Banks & ADIs compliance obligations in Queensland: trading trust

Compared with the same business run through a Pty Ltd company (6–19 employees) in Queensland, 1 obligation applies that did not, and 9 drop away.

• Applies: Make trustee resolutions for trust distributions by 30 June

• No longer applies: Apply for a Director Identification Number (Director ID)
• No longer applies: Comply with directors' general law and statutory duties
• No longer applies: Prevent insolvent trading (s 588G)
• No longer applies: Pay company PAYG/GST/SG or face Director Penalty Notice (DPN)
• No longer applies: Lodge the ASIC annual company statement and review fee
• No longer applies: Determine large proprietary company status annually
• No longer applies: Pay ASIC fees + lodge prescribed forms
• No longer applies: Discharge of directors' duties — practical evidence

2 Queensland obligations apply on these facts, and 1 more is worth checking:

QLD: 4.75% on Australian wages above the $1.3 million tax-free threshold (FY2026-27). On these facts it may apply: 6–19 employees in QLD — enter annual payroll to confirm; it applies only if your annual Australian wages (grouped) exceed $1.3M.

How the threshold works

Deduction of $1.3M reduces by $1 for every $7 of Australian wages above $1.3M, reaching nil at $10.4M.

Surcharges

Mental health levy: 0.25% of Queensland wages above $10M (Australian wages >$10M); additional 0.5% above $100M.

Regional concession

1% rate discount for eligible regional employers (to 30 June 2030)

Returns

Monthly by the 7th of the following month; annual reconciliation by 21 July

Administered by

QRO

• Workplace Health and Safety Queensland (WHSQ)
• Queensland Revenue Office (QRO)
• Office of the Information Commissioner Queensland (OIC Qld)
• Office of Fair Trading Queensland (OFT Qld)
• Queensland Department of Environment, Science and Innovation (DES Qld)
• Office of Liquor and Gaming Regulation (Queensland) (OLGR Qld)

• Enrol with AUSTRAC as a reporting entity (Authorised deposit-taking institution — AML/CTF reporting entity)
• Maintain a written AML/CTF program (Authorised deposit-taking institution — AML/CTF reporting entity)
• Customer due diligence (KYC) on every customer (Authorised deposit-taking institution — AML/CTF reporting entity)
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC (Authorised deposit-taking institution — AML/CTF reporting entity)
• Notifiable Data Breach (NDB) scheme (AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)))
• 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))

• Mortgage broker best interests duty: only if you are a mortgage broker
• Small Amount Credit Contract + Consumer Lease caps (post-SACC reforms): only if you provide small amount credit contracts or consumer leases
• Lodge an FBT return and pay FBT by 21 May: only if you provide fringe benefits (cars, entertainment, loans) to employees
• Pay Queensland payroll tax when threshold met: only if your annual Australian wages (grouped) exceed $1.3M
• Wash outbound marketing lists against the Do Not Call Register: only if you make outbound telemarketing calls
• Influencer + ad disclosure under ACL + AANA Code: only if you advertise to consumers or engage influencers
• Pre-2025 ban on unsolicited credit limit increase invitations: only if you issue credit cards
• Pay redundancy under NES (s 119 FW Act): only if you have 15 or more employees (FW Act s 121 small business exemption)

• Lose the Privacy Act small-business exemption at $3M annual turnover (removal of the exemption altogether is proposed, not yet law) (threshold $3M; very close)