Meeting Compliance


How can we make a basic assessment of the potential compliance work required for a particular overseas activity?

The ACNC understand that charities operate for a specific charitable purpose. For a church missions’ program, we are often driven to see positive, holistic, sustainable change take place in the lives of individuals and communities overseas. We have a desired change goal, which we want to see occur in people’s lives. Often this is a combination of spiritual change, social change as well as changes to their physical circumstances.

The ACNC guidance materials advocate for charities to take a risk-based approach in regard to their overseas activities. This means you need to first identify and understand those risks, before you can evaluate and document an appropriate response.

We have developed an online Due Diligence Self-Assessment Tool, to help you make an initial basic assessment of the compliance work that might be required for a particular overseas activity.


So how do you suggest that a church should approach its compliance with the External Conduct Standards?

If you are supporting overseas activities through ACCI Missions or ACCI Relief, then try our Due Diligence Self-Assessment Tool to see how we can reduce your church’s compliance burden. 

If you are not working through ACCI or another ACNC Registered Charity, then we suggest that you consider working through these steps:

  1. Overseas Activity
    • Detailed Activity Assessment (including change goal, methods, motives and good principles)
    • Identify High Risk Activity Flags (including vulnerable people, specialist skills, legal/regulatory requirements and inherently high risk)
    • Activity Risk Mitigation (including sound policies and procedures, good practices standards, codes of conduct, technical skills, training or experience, legal structures and appropriate registrations, oversight bodies and external accountability and reporting)
  2. Implementing Organisation (or Individuals)
    • Partner Alignment, Compatibility and Reputation
    • Legal Structure (including legal status, registrations, governance, accountability, oversight, in-country teams, partners)
    • Organisational and Technical Capacity
    • Financial Controls and Systems
    • Policies and Safeguarding (including children and other vulnerable persons)
  3. Your Church Involvement
    • Your Contribution (including funding, people, equipment and other resources)
    • Your Financial Controls, Systems and Processes
    • Your Policies and Procedures (including HR, child safeguarding, conflicts of interest, counter terrorism, complaints handling and whistleblowers)
  4. Partnership Plan
    • Written Agreement (clearly setting out roles and responsibilities)
    • Document Overseas Activities
    • Budget and Funding/Resource Commitments
    • Risk Management Plan (addressing the overseas activity risks, implementing organisation risks and your involvement risks)
  5. Implementation
    • Progress Reporting (which you require from the implementer)
    • Monitoring and Evaluation (including an annual review of overseas activities and partnership plan)
    • Your Record Keeping (paying special attention to the Standard 2 requirements)

So the end result will hopefully be that your church missions program has participated in a meaningful overseas activity, which has made a positive impact in people’s lives. But it should also mean that you have been able to comply with the External Conduct Standards in the following ways:

Standard 1: Activities and control of resources (including funds). The plan above documents your sound approach to complying with the control of your resources in regards to the overseas activity.

Standard 2: Annual review of overseas activities and record-keeping. The need to keep sufficiently detailed records of your overseas activities has been factored into your implementation.

Standard 3: Anti-fraud and anti-corruption. This has been addressed through your review of the implementing organisation, your own policies and procedures, the progress reporting and annual review.

Standard 4: Protection of vulnerable individuals. The activity risk review should identify up front the degree to which vulnerable individuals may be involved in this activity. Ongoing compliance by the implementor and your own church with the appropriate safeguarding policies will be required. Any other appropriate responses should be specifically documented as part of your risk management plan and reviewed as part of your annual review (at a minimum).


Does ACCI have an External Conduct Standards Compliance Declaration?

ACC International Missions Ltd
ABN 66 077 367 223

ACC International Missions is an accredited member of Missions Interlink and operates in compliance with Missions Interlink Statements and Accreditation Standards.

ACC International Missions has in place existing policies and procedures that will ensure our compliance with all four of the ACNC external conduct standards, specifically:

  1. Activities and control of resources (including funds)
  2. Annual review of overseas activities and record keeping
  3. Anti-fraud and anti-corruption
  4. Protection of vulnerable individuals

ACC International Missions is already positioned to more than meet the requirements of the ACNC external conduct standards.


ACC International Relief Inc
ABN 26 077 365 434

ACC International Relief is a member of the Australian Council for International Development (ACFID) and has been a signatory to the ACFID Code of Conduct since 2006. The ACFID Code of Conduct (the Code) is a voluntary, self-regulatory industry code of good practice. The aim of the Code is to improve the outcomes of international development and increase stakeholder trust by enhancing the transparency and accountability of signatory organisations.

You can read more about the Code here.  To see how the ACFID Code compliance lines up with the External Conduct Standards click here

ACFID’s members already comply with the ACFID Code and undertake annual reporting and continuous internal governance and compliance work to uphold our own rigorous self-regulatory Code. In choosing to regulate ourselves, ACFID’s members choose to pursue compliance with a standard that is much higher than government regulation.

The enactment of the external conduct standards will not impact our current standard of work as the requirements of these new ACNC minimum standards are already extensively covered through our compliance with the ACFID Code.

ACC International Relief is already positioned to meet and exceed the ACNC external conduct standards through our ongoing compliance with the ACFID Code of Conduct.


Where can I find your Due Diligence Self-Assessment Tool?

We have developed an online Due Diligence Self-Assessment Tool, to help you make an initial basic assessment of the compliance work that might be required for a particular overseas activity.

We are in the process of updating our due diligence guidelines and checklist for those assessing their partnerships with overseas organisations but you can find our previous version here