCCP Act 2009 s.29 · s.6 · ASIC RG 203
Board meeting #6 Chair Board Charter §3.1
Y2 Q3
Jan–Mar
If ACL trigger met: lodge ACL application via ASIC. See ACL Application Package Solicitor + CEO NCCP Act s.36 · ASIC RG 204 · RG 205
Half-year management accounts; reserves tracking; direct-relief spend against caps Treasurer Reserves Policy · Board Charter DAS §5.3
Case Review Committee — review anonymised beneficiary case outcomes Beneficiary Services Committee Board Charter §6.3
Board meeting #7 Chair Board Charter §3.1
Y2 Q4
Apr–Jun
30 Jun — FYE Y2 close Treasurer Corporations Act s.323D
Annual policy review (Charter, DAS, Direct Relief, Reserves, Risk, Conflicts, Privacy) Board Board Charter §9
Board effectiveness self-assessment Chair + N&R Committee ACNC Governance Standard 5
Board meeting #8 Chair Board Charter §3.1

Year 3 — Operating rhythm and first Director-rotation cycle

Y3 focus

Operating rhythm is now established. Y3 introduces the first Director-rotation event (per Constitution cl.17 one-third retirement by rotation), the first triennial Constitution review, and — if ACL was obtained in Y2 — the first ACL annual compliance certificate.

Quarter Event / obligation Owner Anchor / authority
Y3 Q1
Jul–Sep
Second AGM — first rotation event: one-third of Directors retire (may stand for re-election) Chair + N&R Constitution cl.17 · Corporations Act s.201H
ACNC AIS Y2 lodged (due 31 Dec) Secretary ACNC Act s.60-5
AFR Y2 lodged with AIS Treasurer + auditor ACNC Act s.60-15
If ACL held: first ACL annual compliance certificate due Compliance Officer NCCP Act s.53 · ASIC RG 205
Y3 Q2
Oct–Dec
ASIC annual review Y3 — anniversary review, fee waived Secretary Corporations Act s.345A
Triennial Constitution review — is the current Constitution still fit for purpose? Board + solicitor Constitution cl.21 · Board Charter §9
Board meeting #10 (Q2) Chair Board Charter §3.1
Y3 Q3
Jan–Mar
DGR triennial internal audit — gift fund records; [DGR endorsement pending] activity substantiation Audit & Risk Committee ITAA 1997 s.30-125(7)(b)(iii)
Board meeting #11 Chair Board Charter §3.1
Y3 Q4
Apr–Jun
30 Jun — FYE Y3 close Treasurer Corporations Act s.323D
Full policy suite review (all documents on Board Charter §9 cadence) Board Board Charter §9
Board meeting #12 + effectiveness review Chair Board Charter §3.1

Part C · Per-obligation reference index

Each recurring obligation and its authority. Refer to this when a new Director asks "what is that filing and where does it come from?".

Obligation Frequency Deadline Authority
ACNC Annual Information Statement (AIS)Annual6 months after FYE = 31 DecACNC Act s.60-5, s.60-10
ACNC Annual Financial Report (AFR)Annual (Medium/Large only)With AISACNC Act s.60-15 (Medium: review), s.60-20 (Large: audit)
ASIC annual review + statement of solvencyAnnualWithin 28 days of anniversary of incorporationCorporations Act s.345A · s.347A
Directors' ReportAnnualWith AFRCorporations Act s.298 · s.300B (small tier concession may apply)
Directors' DeclarationAnnualWith AFRCorporations Act s.295(4)
Annual General MeetingAnnualWithin 5 months of FYE (18 months for first AGM)Corporations Act s.250N
Register of Members updatedOn change + before AGMRollingCorporations Act s.169
Register of Interests updatedOn changeRollingCorporations Act s.191 · s.192 · Constitution cl.19
Notification of changes to Directors / Secretary / registered officeEvent-drivenWithin 28 days (Form 484)Corporations Act s.205B · s.142
DGR gift-fund audit trailAnnualWith FYE closeITAA 1997 s.30-125(7)(b)(iii) · s.30-130
PAYG withholding + STP reportingEach pay runRolling / annual STP finalisation by 14 JulTAA 1953 Sch 1 · STP Phase 2
Superannuation guaranteeQuarterly28 days after quarter endSGAA 1992
FBT return (if applicable)Annual21 MayFBTAA 1986
BAS / GST return (if registered)Quarterly or monthly28 days after period endGST Act · TAA 1953
Workers Compensation renewalAnnualState-specificState Workers Compensation Acts
Insurance renewals — D&O · PL · PI · cyberAnnualRenewal anniversaryBoard Charter §7 (risk mgmt)
State fundraising authority renewals (see Part D)Varies by stateState-specificState fundraising / charitable-collections Acts
ACL annual compliance certificate (if held from Y2)AnnualWithin 45 business days of licensee's audit dateNCCP Act s.53 · Corporations Regulations reg 7.6.03A
Privacy Act APP compliance reviewAnnualSuggested by 30 JunPrivacy Act 1988 (Cth) — APPs 1–13
Board effectiveness reviewAnnualQ4 each yearACNC Governance Standard 5
Policy suite review (Charter, DAS, Direct Relief, Reserves, Risk, Conflicts, Privacy)AnnualQ4 each yearBoard Charter §9
Constitution reviewTriennialQ2 Y3 and every 3 years thereafterConstitution cl.21

