Know exactly where your charity stands on its overseas obligations and exactly what to do about it.
The External Conduct Standards apply to all ACNC registered charities, including Basic Religious Charities, that operate outside Australia. GovernApp's three-tier ECS frameworks help charities assess those obligations in a practical way that scales by risk and operational complexity.
The ACNC applies the External Conduct Standards broadly to charities that operate outside Australia, including where overseas engagement is only one part of overall operations.
The Standards are principles-based and require reasonable steps, but smaller charities are often left with limited practical guidance on what proportionate compliance should look like in day-to-day governance.
GovernApp's three-tier ECS framework removes guesswork by giving boards a clear way to choose an appropriate assessment depth and action pathway.
GovernApp deconstructs all four External Conduct Standards into practical sections so organisations can assess and act with the right level of proportional control.
Standard 1 focuses on ensuring a charity's overseas resources are used for charitable purposes with reasonable controls and legal compliance.
Decision-making
Examines whether your charity's governance and decision-making processes adequately control how overseas activities are initiated, approved, and reviewed.
Staff and volunteer engagement
Examines whether your charity's people are recruited, inducted, trained, and supervised to a standard that supports compliant overseas operations.
Beneficiary focus
Examines whether your charity maintains active oversight of whether overseas activities are genuinely and appropriately serving intended beneficiaries.
Monitoring overseas activities
Examines whether your charity actively monitors its overseas projects and programs.
Resource monitoring overseas
Examines whether your charity maintains adequate oversight of equipment and other resources used or stored outside Australia.
Identifying wrongdoing
Examines whether your charity has adequate mechanisms to detect and respond to financial wrongdoing in overseas operations.
Engaging third parties
Examines whether your charity has adequate due diligence and controls in place when selecting and contracting overseas third parties.
Overseeing third parties
Examines whether your charity actively maintains oversight of overseas third parties once engaged.
Legal compliance
Examines whether your charity meets relevant Australian legal obligations for overseas operations, including AML/CTF, anti-corruption, modern slavery, and related staff training.
Standard 2 requires clear, complete records of overseas activities and expenditure, including country-by-country reporting capability.
Country-by-country records
Examines records of activities conducted outside Australia, overseas expenditure tracking, and documentation around decision-making.
Record-keeping systems
Examines privacy and confidentiality controls, records management policy, and records retention practices.
Standard 3 requires reasonable steps to prevent and manage corruption, fraud, bribery, and other financial misconduct risks.
Preventing financial misconduct
Addresses fraud and corruption risks, communication of financial management policies, supervision of money handling, and financial delegations.
Detecting fraud or other financial misconduct
Assesses detection capability through regular financial reviews, training, whistleblower processes, and reporting/action on suspected cases.
Standard 4 requires reasonable safeguards for vulnerable people in overseas contexts, including beneficiaries, staff, and volunteers.
Commitment to protecting vulnerable individuals
Tests safeguarding and child protection policies, plus codes of conduct that apply to overseas operations.
Recruitment, suitability, and training
Examines whether people working with vulnerable individuals overseas are appropriately screened, qualified, and trained.
Complaints, concerns, and incident management
Examines whether your charity has safe and accessible channels for reporting concerns in overseas contexts.
Legal and regulatory compliance
Examines whether your charity understands and meets safeguarding obligations under Australian and host-country law.
We have minimal or occasional overseas activity
Start with Tier 1: Limited Exposure
A proportionate starting point for charities with genuinely limited offshore activity and lower complexity.
We regularly partner, fund, or operate overseas
Start with Tier 2: Moderate Engagement
Designed for organisations needing structured due diligence, documented controls, and routine oversight.
We run significant or high-risk overseas operations
Start with Tier 3: Extensive Operations
Built for large-scale programs where independent assurance and continuous compliance monitoring are essential.
| Criteria | Tier 1: Limited Exposure | Tier 2: Moderate Engagement | Tier 3: Extensive Operations |
|---|---|---|---|
| Best suited to | Minimal or occasional international activity | Regular overseas partnerships or programs | Significant overseas programs, staff, or supply chains |
| Overseas activity profile | Small transfers, short-term visits, low operational complexity | Ongoing funding and delivery with recurring overseas touchpoints | Large-scale, complex, or high-risk international operations |
| Governance controls | Basic policy controls and oversight | Structured due diligence and documented controls | High-level governance systems and continuous monitoring |
| Risk expectations | Proportionate baseline controls for limited exposure | Documented risk assessment and active oversight | Independent assurance and deeper control architecture |
Tier 1: Limited Exposure
Tier 2: Moderate Engagement
Tier 3: Extensive Operations
A colour-coded compliance profile across all four External Conduct Standards (Green / Amber / Red / Black)
A full assessment report explaining your results in the context of the ACNC's ECS obligations
A risk-prioritised action plan with model solutions and template documents to close identified gaps
Please note: The ECS assessment is designed to help your charity take meaningful, structured steps toward compliance. Because the ACNC applies a principles-based proportionality model, results indicate likely compliance posture and do not constitute legal advice or a guarantee of regulatory compliance.
Choose the tier that matches your exposure and get a practical, risk-prioritised action pathway.
ACNC ECS aligned assessment model
Tiered proportional compliance approach
Board-ready reporting and action plans
Practical templates for identified gaps
Ready to start your ECS assessment?
Begin with the tier that matches your current overseas activity profile.