'In Australia' Submission - 4 April 2014

This is the third submission on this legislation that has been prepared with the members of the Community Council for Australia (Attachment 2) as well as other key organisations in the not-for-profit sector, academics, lawyers, government officials, and key policy advisors.

A number of our members have raised concerns about the latest proposed legislation. CCA supports the policy intent, and the improvements in this draft compared to previous versions. At the same time, there is scope for further improvement in the legislation to reduce potential negative consequences for not-for-profits, our communities and international communities that benefit from their engagement with Australian not-for-profit organisations. These concerns are outlined under three main sub-headings:

1. New barriers to international engagement
2. Additional administrative requirements
3. Interpretation, implementation and enforcement.