Part D · State & territory fundraising authorities

Australia does not have a single national fundraising licence. LWD must assess each state where it will actively solicit donations (as distinct from passively receiving them) and apply for the applicable authority. The federal Charity Passport (ACNC) reduces but does not eliminate state-based fundraising authority requirements.

Jurisdiction Authority required? Regulator Governing Act
CommonwealthNil (charity registration itself)ACNCACNC Act 2012 (Cth)
New South WalesYes — Authority to FundraiseNSW Fair TradingCharitable Fundraising Act 1991 (NSW)
VictoriaYes — Fundraiser RegistrationConsumer Affairs VictoriaFundraising Act 1998 (Vic)
QueenslandYes — Sanction to FundraiseOffice of Fair TradingCollections Act 1966 (Qld)
South AustraliaYes — Collections for Charitable Purposes LicenceConsumer & Business Services SACollections for Charitable Purposes Act 1939 (SA)
Western AustraliaYes — Charitable Collection LicenceDepartment of Mines, Industry Regulation and Safety (Consumer Protection)Charitable Collections Act 1946 (WA)
TasmaniaYes — Approval to conduct a collectionConsumer, Building and Occupational ServicesCollections for Charities Act 2001 (Tas)
Australian Capital TerritoryYes — Charitable Collections LicenceAccess CanberraCharitable Collections Act 2003 (ACT)
Northern TerritoryGenerally no distinct licence; comply with ACL and privacyNT Consumer AffairsConsumer Affairs and Fair Trading Act 1990 (NT)
Practical approach

Apply for the NSW, Vic, Qld authorities in Y1 Q2 as a baseline (largest populations, most likely donor base). Apply for SA / WA / Tas / ACT before actively fundraising in those jurisdictions. Some states have reciprocal recognition or streamlined recognition for ACNC-registered charities — the solicitor should confirm the current position at each renewal.

Part E · Policy review cadence

Each policy has an owner, an approver, and a review cadence. This table locks that in so no policy silently becomes stale.

Policy / document Owner Approver Cadence Anchor
ConstitutionSecretaryMembers (special resolution)TriennialConstitution cl.21 · Corporations Act s.136
Board Charter (incl. DAS)ChairBoardAnnualBoard Charter §9
Direct Relief PolicyCEOBoardAnnualBoard Charter DAS §5.4
Reserves PolicyTreasurerBoardAnnualACNC Governance Standard 5
Conflicts PolicySecretaryBoardAnnualCorporations Act ss.191–195
Related-Party PolicySecretaryBoardAnnualCorporations Act ss.208–229 (Ch 2E)
Privacy & Beneficiary Data Handling PolicySecretaryBoardAnnualPrivacy Act 1988 (Cth) — APPs
Risk RegisterAudit & Risk ChairBoardQuarterly review, annual refreshBoard Charter §6.1
Compliance Calendar (this document)SecretaryBoardAnnualBoard Charter §9
Compliance PlanSecretaryBoardAnnualACNC Governance Standard 3

Part F · Adoption and sign-off

Resolution — adoption of Compliance Calendar Y1–Y3:

"That the Board adopts the Compliance Calendar Y1–Y3 (Draft v1.0) as the operating compliance schedule for Life Without Debt Ltd, notes that the Secretary is responsible for maintaining the calendar and bringing forward each event on the Board agenda in the quarter it falls due, and that the Calendar itself will be reviewed annually at the Q4 Board meeting alongside the other policy documents listed in Board Charter §9."

[Chair name]
Chair
Date: [dd/mm/yyyy]
[Secretary name]
Secretary
Date: [dd/mm/yyyy]
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