The External Conduct Standards in Plain English

If your Australian charity sends money, people or resources overseas, these standards may apply to you. There are four of them. Here is what each one means in practice.

They are not optional. The External Conduct Standards (ECS) are legal requirements, and non-compliance can put your charity's registration at risk. Even a single overseas grant can trigger them, so if you are not sure whether they apply to you, check our guide on what counts as operating overseas.

Standard 1. Activities and control of resources

Every dollar sent overseas needs to further your charity's stated purpose, and you need systems to verify that funds actually get there and are spent appropriately. This applies whether you are funding a partner, buying from an overseas supplier, or sending staff and equipment abroad.

Your overseas activities also cannot breach Australian law. Anti-money laundering rules, counter-terrorism financing, the Modern Slavery Act, and the foreign bribery laws that make facilitation payments illegal even where they are locally expected.

In practice, this means checking the DFAT Consolidated Sanctions List before making payments, documenting the charitable purpose of each overseas activity, having written agreements with partners, and reviewing their financial reports regularly.

Standard 2. Annual review and record-keeping

Keep records for seven years, organised by country rather than by project. If the ACNC asks about your work in a specific country, "we work in Africa" is not an answer. See our full guide on what records to keep and how to organise them.

Each year, review whether your overseas activities still align with your charitable purpose, whether your systems for managing funds are working, and whether anything went wrong that needs fixing. This is meant to be a genuine assessment, not a box-ticking exercise.

Standard 3. Anti-fraud and anti-corruption

Corruption, bribery and fraud are more common in some jurisdictions, and Australian charities can be held accountable for the conduct of their overseas staff and partners. At minimum, put dual signatories on payments, track budgets against actuals, verify receipts and invoices, and separate the person who approves a payment from the person who makes it.

Bribery of foreign officials is a criminal offence under Australian law, regardless of local custom, and that includes facilitation payments to speed up routine government services. Keep a conflict of interest register, and see our full guide on protecting charity funds overseas for the detail.

Standard 4. Protection of vulnerable people

This is about safeguarding, not only child protection, though children usually get the most attention. It covers people with disabilities, elderly people, people affected by illness or trauma, displaced people and refugees, and your own staff and volunteers in high-risk environments.

You need a safeguarding policy with a code of conduct, screening for staff who work with vulnerable people, and a complaints mechanism that beneficiaries can actually use, in their own language, without fear of retaliation.

How this relates to the Governance Standards

The ACNC's five Governance Standards apply to every registered charity and cover how your charity is run. The ECS are four additional standards that apply specifically if you operate overseas, and they sit on top of the Governance Standards rather than replacing them.

If you are not compliant

For minor issues, the ACNC will usually work with you to fix them. More serious or repeated non-compliance can lead to formal warnings, enforceable undertakings, or in the worst case, suspension or loss of your charity registration, on top of the reputational damage that comes with any of that.

Where to go for help

The ACNC's own External Conduct Standards guide and self-assessment quiz are good starting points.

If you would rather have someone build the policies and systems with you than work through this alone, that is exactly the kind of compliance work we do. Explore our services or get in touch.