CCA Submissions

CCA Pre-Budget Submission 2019-2020

This submission outlines nine measures the Community Council for Australia (CCA) believes will significantly strengthen Australia’s not-for-profit (NFP) sector and drive real economic savings for government over the coming financial year and beyond.

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Electoral Funding and Disclosure Reform Bill – revised Bill is a good demonstration of how public policy can be improved when the concerns of charities are taken seriously

The Community Council for Australia (CCA) was very concerned about how the original Electoral Reform Bill (2017) would impact thousands of charities who would have faced quite complicated new administrative requirements and restrictions if they chose to make any public statements advocating for their cause or their community. The revised Bill is a good demonstration of how public policy can be improved when the concerns of charities are taken seriously.

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Archived

CCA has long supported ending the multiple application processes involved in DGR and charitable status. Reforming DGR to ensure that most DGR organisations are listed with the ACNC and ending the role of separate registers run at a Departmental level makes good sense, reduces red tape and compliance, increases transparency, and is a sound practical policy initiative. Similarly, the move to streamline the public fund requirements has long been supported across the charities sector. CCA welcomes these proposed reforms. CCA has serious reservations about a number of other proposed reforms and…READ MORE

CCA’s submission outlines key areas of opportunity and concern in relation to the Senate Select Committee Inquiry into Charitable Fundraising.

CCA welcomes the opportunity to engage with the Senate Select Committee on this very important issue.

CCA is a member of the fixfundraising coalition, has liaised extensively with Justice Connect and supports their submission.  Parts of this submission reflect this convergence…READ MORE

This submission outlines key areas of opportunity and concern for the Community Council for Australia (CCA) in relation to the Independent Review of the Australian Public Service (the Review).

CCA welcomes the opportunity to engage with the Review and its work to improve the capability and performance of the Australian Public Service, and is keen to engage in further discussion as the Review’s recommendations are developed and considered…READ MORE

CCA commends the government on pursuing an Open Government agenda.  Greater transparency, participation and accountability in government will drive real improvements in performance and better outcomes for the Australian community.  However, this requires governments to commit to collecting and making public a much higher level of outcome and impact reporting, not just of the services they contract, but of their own performance in achieving government policy goals…READ MORE

CCA generally welcomes the intention of the amendments proposed by Attorney General, Christian Porter – but calls for areas of uncertainty to be resolved –  and remains confused as to why charities pursuing their charitable purpose are not excluded when business groups, non-charitable peak bodies and others are exempt.  The cost to Australia of reducing international collaboration by charities and their engagement in the public policy process would be extremely high.  Ideally the Bill will exclude Australian registered charities engaged in their normal activities and pursuing their…READ MORE

Following CCA’s submission last October and an appearance before the Senate Select Committee on Political Donations, CCA was invited to address questions from the Committee including on the adequacy of current laws governing third parties and their political expenditure; the most appropriate means, if any, of further regulating third party actors to improve the integrity of decision-making; and how additional third party regulation might impact charities to fulfil their purpose under the ACNC Act.

CCA’s submission and supplementary submission highlights the current power imbalance between vested interests that seek political influence for economic gain and charities serving their charitable purpose to strengthen communities.  CCA argues against any further restrictions and compliance burdens for charities – who are already well-regulated in relation to what they can and cannot do in regard to exerting political influence.  Most importantly charities can only advocate to progress their charitable purpose and serve their communities – and Australia is a better place when they do.

Read CCA’s Supplementary Submission in conjunction with CCA’s full submission to the Senate Select Committee into the Influence of Political Donations

CCA also provided evidence to the Inquiry’s public hearing on 6 November 2017. Transcript available here, on the Parliament House website.

CCA’s submission outlines key issues in relation to the past performance and future direction of the Australian Charities and Not-for-profit Commission (ACNC) with a focus on possible legislative changes…READ MORE

CCA’s submission to the Parliamentary Joint Committee on Intelligence and Security (PJCIS) expresses concern at the negative impact of the proposed Foreign Influence Transparence Scheme Bill 2017 on many Australian charities.  Australian charities are well-regulated by the Australian Charities and Not-for-profits Commission (ACNC) and the Bill’s broad ‘catch all’ terms threaten to ensnare many charities going about their normal activities in support of their charitable purpose. CCA, as does the Law Council of Australia, calls for an exemption for charities registered with the ACNC…READ MORE

This submission to the Joint Standing Committee on Electoral Matters outlines key areas of concern for the Community Council for Australia (CCA) in relation to changes to the Electoral Legislation Amendment (Electoral Funding and Disclosure Reform) Bill 2017…READ MORE

CCA’s  submission outlines nine measures the Community Council for Australia (CCA) believes will significantly strengthen Australia’s not-for-profit (NFP) sector and drive real economic savings for government over the coming financial year and beyond.

