Submission to the House of Representatives Standing Committee on the Environment - 21 May 2015

CCA welcomes the opportunity to provide a submission into the House of Representatives Standing Committee on the Environment Inquiry into the administration and transparency of the Register of Environmental Organisations (the Register) and its effectiveness in supporting communities to take practical action to improve the environment.

CCA is concerned that this inquiry seeks to confuse the established definition of charity by bringing into question one particular area of charitable endeavour, seeking to use activity rather than purpose in determining organisational status, and potentially adding more complexity to an onerous process that serves little purpose in terms of delivering real community benefits.

CCA’s submission addresses the following issues:

  • The Australian Charities and Not-for-profits Commission – a fit for purpose regulator
  • Why just environmental groups?
  • Purpose not activity
  • Advocacy versus ‘on-ground environmental works’
  • The illegal activities of some charities
  • Ministerial involvement in DGR status
  • DGR as a seal of government endorsement / popularity

In conclusion, CCA strongly supports the need for reform, particularly with the ongoing engagement between not-for-profit organisations and Commonwealth agencies. The level of counter-productive regulatory and compliance activity, and lack of consistent independent application of tax concessions is having a very negative impact on the productivity and effectiveness of not-for-profit organisations. Many environmental organisations have been through an extensive process to obtain DGR status based on a review of public benefit and the purpose of their work. Second, third or even fourth guessing these decisions based on ill-conceived commentary about practical interventions versus advocacy serves no-one’s interests, other than those seeking to obtain economic benefits from environmental exploitation.

The charities and not-for-profit sector wants to work with government to reduce red tape while improving transparency and accountability. One way to achieve these outcomes is to accept the recommendations of many inquiries and reports by streamlining requirements for all charities in gaining DGR status. The best, most efficient, transparent and effective means of doing this is to empower the ACNC to determine charitable status as well as making recommendations to the ATO on DGR eligibility. This would not only make the ACNC a truly one stop shop for charities, but also end duplication and costly reliance on a range of disparate departmentally based bodies that are often under-resourced and ill-equipped for the roles they are enacting.

The Terms of Reference and further information about this inquiry are available at: