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.
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
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
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
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) | Annual | 6 months after FYE = 31 Dec | ACNC Act s.60-5, s.60-10 |
| ACNC Annual Financial Report (AFR) | Annual (Medium/Large only) | With AIS | ACNC Act s.60-15 (Medium: review), s.60-20 (Large: audit) |
| ASIC annual review + statement of solvency | Annual | Within 28 days of anniversary of incorporation | Corporations Act s.345A · s.347A |
| Directors' Report | Annual | With AFR | Corporations Act s.298 · s.300B (small tier concession may apply) |
| Directors' Declaration | Annual | With AFR | Corporations Act s.295(4) |
| Annual General Meeting | Annual | Within 5 months of FYE (18 months for first AGM) | Corporations Act s.250N |
| Register of Members updated | On change + before AGM | Rolling | Corporations Act s.169 |
| Register of Interests updated | On change | Rolling | Corporations Act s.191 · s.192 · Constitution cl.19 |
| Notification of changes to Directors / Secretary / registered office | Event-driven | Within 28 days (Form 484) | Corporations Act s.205B · s.142 |
| DGR gift-fund audit trail | Annual | With FYE close | ITAA 1997 s.30-125(7)(b)(iii) · s.30-130 |
| PAYG withholding + STP reporting | Each pay run | Rolling / annual STP finalisation by 14 Jul | TAA 1953 Sch 1 · STP Phase 2 |
| Superannuation guarantee | Quarterly | 28 days after quarter end | SGAA 1992 |
| FBT return (if applicable) | Annual | 21 May | FBTAA 1986 |
| BAS / GST return (if registered) | Quarterly or monthly | 28 days after period end | GST Act · TAA 1953 |
| Workers Compensation renewal | Annual | State-specific | State Workers Compensation Acts |
| Insurance renewals — D&O · PL · PI · cyber | Annual | Renewal anniversary | Board Charter §7 (risk mgmt) |
| State fundraising authority renewals (see Part D) | Varies by state | State-specific | State fundraising / charitable-collections Acts |
| ACL annual compliance certificate (if held from Y2) | Annual | Within 45 business days of licensee's audit date | NCCP Act s.53 · Corporations Regulations reg 7.6.03A |
| Privacy Act APP compliance review | Annual | Suggested by 30 Jun | Privacy Act 1988 (Cth) — APPs 1–13 |
| Board effectiveness review | Annual | Q4 each year | ACNC Governance Standard 5 |
| Policy suite review (Charter, DAS, Direct Relief, Reserves, Risk, Conflicts, Privacy) | Annual | Q4 each year | Board Charter §9 |
| Constitution review | Triennial | Q2 Y3 and every 3 years thereafter | Constitution 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 |
|---|---|---|---|
| Commonwealth | Nil (charity registration itself) | ACNC | ACNC Act 2012 (Cth) |
| New South Wales | Yes — Authority to Fundraise | NSW Fair Trading | Charitable Fundraising Act 1991 (NSW) |
| Victoria | Yes — Fundraiser Registration | Consumer Affairs Victoria | Fundraising Act 1998 (Vic) |
| Queensland | Yes — Sanction to Fundraise | Office of Fair Trading | Collections Act 1966 (Qld) |
| South Australia | Yes — Collections for Charitable Purposes Licence | Consumer & Business Services SA | Collections for Charitable Purposes Act 1939 (SA) |
| Western Australia | Yes — Charitable Collection Licence | Department of Mines, Industry Regulation and Safety (Consumer Protection) | Charitable Collections Act 1946 (WA) |
| Tasmania | Yes — Approval to conduct a collection | Consumer, Building and Occupational Services | Collections for Charities Act 2001 (Tas) |
| Australian Capital Territory | Yes — Charitable Collections Licence | Access Canberra | Charitable Collections Act 2003 (ACT) |
| Northern Territory | Generally no distinct licence; comply with ACL and privacy | NT Consumer Affairs | Consumer Affairs and Fair Trading Act 1990 (NT) |
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 |
|---|---|---|---|---|
| Constitution | Secretary | Members (special resolution) | Triennial | Constitution cl.21 · Corporations Act s.136 |
| Board Charter (incl. DAS) | Chair | Board | Annual | Board Charter §9 |
| Direct Relief Policy | CEO | Board | Annual | Board Charter DAS §5.4 |
| Reserves Policy | Treasurer | Board | Annual | ACNC Governance Standard 5 |
| Conflicts Policy | Secretary | Board | Annual | Corporations Act ss.191–195 |
| Related-Party Policy | Secretary | Board | Annual | Corporations Act ss.208–229 (Ch 2E) |
| Privacy & Beneficiary Data Handling Policy | Secretary | Board | Annual | Privacy Act 1988 (Cth) — APPs |
| Risk Register | Audit & Risk Chair | Board | Quarterly review, annual refresh | Board Charter §6.1 |
| Compliance Calendar (this document) | Secretary | Board | Annual | Board Charter §9 |
| Compliance Plan | Secretary | Board | Annual | ACNC 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."
- Board Charter (with DAS) — the source of policy-review cadence in §9
- Compliance Plan — the narrative complement to this calendar
- ACNC Portal-Ready Answers — content that feeds the Governance Standards narrative
- ASIC Form 201 Worksheet — creates the incorporation anchor date
- ACL Application Package — the Y2 Q2 assessment trigger