JobKeeper, ASIC reviews, restatements and charity thresholds

JobKeeper notices, ASIC’s recent review of financial reports, restatements, and new reporting thresholds for charities. These are among the key regulatory activities that Australian financial reporters should understand in December 2021.

ASIC and JobKeeper notices

The Corporations Act 2001 has been amended to require all listed entities that received JobKeeper payments to give a notice to the relevant market operator (e.g., ASX) outlining:

  • the listed entity’s name and ABN,
  • the number of individuals for whom the entity or its subsidiaries received JobKeeper payments each fortnight that ended in the financial year,
  • the total amount of JobKeeper payments the entity and its subsidiaries received in a JobKeeper fortnight that ended in the financial year, and
  • whether or not the entity or its subsidiaries made voluntary repayments of JobKeeper payments, and the total amount of those repayments if they did.

The due date for the notice depends on the date that 2021 financial report has been lodged as illustrated in the table below:

  • If the company has received JobKeeper but repaid all its (and its subsidiaries’) JobKeeper receipts:
    • before the commencement of section 323DB (14 September 2021), it must still give a JobKeeper notice to its relevant market operator for each financial year
    • after the market notice has been submitted then another JobKeeper notice should be submitted.
  • The notice is required even if the financial statements include information about JobKeeper received / repaid.
Annual report lodged on or before 14 September 2021Annual report lodged after 14 September 2021
Lodge JobKeeper notice by 13 November 2021JobKeeper notice submitted within 60 days of annual report lodgement date

ASIC and review of 31 December 2020 financial reports

ASIC has released the results of their review of 85 listed company 31 December 2020 financial reports, the three key themes arising from the review are:

It is important for entities to ensure that the disclosures of key assumptions, estimates and judgements in the financial statements is sufficient to explain the balance and transaction to the users of the financial statements.

ASIC and restatements

The restatements to entities’ financial statements arising from ASIC queries over the previous six months are shown below. These are useful to allow us to understand the areas where the corporate regulator is finding incorrect accounting or inappropriate assumptions in financial reporting. Additional information can be found in the relevant media release.

Note that two of the restatements relate to makegood provisions and we would strongly encourage all entities with building leases to confirm whether there are any makegood or similar clauses in the agreements and relevant provisions have been included in the financial statements.

ACNC / The Treasury and charity reporting thresholds

We reported in our May 2021 newsletter that Treasury has released a proposal to increase the financial reporting thresholds for ACNC registered charities. These proposals have been finalised and ACNC registered charities will need to report using the new thresholds for reporting periods commencing 1 July 2021.

 Current revenue thresholdNew revenue threshold
Small: Preparation of Annual Information Statement only<$250,000<$500,000
Medium: Preparation of financial statements to be audited or reviewedBetween $250,000 and $1 millionBetween $500,000 and $3 million
Large: Preparation of financial statements to be audited.>$1 million>$3 million

For assistance with your financial reporting requirements, contact your local Bentleys audit and assurance advisor.

We, at Bentleys, are doing everything we can to help businesses come out of this challenging time in good shape.


Disclaimer: This information is general in nature and should not be relied on as advice. It does not take into account the objectives, financial situation or needs of any particular person. You need to consider your financial situation and needs and seek professional advice before making any decisions based on this information.

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