CA ANZ has responded to Treasury’s Exposure Draft: Corporations Amendment (Proprietary Company Thresholds) Regulations 2026 which proposes doubling the monetary thresholds used to determine whether a proprietary company is large. Our submission supports proportionate reporting obligations and does not oppose an increase but calls for a published impact assessment and further consultation before the scale of the uplift is settled. We also note the highly compressed consultation period creates a significant risk that material issues will be overlooked, and key stakeholders will miss the opportunity to provide feedback. In preparing our submission, we drew on feedback from our 2026 Chartered Accountants’ IFRS Survey.

We make the following recommendations:

1. Do not finalise the proposed doubling of the thresholds until Treasury has assessed and consulted on the affected mid-market population and the wider economic and stakeholder impacts.
2. Publish the evidence and modelling supporting the selected revenue and asset thresholds, including the expected number, industries and risk characteristics of entities that would cease to prepare, have audited and lodge financial reports.
3. Test the proposed doubling of the thresholds against economic growth and alternative settings, including a 1.5 times uplift, rather than treating a doubling as the default.
4. Assess financial reporting and sustainability reporting thresholds separately against their distinct policy purposes, supported by a clear rationale for any alignment or divergence.
5. Provide an appropriate transition period and commit to periodic, evidence-based review or indexation so future changes are more incremental and predictable.