If Australia is to be a just and fair society where we increase collective ownership of local issues and build flourishing communities, there needs to be a genuine commitment to supporting reforms across the charities and not-for-profit sector from government and other key stakeholders.  This is not about providing more funding to the…READ MORE

The Community Council for Australia (CCA) welcomes the opportunity to provide input into the Review to Achieve Educational Excellence in Australia Schools and is keen to engage in detailed discussion about any proposals arising from the Inquiry. READ MORE…

 

CCA believes the current system of influence and power in national politics often favours the most economically powerful who benefit economically from certain policies.  These policies may or may not be in the broader public interest.  This bias towards the most powerful having more input into public policy is partly facilitated through political donations, but mostly operates outside of the disclosure regimes.

Charities that try and advocate for the benefit of community are often at a major disadvantage against very strong and powerful economic interests. READ MORE…

The Joint Standing Committee on Electoral Matters – Inquiry into and report on all aspects of the conduct of the 2016 Federal Election and matters related thereto – including overseas donations and the role of third parties

CCA’s  submission is based on a Position Paper developed in collaboration with the Australian Council for International Development (ACFID) and Philanthropy Australia. READ MORE…

 

As part of a move to ban foreign donations to political parties, the Government has flagged that it also intends to ban overseas funding to other organisations. The impact of this wider push may mean that registered charities are prevented from accepting international philanthropy.

This position paper has been prepared by a consortia of charities, led by the Australian Council for International Development, Philanthropy Australia and the Community Council for Australia. READ MORE…

 

This Community Council for Australia (CCA) submission briefly outlines some of the key issues for Australia’s not-for-profit sector in response to the Productivity Commission Inquiry Into Introducing Competition And Informed User Choice Into Human Services and the Draft Report May 2017. READ MORE…

 

Begin with what the policy is trying to achieve – what is the goal of DGR concessions?

The goal of the DGR process should be to encourage community involvement, engagement and ownership of issues they are concerned about.  Encouraging civil society to own their issues of concern is not only good public policy, it is very good economic policy.  Governments around the world acknowledge the benefit of community involvement and actively seek to promote philanthropy. READ MORE…

Introduction

This submission outlines five key areas where the Community Council for Australia believes there is scope to support a stronger and more effective impact investing market in Australia. READ MORE…

 

Introduction

This submission outlines five key areas of concern for the Community Council for Australia (CCA) in relation to whistleblower protections and the associated inquiry by the Parliamentary Joint Committee on Corporations and Financial Services.

CCA is particularly interested in the terms of reference relating to the development and implementation of whistleblower protections for the charities and not-for-profit sector (NFPs). READ MORE…

 

This submission outlines nine measures the Community Council for Australia (CCA) believes will significantly strengthen Australia’s not-for-profit (NFP) sector and drive real economic savings for government over the coming financial year and beyond.  These measures have been informed by consultation with CCA members (listed in Attachment A) and key organisations in the NFP sector.  

It is important to note that this submission does not override the policy positions outlined in any individual Federal budget submissions from CCA members. READ MORE…

Introduction

This Community Council for Australia (CCA) submission briefly outlines some of the key issues for Australia’s not-for-profit sector in response to the Productivity Commission Inquiry Into Introducing Competition And Informed User Choice Into Human Services and the associated discussion paper.  It has been prepared with CCA members (see listing of CCA members, Attachment 1) as well as other key organisations working in the broader not-for-profit sector. READ MORE…

 
 

Community Council for Australia: AASB ED 270 Submission, April 2016

Introduction

This submission outlines issues relating to the proposed accounting standards relating to reporting of the performance of charities and not-for-profits. It has been informed by consultation with CCA members (listed in Attachment A) and key organisations in the NFP sector.

