What Records Should Your Charity Keep for Overseas Work?

The simple rule is seven years. The more useful question is what records you actually need to keep and how to organise them so you can find them when the ACNC, a donor or your auditor asks.

External Conduct Standard 2 requires charities to keep records that demonstrate compliance with all four External Conduct Standards, retained for seven years from the date they were created (or the relevant transaction, whichever is later), organised on a country-by-country basis.

What to keep, by category

Financial records. Payment records, receipts and invoices, approved budgets, budget-to-actual reports, partner financial statements and audit documentation, and the exchange rates used for currency conversions.

Operational records. Activity reports, outcome data, meeting minutes on overseas decisions, key correspondence with partners, and site visit notes.

Partner documentation. Due diligence records for each partner, agreements (MOUs, contracts, grants), partner financial and narrative reports, and evidence of partner governance.

Risk and compliance records. Risk assessments, DFAT sanctions screening evidence, conflict of interest declarations, and anti-bribery training records.

Safeguarding records. Policy versions in force, training records, screening and background-check records, and incident reports and investigations.

Annual review documentation. Evidence of your annual ECS review, how overseas operations were reported to the board, and what changed as a result.

Organise it by country, not just by project

If the ACNC asks about your operations in a specific country, "we work in Africa" is not an answer. You need to be able to produce, for each country, a summary of activities, total expenditure, partner names, and the risks you identified and how you managed them. A simple folder structure works well.

Overseas Operations/
├── Cambodia/
│   ├── Partners/
│   ├── Financial Records/
│   ├── Project Reports/
│   └── Incidents/
├── Philippines/
│   └── ...
└── Annual Summaries/

Format and storage

Records need to be in English, or readily translatable into English within a reasonable timeframe if the ACNC requests them. Beyond that, they should be findable, legible over time, complete and logically organised, with reasonable access controls and backups given the sensitivity of some of this information.

If you work through partners

Most charities managing overseas operations remotely rely on partners to generate the bulk of this documentation locally. Your partner agreements should say what records partners must keep, what they must hand over to you, and in what format and how often. Keep version control simple. Date every document clearly, and know which version is current.

Where to go for help

See the ACNC Keeping Charity Records guidance and the ECS Standard 2 Guidance directly.

If your record-keeping is scattered across inboxes and personal drives, that is exactly the kind of thing our operations and compliance work is built to fix. Get in touch and tell us what is not working.