What Are the ACNC External Conduct Standards?
Last updated: 25 October 2026.
If your charity sends money, goods or volunteers overseas, even occasionally, the ACNC External Conduct Standards apply to you. Many small charities do not realise this, because they think of the standards as a requirement for large aid agencies. The ACNC says otherwise.
This guide gives an overview of who the standards apply to, what each of the four standards requires, how the ACNC regulates them and the practical evidence to keep. Everything is taken from the ACNC’s External Conduct Standards pages (checked 25 October 2026). It is general information, not legal advice. For the detailed obligations, read the ACNC’s own guidance and use its self-evaluation tool.
The short version: the standards are principles-based. They require “reasonable steps” on four things: controlling overseas activities and resources, keeping records country by country, preventing fraud and corruption, and protecting vulnerable people. You do not submit anything to the ACNC, but you must be able to show evidence if asked.
Who must comply
All registered charities that operate outside Australia must comply, including Basic Religious Charities (even though those charities are not subject to the Governance Standards). The ACNC is clear that “operate outside Australia” is not limited to major programs. A charity is generally considered to operate outside Australia:
- even if overseas activities are only a minor part of its work
- even if it only sends a small amount of money overseas, and
- even when the activities are carried out through a third party.
Charities that do not operate outside Australia are not subject to the External Conduct Standards, but still must meet the Governance Standards. The External Conduct Standards apply in addition to the Governance Standards. Like them, they are principles-based, setting reasonable levels of oversight rather than prescribing specific steps.
The four standards
Standard 1: Activities and control of resources
A charity must take reasonable steps to ensure its overseas activities are consistent with its purpose and character as a not-for-profit, and maintain reasonable internal controls so funds, equipment, supplies and other resources are used consistently with that purpose. That includes resources provided to third parties for use overseas. Charities must also comply with Australian laws on money laundering, financing of terrorism, sexual offences against children, slavery, trafficking and debt bondage, people smuggling, international sanctions, taxation and bribery, and maintain reasonable internal control procedures to ensure that compliance.
The ACNC lists the risks this is designed to manage: funds being stolen or misappropriated, benefits going to people who do not qualify as beneficiaries, funds inadvertently financing terrorism or other crime, funds used for other purposes, partners not using funds appropriately and illegitimate donors using the charity for money laundering or tax avoidance.
Standard 2: Annual review of overseas activities and record-keeping
A charity must obtain and keep records for its overseas operations, including activities it runs itself or with a third party and funds it sends overseas. Records must allow the charity to prepare a summary of its overseas activities and related spending country by country. The ACNC says a charity is likely to meet the standard if its records show:
- the types of activities in each country
- how those activities helped it achieve its purpose
- all expenditure for overseas activities in each country
- the procedures it used to monitor overseas operations
- a list of the third parties it worked with
- any documented claims of inappropriate behaviour by employees or Responsible People overseas, and the actions taken.
Records should be complete, accurate, legible, timely, kept in English or a form easily translated, stored safely and kept for at least seven years. The ACNC does not require you to send the records in, but may request them in an enquiry or investigation. Our guide to records a charity should keep when sending money overseas covers this in practice.
Standard 3: Anti-fraud and anti-corruption
A charity must take reasonable steps to minimise the risk of corruption, fraud, bribery or other financial impropriety by its Responsible People, employees, volunteers and third parties outside Australia, and identify and document perceived or actual material conflicts of interest. The ACNC says the standard does not require charities to avoid every conflict, which can be unavoidable in small communities. The point is to identify, document and manage them so they do not affect decisions.
Standard 4: Protection of vulnerable individuals
A charity must take reasonable steps to ensure the safety of vulnerable individuals overseas, whether they receive services under its programs or are engaged to provide services for it or its partners. “Vulnerable” covers people under 18 and anyone who may be unable to take care of or protect themselves from harm or exploitation, including the charity’s own workers and volunteers. The ACNC does not prescribe the steps. It expects a charity to identify and assess the risks, develop a plan, and apply stronger measures where it has more contact with vulnerable people, such as overseas volunteering and child sponsorship.
How the ACNC regulates the standards
- You do not submit anything to the ACNC to show you comply, but must be able to give evidence if asked.
- The ACNC expects most charities to comply and focuses on charities that have seriously or deliberately breached the standards.
- It asks organisations applying for registration, or for new subtypes, what steps they have taken to comply if they operate overseas.
- It offers a self-evaluation tool for charities operating overseas.
A practical evidence checklist
| Standard | Evidence to have ready |
|---|---|
| 1. Control of resources | Board-approved overseas funding policy, written agreements with partners, payment approvals, evidence funds were used as agreed |
| 2. Records | Country-by-country activity and expenditure summary, partner list, bank and transfer records, monitoring reports, 7-year retention |
| 3. Fraud and corruption | Anti-fraud and conflict of interest policies, register of interests, due diligence on partners, incident log |
| 4. Vulnerable people | Risk assessment, child safeguarding or protection policy where relevant, screening and training records, complaints process |
This table is our practical suggestion, not an ACNC checklist. The ACNC says the right steps depend on each charity’s circumstances.
What the finance side looks like
Standards 1 and 2 depend on good bookkeeping. A charity that tracks overseas spending by country and by partner in its accounts can produce the summary in an afternoon. A charity that mixes overseas transfers with general expenses will struggle. Practical steps:
- Use tracking categories or separate accounts for each country and, where relevant, partner.
- Keep the transfer confirmation, agreement and partner report together for each payment.
- Reconcile the overseas accounts monthly and report on them to the board.
- Review the setup annually when preparing the Annual Information Statement. See our 2026 AIS checklist.
Before funding a new partner, see our checklist for checks before funding an overseas partner.
How we help
We help Sydney charities and NFPs set up bookkeeping that tracks overseas spending by country and partner and keeps transfer records in order, so evidence is ready if the ACNC asks. We are not auditors or legal advisers, so policy wording and risk assessments belong with your board and its advisers. See our charities and NFPs page, bookkeeping services and services, or try our free Charity Health Check. You can also email info@guidancegrowth.com.au or use our contact page.
Frequently asked questions
What are the ACNC External Conduct Standards?
Four principles-based standards for registered charities that operate outside Australia: activities and control of resources, annual review and record-keeping, anti-fraud and anti-corruption, and protection of vulnerable individuals.
Does my small charity have to comply if we only send a little money overseas?
Yes. The ACNC says a charity is generally considered to operate outside Australia even if the activities are a minor part of its work, or it only sends a small amount of money overseas, including through a third party.
Do Basic Religious Charities have to comply?
Yes, if they operate outside Australia, even though they do not have to comply with the ACNC Governance Standards.
Do I have to submit anything to the ACNC to show compliance?
No, but you must be able to provide evidence if asked, and the ACNC asks organisations applying for registration about their steps to comply.
How long must overseas records be kept?
The ACNC says records for overseas operations should be kept for at least seven years, and be complete, accurate, legible, timely and kept in English or an easily translated form.
Is there a tool to check whether we comply?
Yes. The ACNC has a self-evaluation tool for charities operating overseas.
Sources and further reading
- ACNC: External Conduct Standards (checked 25 October 2026)
- ACNC: External Conduct Standard 1 (checked 25 October 2026)
- ACNC: External Conduct Standard 2 (checked 25 October 2026)
- ACNC: External Conduct Standard 3 (checked 25 October 2026)
- ACNC: External Conduct Standard 4 (checked 25 October 2026)
This article is general information, not personal advice. Rules and dates can change, so check ato.gov.au or acnc.gov.au for the latest, or speak to us about your situation.