Health practitioners compliance obligations for an unregistered not-for-profit
Computed by the Rules Mate applicability engine for an unregistered not-for-profit in health practitioners with 6–19 employees, turnover $1M–$3M, selling to consumers and small businesses.
Short answer: 41 obligations
41 Commonwealth obligations apply to an unregistered not-for-profit in health practitioners with 6–19 employees, turnover $1M–$3M (16 critical), plus 19 to check. Risk rating: medium. No licensed regime, but you employ staff (WHS, Fair Work, super and payroll duties); you are an APP entity under the Privacy Act; 16 critical obligations apply.
What the structure changes
Compared with a Pty Ltd company of the same size in health practitioners, an unregistered not-for-profit picks up 0 Commonwealth obligations and drops 9.
- Does not apply: Apply for a Director Identification Number (Director ID)
- Does not apply: Comply with directors' general law and statutory duties
- Does not apply: Prevent insolvent trading (s 588G)
- Does not apply: Pay company PAYG/GST/SG or face Director Penalty Notice (DPN)
- Does not apply: Lodge the ASIC annual company statement and review fee
- Does not apply: Determine large proprietary company status annually
- Does not apply: Pay ASIC fees + lodge prescribed forms
- Does not apply: Discharge of directors' duties — practical evidence
- Does not apply: Beneficial ownership transparency (Tranche 3 — under consultation)
Critical Commonwealth obligations on this profile
- Notifiable Data Breach (NDB) scheme (Provides a health service and holds health information — not covered by the small business exemption (Privacy Act s 6D(4)(b)))
- Pay superannuation on every payday (Payday Super) (You have employees (6–19))
- Pay employees in accordance with the applicable modern award (You have employees (6–19))
- Manage psychosocial hazards at work (You have employees (6–19))
- Take reasonable and proportionate measures to prevent sex discrimination, sexual (You have employees (6–19))
- Maintain AHPRA registration and CPD (Industry: Health practitioners)
- Make mandatory notifications to AHPRA (Industry: Health practitioners)
- Australian Business Number (ABN) application (Every business carrying on an enterprise needs an ABN)
Check whether these apply
- Apply for a Director Identification Number (Director ID): only if your organisation is a company limited by guarantee (its directors need a director ID)
- Maintain PBS approval + claim accurately for PBS-listed medicines: only if you are a PBS-approved pharmacy
- Maintain controlled drugs register (Schedule 8 / 9): only if you hold Schedule 8 medicines
- Cosmetic surgery practitioner endorsement (from 2025): only if you perform or advertise cosmetic procedures
- Cosmetic surgery advertising standards (Medical Board reforms 2024-2025): only if you perform or advertise cosmetic procedures
- Lodge an FBT return and pay FBT by 21 May: only if you provide fringe benefits (cars, entertainment, loans) to employees
- Wash outbound marketing lists against the Do Not Call Register: only if you make outbound telemarketing calls
- Maintain DGR endorsement: only if you are endorsed as a deductible gift recipient
State and territory law
This page counts Commonwealth obligations only. Payroll tax, workplace safety, licensing and other state duties depend on where the business operates; the industry's state pages list them.
Other structures and industries
- Health practitioners: sole trader
- Health practitioners: trust
- Health practitioners: pty Ltd company
- Health practitioners: public company
- Health practitioners: registered charity
- Aged care providers: not-for-profit
- NDIS providers: not-for-profit
- Education — registered training orgs: not-for-profit
- Charities & not-for-profits: not-for-profit
Questions
- What compliance obligations apply to an unregistered not-for-profit in health practitioners?
- 41 Commonwealth obligations apply to an unregistered not-for-profit in health practitioners with 6–19 employees, turnover $1M–$3M (16 critical), plus 19 to check. Risk rating: medium. No licensed regime, but you employ staff (WHS, Fair Work, super and payroll duties); you are an APP entity under the Privacy Act; 16 critical obligations apply.
- What changes compared with a Pty Ltd company of the same size?
- An unregistered not-for-profit picks up 0 obligations and drops 9.
Related
- Health practitioners: all obligations
- Compliance obligations by structure
- Compliance obligations by industry, state and size
- Maintain AHPRA registration and CPD: does it apply to health practitioners?
- Make mandatory notifications to AHPRA: does it apply to health practitioners?
- Maintain PBS approval + claim accurately for PBS-listed medicines: does it apply to health practitioners?
- Maintain controlled drugs register (Schedule 8 / 9): does it apply to health practitioners?
Sources
- Notifiable Data Breach (NDB) scheme
- Pay superannuation on every payday (Payday Super)
- Pay employees in accordance with the applicable modern award
- Manage psychosocial hazards at work
- Take reasonable and proportionate measures to prevent sex discrimination, sexual harassment and victimisation (positive duty)
- Maintain AHPRA registration and CPD
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.