Medical devices & therapeutic goods compliance obligations in Australian Capital Territory: 20–99 employees, turnover $1M–$3M
Computed by the Rules Mate applicability engine for a Pty Ltd company with 20–99 employees, turnover $1M–$3M, in medical devices & therapeutic goods, operating in Australian Capital Territory and selling to consumers and small businesses.
Short answer: 48 obligations
48 obligations apply (18 critical) across 24 regulators, plus 13 to check. Risk rating: medium. No licensed regime, but you employ staff (WHS, Fair Work, super and payroll duties); 18 critical obligations apply.
Turnover $1M–$3M instead of $3M–$10M: what changes
Compared with a Pty Ltd company with 20–99 employees, turnover $3M–$10M in Australian Capital Territory, 1 obligation applies that did not, and 8 drop away.
- No longer applies: Notifiable Data Breach (NDB) scheme
- No longer applies: Publish a Privacy Policy that meets APP 1
- No longer applies: Provide an APP 5 collection notice at or before collection
- No longer applies: APP 12 & APP 13 access and correction requests
- No longer applies: APP 7 direct marketing: consent, opt-out & when you can't message (2026)
- No longer applies: Privacy Act Reform — information controllers regime (proposed Tranche 2)
- No longer applies: Report ransomware and cyber extortion payments within 72 hours
- No longer applies: APP 2 — anonymity + pseudonymity for individuals
Australian Capital Territory law that applies
3 Australian Capital Territory obligations apply on these facts, and 1 more is worth checking:
| Obligation | Why it applies |
|---|---|
| PCBU primary duty of care (ACT WHS Act s 19) | Every business is a PCBU — the primary duty of care applies whether or not you employ anyone · ACT law |
| Industrial manslaughter offence (ACT WHS Act s 34A) | Applies to every PCBU and its officers — a death caused by reckless or negligent breach of a WHS duty is a crime · ACT law |
| Comply with Workplace Privacy Act 2011 (ACT) | You have employees (20–99) · ACT law |
| Pay ACT payroll tax when threshold met | Check: applies only if your annual Australian wages (grouped) exceed $1.75M |
Payroll tax in Australian Capital Territory (FY2026-27)
ACT: 6.75% on Australian wages above the $1.75 million tax-free threshold (FY2026-27). On these facts it may apply: 20–99 employees in ACT — enter annual payroll to confirm; it applies only if your annual Australian wages (grouped) exceed $1.75M.
- How the threshold works
- Flat tax-free threshold, apportioned by days employed and the ACT share of Australia-wide wages.
- Returns
- Monthly by the 7th of the following month; annual reconciliation by 28 July
- Administered by
- ACT Revenue Office
Australian Capital Territory regulators
Where the obligations sit
| Area | Obligations |
|---|---|
| Workplace | 8 |
| Tax | 7 |
| Directors | 4 |
| Whs | 4 |
| Privacy | 3 |
| Consumer law | 3 |
| Super | 2 |
| Medicines | 2 |
| Migration | 2 |
| Corporations | 2 |
Critical obligations on this profile
- Apply for a Director Identification Number (Director ID) (Incorporated company (Corporations Act))
- Comply with directors' general law and statutory duties (Incorporated company (Corporations Act))
- Prevent insolvent trading (s 588G) (Incorporated company (Corporations Act))
- Pay superannuation on every payday (Payday Super) (You have employees (20–99))
- Pay employees in accordance with the applicable modern award (You have employees (20–99))
- Manage psychosocial hazards at work (You have employees (20–99))
- Take reasonable and proportionate measures to prevent sex discrimination, sexual (You have employees (20–99))
- Australian Business Number (ABN) application (Every business carrying on an enterprise needs an ABN)
Check whether these apply
- 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
- Pay ACT payroll tax when threshold met: only if your annual Australian wages (grouped) exceed $1.75M
- Register R&D activities for the R&D Tax Incentive: only if you claim the R&D Tax Incentive
- Comply with self-assessed clearance + Integrated Cargo System (ICS): only if you import goods into Australia
- Comply with anti-dumping + countervailing duties: only if you import goods into Australia
- Influencer + ad disclosure under ACL + AANA Code: only if you advertise to consumers or engage influencers
- Customs Act 1901 — import declarations + duties: only if you import goods into Australia
Thresholds to watch
- 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)
- WGEA gender pay gap reporting becomes mandatory (threshold 100 employees; very close)
Questions
- How many compliance obligations apply to medical devices and therapeutic goods in Australian Capital Territory with 20–99 employees, turnover $1M–$3M?
- 48 obligations apply (18 critical) across 24 regulators, plus 13 to check. Risk rating: medium. No licensed regime, but you employ staff (WHS, Fair Work, super and payroll duties); 18 critical obligations apply.
- Which Australian Capital Territory laws apply?
- PCBU primary duty of care (ACT WHS Act s 19), Industrial manslaughter offence (ACT WHS Act s 34A) and Comply with Workplace Privacy Act 2011 (ACT)
Related
- Medical devices & therapeutic goods compliance in Australian Capital Territory
- Medical devices & therapeutic goods: all obligations
- Compliance obligations by industry, state and size
- Medical devices & therapeutic goods in ACT: sole trader
- Medical devices & therapeutic goods in ACT: sole trader with employees
- Medical devices & therapeutic goods in ACT: partnership
- Medical devices & therapeutic goods in ACT: trading trust
- Medical devices & therapeutic goods in ACT: no employees
- Medical devices & therapeutic goods in ACT: 1–5 employees
- Medical devices & therapeutic goods in ACT: 20–99 employees
- Medical devices & therapeutic goods in ACT: 100–499 employees
- Medical devices & therapeutic goods in ACT: 6–19 employees, turnover $3M–$10M
- Medical devices & therapeutic goods in ACT: 100–499 employees, turnover $100M–$1B
- Medical devices & therapeutic goods in ACT: 500+ employees, turnover $1B+
- Medical devices & therapeutic goods in New South Wales: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in Victoria: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in Queensland: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in Western Australia: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in South Australia: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in Tasmania: 20–99 employees, turnover $1M–$3M
- Medical devices & therapeutic goods in Northern Territory: 20–99 employees, turnover $1M–$3M
- Conduct post-market surveillance of therapeutic goods: does it apply to medical devices & therapeutic goods?
- In-vitro diagnostic medical device classification + ARTG: does it apply to medical devices & therapeutic goods?
- Notify ACCC of a voluntary recall within 2 days: does it apply to medical devices & therapeutic goods?
- Comply with the Therapeutic Goods Advertising Code: does it apply to medical devices & therapeutic goods?
Sources
- ACT Revenue Office: payroll tax thresholds and rates
- PCBU primary duty of care (ACT WHS Act s 19)
- Industrial manslaughter offence (ACT WHS Act s 34A)
- Comply with Workplace Privacy Act 2011 (ACT)
- Apply for a Director Identification Number (Director ID)
- Comply with directors' general law and statutory duties
- Prevent insolvent trading (s 588G)
- Pay superannuation on every payday (Payday Super)
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.