It is important to note that this submission does not override the policy positions outlined in any individual submissions from CCA members. READ MORE…

 

Submission to:

Assistant Treasurer The Hon. Kelly O’Dwyer

Private Ancillary Fund (PAF) and Public Ancillary Fund (PuAF) Amendment Guidelines 2015

February 2016

Introduction. READ MORE…

 

This submission outlines nine measures the Community Council for Australia (CCA) believes will significantly strengthen Australia’s not-for-profit (NFP) sector and drive real economic savings for government over the coming financial year and beyond. READ MORE…

CCA’s submission to The Treasury in response to Exposure Draft Legislation limiting Fringe Benefit Tax Concessions for Salary Packaged Entertainment Expenses affecting employees of public benevolent institutions, health promotion charities, public and not-for-profit hospitals and public ambulance services. READ MORE…

 

CCA Submission in response to the Re:think – Tax discussion paper: Better tax system, better Australia. READ MORE…

 

Submission on the Competition Policy Review’s recommendations for Australia’s Competition and Consumer Policy 2010. READ MORE…

 

CCA is concerned that this inquiry seeks to confuse the established definition of charity by bringing into question one particular area of charitable endeavour, seeking to use activity rather than purpose in determining organisational status, and potentially adding more complexity to an onerous process that serves little purpose in terms of delivering real community benefits. READ MORE…

 

Joint Committee of Public Accounts and Audit Inquiry into the Development of Commonwealth Performance Framework. READ MORE…

 

Submission into the impact on service quality, efficiency and sustainability of recent Commonwealth Indigenous Advancement Strategy tendering processes by the Department of the Prime Minister and Cabinet. READ MORE…

 

CCA’s submission to the Senate Inquiry into the Commonwealth community service tendering processes by DSS focuses on the opportunity to mature the Government’s approach to tendering – across the Department of Socail Services and all federal departments and agencies. READ MORE…

 

This submission promotes Federal Government measures to strengthen the not for profit sector that deliver real economic and social benefits for governments and our communities. With six proposals, CCA asks for a commitment of only $2.4 million over three years that will significantly increase the sector’s efficiency, effectiveness and sustainability. READ MORE…

This submission briefly summarises the CCA policy position in relation to the Productivity Commission Draft Report on Childcare and Early Childhood Learning.

CCA has not focused on many of the issues relating to Childcare and Early Childhood Learning. This submission is really about how the Productivity Commission Draft Report may impact on charities and not-for-profit organisations across Australia. READ MORE…

 

This outlines Community Council for Australia’s (CCA) response to the Options Paper on proposed replacement arrangements for charities if the Australian Charities and Not-for-profits Commission (ACNC) is disbanded.

This is CCA’s fifth submission in relation to the establishment of the ACNC.  It is important to note that this response has been prepared in consultation with the membership of CCA  and key organisations in the not-for-profit sector. READ MORE...

 

In response to the Treasury’s Discussion Paper on Unclaimed Funds, Community Council for Australia provided a submission to Treasury and met with Treasury Officials to advocate for the diversion of unclaimed moneys into a capital fund that supports viable investment options in the not-for-profit sector. This addiional capital pool for the not-for-profit sector will deliver real economic and social benefits for governments and our communities in the longer term. READ MORE…

 

Retain the ACNC to build sector transparency and efficiency

This submission outlines the Community Council for Australia (CCA) response to the Australian Charities and Not-for-profits Commission Repeal Bill 2014.  This is the fourth submission by CCA in relation to the establishment of the Australian Charities and Not-for-profit Commission (ACNC).  CCA has also appeared before the Senate Economics Committee, Joint Committee on Corporations and Financial Services, and the Senate Community Affairs Committee to give evidence on Bills relating to the ACNC. READ MORE…

This is the third submission on this legislation that has been prepared with the members of the Community Council for Australia (Attachment 2) as well as other key organisations in the not-for-profit sector, academics, lawyers, government officials, and key policy advisors. READ MORE…

Open Letter to Government: Civil Society Support for Independent Regulator – 18 March 2014

RE: Civil Society Support for Independent Regulator

See Media Release here.

