Awake at night ... again
Posted on 12 Nov 2025
Managing a charity or not-for-profit in Australia is often more complex than it may appear. On any…
Posted on 20 Mar 2024
By Greg Thom, journalist, Institute of Community Directors Australia
The ability of charities to manage cyber security threats will be a key focus of the Australian Charities and Not-for-Profits Commission’s approach to compliance and enforcement over the coming year.
ACNC commissioner Sue Woodward described cyber security as a “key governance risk for charities”.
“In our reviews we work with charities to better understand how they protect themselves from cyber risks and manage cyber security incidents.”

Ms Woodward said the regulator would consider three key questions when assessing the challenges faced by charities relating to cyber security:
Ms Woodward’s comments follow several high-profile cyber security breaches involving the charity sector in 2023.
One of the largest related to Brisbane-based telemarketer Pareto Phone, which was the victim of a ransomware attack that affected more than 70 Australian and New Zealand charities.
The incident resulted in the details of tens of thousands of donors to charities including WWF Australia, the Australian Conservation Foundation and Plan International being splashed across the dark web.
“At the rarer and more extreme end, we are concerned about entities that may deliberately use complex corporate structures to try and obscure illegal activities.”
Ms Woodward said there were some matters considered so detrimental they would always be an enforcement priority for the regulator, including:
Speaking at the Australian Governance Summit in Melbourne, Ms Woodward outlined the ACNC compliance and enforcement focus for 2024–2025.
High on the list was increasing concern about charities’ misuse of complex corporate structures to conceal non-compliance with the ACNC Act and Regulations.
The ACNC was particularly concerned about organisations deliberately using complexity as a cover for wrongdoing.
“At the rarer and more extreme end, we are concerned about entities that may deliberately use complex corporate structures to try and obscure illegal activities.”
“We will … continue to refer matters to other appropriate government agencies when we have concerns about suspected breaches of other laws,” she said.
Ms Woodward said charities were free to use a variety of structures to suit their purpose and the regulator acknowledged there can be legitimate reasons to do so.
However, the decision to use complex structures, or the gradual and perhaps ad hoc development of complex structures, also came with more complex governance obligations.
“While many charities are well advised and adhere to robust compliance regimes, there are others which may not appreciate that complex structures bring associated governance complexity and risk,” said Ms Woodward.
“Inadvertent non-compliance is more likely because there may not be clear delineation in the oversight of each entity, including the required focus on each charity’s particular charitable purpose.”
Posted on 12 Nov 2025
Managing a charity or not-for-profit in Australia is often more complex than it may appear. On any…
Posted on 12 Nov 2025
At the Institute of Community Directors Australia, we believe that stronger communities make a…
Posted on 12 Nov 2025
Like many Community Directors members, Hazel Westbury is a community leader who isn’t easily…
Posted on 11 Nov 2025
Australian charities are curious about how to use artificial intelligence and are increasingly…
Posted on 11 Nov 2025
Thousands of not-for-profit organisations are being held back by an outdated, rigid and complicated…
Posted on 11 Nov 2025
A new Understanding, Measurement, Evaluation and Learning (UMEL) digital platform that allows…
Posted on 11 Nov 2025
New grants worth $36 million aim to help farmers and farming communities prepare for drought by…
Posted on 11 Nov 2025
Project Manta, a long-running scientific study that includes a citizen scientist component, is…
Posted on 11 Nov 2025
I’ve seen what happens when fear of conflict wins out over taking a principled stand.
Posted on 11 Nov 2025
‘It’s not a question of enough, pal. It’s a zero-sum game. Somebody wins and somebody loses’.
Posted on 11 Nov 2025
Progressive economic Richard Denniss believes the constant hunt by governments for the political…
Posted on 10 Nov 2025
In an increasingly polarised and uncertain world, Radical Moderates must have the values to know…