The Queensland Office of Fair Trading has released three consultation papers on making regulations to the Associations Incorporation Act and the Collections Act in regards:

  • The form of grievance procedures to be required of Incorporated Associations;
  • The form of compulsory disclosure of remuneration of association committee members and senior staff; and
  • New reporting requirements and thresholds for associations and fundraising.

Submissions are due by 12 September 2022.


In 2020, the Parliament of Queensland passed the Associations Incorporation and Other Legislation Amendment Act 2020 (the Amendment Act). The Amendment Act introduced changes to the Associations Incorporation Act 1981 and the Collections Act 1966.

Some amendments were not in force while consultations were to take place to develop regulations to complement that Act. Due to COVID-19 the consultations were delayed for two years but are now progressing.

The relevant amendments to the Associations Incorporations Act commenced on 22 June 2022, but will not have practical effect until various matters are prescribed in the Associations Incorporation Regulation.

Incorporated Association Member Grievance

The Amendment Act requires an incorporated association to have a specified grievance procedure that complies with the Act.

The procedure may be set out in the association’s rules, and if not, then the association is taken to be using the model rule grievance procedure as a default.

The model rules are yet to be amended to specify the grievance procedure, and the consultation seeks views on its form.

The proposed model rule grievance procedure is that:

  • if an aggrieved party wishes to engage in the grievance procedure, they may do so by advising the other party in writing. The grievance procedure may not be engaged by a person who is the subject of disciplinary action about a matter related to the disciplinary action.
  • the parties must then attempt to resolve the dispute between themselves. If the dispute cannot be resolved within 14 business days, the aggrieved party may, within the next 14 business days, advise the secretary that the matter is to proceed to mediation.
  • a mediator must then be engaged.
  • mediation must occur within 28 business days of the mediator’s engagement.

An unbiased mediator appointed by the agreement of the parties or by the management committee does not determine the dispute but rather attempts to guide the parties to a mutually acceptable agreement.

If this fails, then the parties may use other legal remedies such as litigating in the Supreme Court.

Disclosure of Remuneration

The Amendment Act inserted a new section 70D into the Associations Incorporation Act to provide for the disclosure of certain details regarding how committee members and senior employees are remunerated.

As a result, management committees will be required to ensure that details of the remuneration or other benefits are disclosed at the association’s annual general meeting. The details of what exactly must be disclosed, and details of the way in which the information is to be presented to the AGM, are to be prescribed in the regulation.

The consultation seeks views on whether the regulations should either:

  • aggregated reporting, where remuneration paid to committee members would be reported as a single lump sum figure, with similar aggregated figures reported for senior staff and relatives, or
  • individualised reporting, where remuneration paid to specific individuals is disclosed.


  • whether the disclosure of benefits should only be required in circumstances where the amount or monetary value of the benefit is over a particular threshold.

New Reporting Thresholds

From 29 July 2022, incorporated associations that are classed as exempt associations and Collections Act organisations that are classed as exempt charities are no longer required to lodge financial statements with the OFT under the Associations Incorporation Act or Collections Act if they fulfil an annual reporting obligation to the Australian Charities and Not-for-Profits Commission (ACNC).

An exempt association is still required to lodge documents with the OFT for changes of name, rules, address, office bearers, or transfer of incorporation to a company. In addition, an exempt association is also required to present to the incorporated association’s AGM the same documents it is required to provide to the ACNC to ensure members are still kept appraised of the association’s financial standing.

The Consultation seeks views on:

  • Whether the annual revenue and current asset thresholds stated in the Associations Incorporation Act should be increased, and if so, what the thresholds should be. The thresholds stated in the Associations Incorporation Act will continue to apply to incorporated associations that are not exempt from reporting to the Queensland Government.
  • Reporting requirements under the Collections Act.
  • Financial documents that all incorporated associations and Collections Act organisations (including those that are exempt from reporting under the Associations Incorporation and Collections Acts) will be required to maintain.

The Consultation Papers

You can access the full papers at the Queensland Government website

Article by:

Latest News

April 18, 2024

A housing trust’s modernisation requires Court approval

Background The Baxter Homes Trust (Trust), was a charitable trust established in Victoria by a deed executed in 1960. Its purpose was to provide aged inhabitants of Geelong Victoria or its neighbourhood with housing as administered by The Geelong and Western District Ladies Benevolent Association’ incorporated under the Hospitals and Charities Act 1890. The Trust A housing trust’s modernisation requires Court approval

Read Article

April 18, 2024

Draft Regulations for NPO Self-Review Assessment Return Released

We have previously written in bulletins about the forthcoming self-assessment tax review for non-profit profit organisations which have an Australian Business Number (ABN) but are not registered as charities with the ACNC – Be alert to being alarmed on viewing your club or society annual report this year and self-assessment by tax-exempt. The background is Draft Regulations for NPO Self-Review Assessment Return Released

Read Article

March 13, 2024

Last of the loopholes? Let’s hope so!

Background All Australian employers will be acutely aware that the Federal government has, since the last election, embarked on a fairly aggressive program of targeted changes to the nation’s industrial relations laws. So far, we’ve had changes aimed at supporting Australia’s jobs and economic recovery[1], gained more respect at work[2], we’ve secured our jobs and Last of the loopholes? Let’s hope so!

Read Article