Trust & company service providers compliance obligations in Queensland: no employees

Compared with a trust & company service providers business run as a sole trader with no employees in Queensland, 10 obligations apply that did not.

• Applies: Apply for a Director Identification Number (Director ID)
• Applies: Comply with directors' general law and statutory duties
• Applies: Prevent insolvent trading (s 588G)
• Applies: Pay company PAYG/GST/SG or face Director Penalty Notice (DPN)
• Applies: Lodge the ASIC annual company statement and review fee
• Applies: Determine large proprietary company status annually
• Applies: Apply for a Tax File Number for new entities and partnerships
• Applies: Pay ASIC fees + lodge prescribed forms
• Applies: Discharge of directors' duties — practical evidence
• Applies: Beneficial ownership transparency (Tranche 3 — under consultation)

Moving to a Pty Ltd company with 1–5 employees, turnover $100K–$1M adds 20 obligations:

• 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
• Withhold PAYG from employee and contractor payments
• Provide 10 days paid family + domestic violence leave (FDV)
• Document VEVO checks + retain employer records (s 245AYL Migration Act)
• Casual employment definition + conversion (Closing Loopholes 2024)
• Report under Single Touch Payroll Phase 2
• Honour employees' right to disconnect (s 333M)

1 Queensland obligation applies on these facts:

QLD: 4.75% on Australian wages above the $1.3 million tax-free threshold (FY2026-27). On these facts the business is below the Queensland threshold, so payroll tax does not apply yet.

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 (Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026)
• Maintain a written AML/CTF program (Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026)
• Customer due diligence (KYC) on every customer (Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026)
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC (Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026)
• Notifiable Data Breach (NDB) scheme (AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)))
• 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))

• 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
• Comply with AANA Code of Ethics + community guidelines: only if you advertise to consumers or engage influencers

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