Date posted: 30/09/2022

Joint submission on Tier 3 and 4 Not for Profit and Public Sector Reporting Consultation

Amendments proposed in response to post-implementation review

In 2020 the XRB performed a post-implementation review of the reporting requirements for Tier 3 and Tier 4 not-for-profit (NFP) and public sector (PS) entities. The feedback the XRB received highlighted that overall, the four standards are working well and are achieving their desired objectives. However, there were some key areas identified where improvements could be made. The XRB has now released exposure drafts of the revised standards written in plain English – the length of which has been reduced significantly.

CA ANZ’s joint submission with CPA Australia is largely supportive of the proposed amendments, except for the following two areas:

  • The introduction of reduced reporting requirements for “small” Tier 4 entities (total annual payments of less than $10,000 for the current and previous financial years). We believe that the other proposed amendments, especially the removal of the statement of resources and commitments, sufficiently reduces and simplifies the reporting requirements for all Tier 4 entities.  
  • The recognition of the effect of any transactions (other than transactions with owners) directly in accumulated funds. We suggest such transactions be presented below “operating surplus/(deficit)” in the statement of financial performance, thus separating these transactions from other revenue and expenses.  

Our submission also suggests several other improvements that we heard during our outreach with members.

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