Dear Prime Minister

We want to make it very clear to the Commonwealth Government and wider community that like most charities across Australia, we value the Australian Charities and Not-for-Profits Commission, and we want to see it continue its impressive work.

Charities and the broader not-for-profit sector are at the heart of Australian communities.  They are there in the good times and bad.  They provide support to the most vulnerable; lift our sights and our hearts through culture, sport, education, welfare, support for the aged or the unwell; promote our spirituality; protect our animals and our environment; play our part internationally, and ensure those less able can still participate. READ MORE…

Effective financial systems for the not for profit sector and the community

This submission promotes discussion about financial system issues that are impacting across the NFP sector now and into the future. Addressing some of these issues will deliver real economic and social benefits for governments and our communities in the longer term. READ MORE…

 

$35 Million Plan to Strengthen the NFP Sector

Informed by expert consultation with members, CCA’s pre-budget submission outlines seven measures to drive real economic savings for Government, whilst simultaneously strengthening Australia’s not-for-profit sector. READ MORE…

 

Time for a Real Relationship Reform

CCA’s submission focused on the need for the Prime Minister’s Business and Community Partnership (CBP) to be much more than a talk fest and become a vehicle to enhance relations between not-for-profit entities, their communities, government and businesses. READ MORE…

Government Audit Must Engage with NFP Sector

This submission addresses key issues outlined in the terms of reference for the NCA and the implications of the work of the NCA for the charities and not-for-profit sector. READ MORE…

Prime Minister’s Business and Community Partnership – 27 Nov 2013 -Time for Real Relationship Reform

CCA’s submission focused on the need for the Prime Minister’s Business and Community Partnership (CBP) to be much more than a talk fest and become a vehicle to enhance relations between not-for-profit entities, their communities, government and businesses.

The submission proposed the CBP do this through prioritizing the following areas:

  1. Increasing both the level and effectiveness of investment in the Not for Profit sector with a particular focus on philanthropy and the relationship between Not for Profit organisations, business, community and government;
  2.  Increasing knowledge and awareness of the value of investing in the Not for Profit sector with a strong focus on impact and benefits including better measurement and reporting of investment outcomes;
  3.  Increasing the level of collaboration between Not for Profit organisations and across communities including business, particular populations groups, organisations and government.

Pro Bono’s coverage of CCA’s submission is available here. READ MORE…

CCA has made a submission calling for the purpose of the new definition of charity to be outlined as objects of the proposed legislation.

This submission briefly outlines some of the key issues for Australia’s not-for-profit sector in response to the release by Treasury of the ‘Exposure Draft Charities Bill 2013’, a bill seeking to establish a statutory definition of charity. READ MORE…

Introduction

This submission briefly outlines the Community Council for Australia (CCA) response to the COAG Regulatory Impact Assessment of potential duplication of governance and reporting standards for charities (RIA) consultation paper.

The CCA Board and members believe the issue of duplication in regulatory requirements for charities and more broadly for the not-for-profit (NFP) sector is a critical issue. READ MORE…

This submission outlines eight measures the Community Council for Australia (CCA) believes will significantly strengthen Australia’s not-for-profit (NFP) sector and drive real economic savings for government over the coming financial year and beyond.  It has been prepared through consultation with the membership of the CCA (see Attachment 1 for a listing of CCA members) and key organisations in the NFP sector. It also draws on recommendations from previous CCA submissions. READ MORE…

Manager Philanthropy and Exemptions Unit Indirect, Philanthropy and Resource Tax Division The Treasury Langton Crescent PARKES ACT 2600

Dear Sir or Madam

CCA has reviewed the proposed requirements for annual financial reports under the Australian Charities and Not-for-profit Commission (ACNC) and broadly endorses the approach outlined. READ MORE…

This submission briefly outlines the Community Council for Australia (CCA) response to the Development of Governance Standards Consultation Paper published in December 2012 by The Treasury.

The CCA Board and members believe the issue of effective governance in not-for-profit (NFP) organisations is a critical issue. READ MORE…

 

This submission briefly outlines the Community Council for Australia (CCA) response to the Corporations and Markets Advisory Committee review of Trusts and Trustee Companies. READ MORE…

 

This submission briefly outlines the Community Council for Australia (CCA) response to the Not-for-profit Sector Tax Concessions Working Group discussion paper.

It is important to note that this submission has been prepared through a process of consultation with the membership of the CCA (see Appendix 1 list of CCA members) and key organisations in the not-for-profit (NFP) sector. This submission does not over-ride any positions outlined in individual submissions from CCA members. READ MORE…

 

Attached is CCA’s joint submission to the the Senate Standing Committee on Community Affairs and the Parliamentary Joint Committee (PJC) on Corporations and Financial Services on the ACNC Bills 2012 and the Tax Laws Amendment (Special Conditions for not-for-profit concessions) Bill 2012. CCA will appear at the hearings for both Committee’s Inquiries. READ MORE…

 

This submission briefly outlines the CCA response to the Exposure Draft Bills establishing the Australian Charities and Not-for-profit Commission (ACNC). This submission does not attempt to address every aspect of the proposed ACNC Bills but seeks to place the Bills within a broader context and address key issues from both the Bills and the Explanatory Materials. READ MORE…

Overview of key issues

Support for reform

CCA strongly supports the overall directions for CFAR reform of the Commonwealth Financial Framework as outlined in the CFAR Discussion Paper. 

‘The financial Framework should support government operations to create public value.  It should promote the efficient and effective achievement of outcomes and provide for high levels of transparency and accountability.’                        (Chapter 4, Directions for reform pg. 19). READ MORE…

 

Executive summary

CCA supports the apparent policy intent of the draft legislation that is to ensure income tax exempt entities generally must be operated principally in Australia and for the broad benefit of the Australian community.  Likewise, deductible gift recipients (DGRs) generally must be operated solely in Australia and for the broad benefit of the Australian community. READ MORE…

 

Informing principles for new fundraising regulation. READ MORE…

 

Recommendations

  1. NFP reform agenda

1.1 The ACNC must be enabled to operate independently and reduce the compliance burden on NFPs through more effective regulation and referral of information and powers from the many local, State and Federal bodies imposing regulatory burdens on NFPs. READ MORE…

 

Submission to the Treasury – A Definition of Charity – December 2011

Introduction

This submission briefly outlines some of the key issues for Australia’s not-for-profit sector in response to the release by Treasury of a consultation paper on a definition of charity for the purposes of Commonwealth laws. READ MORE…

 

Submission to The Treasury – Restating the ‘in Australia’ special conditions for tax concession entities – August 2011

Introduction

This submission briefly outlines some of the key issues for Australia’s not-for-profit sector in response to the release by Treasury of draft legislation that will restate the ‘in Australia’ special conditions for tax concession entities. READ MORE…

 

Submission to The Treasury – Better targeting of not-for-profit tax concessions – July 2011

Introduction

This submission briefly outlines key issues for Australia’s not-for-profit sector (NFPs) in response to The Treasury Consultation Paper of 27 May 2011 ‘Better targeting of not-for-profit tax concessions’. READ MORE…

 

Submission to the Senate Economics References Committee – Inquiry into Finance for Social Organisations – June 2011

Introduction

This brief submission provides a summary of discussions and consultations CCA has had with not-for-profit organisations, a number of key finance sector organisations, government officials and investors in the not-for-profit sector.  The submission should be read as a collation of views rather than a formal CCA policy position statement. READ MORE…

 

Introduction

This submission briefly outlines a response to the consultation paper: Scoping study for a national not-for-profit regulator.  It has been prepared through a process of consultation with the membership of the Community Council for Australia (see Appendix 1 list of CCA members) and key organisations in the not-for-profit sector. READ MORE…

 

Submission to the Assistant Treasurer

Introduction

This submission briefly outlines key issues for Australia’s not-for-profit sector (NFPs) over the coming financial year and provides a summary of the emerging budget implications for government and the NFP sector.  It has been prepared through a process of consultation with membership of the Community Council for Australia (see Appendix 1 listing of CCA members) and key organisations in the not-for-profit sector. READ MORE..

 

The Community Council for Australia commends the Assistant Treasurer for initiating this consultation and providing the Public Ancillary Funds discussion paper ‘Improving the integrity of public ancillary funds’.

This submission has been prepared through a process of consultation with the membership of the Community Council for Australia, other key organisations in the not for profit sector and a number of key stakeholders in the finance and philanthropy sectors. READ MORE…