Public Benevolent Institution (PBI) Readiness Checklist
Is your organisation eligible—and ready—to be recognised as a PBI? The checklist below reflects the key interpretive tests used by the ACNC and ATO for assessing whether a charity qualifies as a Public Benevolent Institution.
The Public Benevolent Institution (PBI) status is a key charitable category in Australia that unlocks significant tax benefits—including Deductible Gift Recipient (DGR) endorsement. However, eligibility requires more than good intentions. This checklist helps your organisation assess whether your purpose, structure, and activities meet the legal and regulatory benchmarks set by the Australian Charities and Not-for-profits Commission (ACNC) and the Australian Taxation Office (ATO).
Why PBI Status Matters
Achieving PBI status is not just symbolic—it provides access to income tax exemption, GST concessions, fringe benefits tax (FBT) relief, and crucially, DGR endorsement, which allows donors to claim tax deductions for their gifts. But the ATO applies strict tests to ensure only organisations genuinely relieving public need qualify.
PBI Readiness Checklist
Purpose: Relief of Need
✓ Our main purpose is to provide benevolent relief
- We can clearly describe who is in need (e.g., people with psychosocial disability, survivors of coercive treatment, people living in poverty, or those at risk of homelessness)
- The need we relieve is beyond ordinary hardship — it is serious enough to arouse compassion in the community
- Our governing documents (constitution, rules, or trust deed) explicitly state that benevolent relief is our dominant purpose
Tip: If you do both advocacy and service delivery, make sure relief work is substantial and not incidental. Advocacy may support your relief purpose but can’t replace it.
Public Character
✓ We serve an appreciable section of the community
- We serve an appreciable section of the community, not just members, employees, or a closed group
- Our governance and membership structures are open, representative, and accountable to the public
- We can show that our relief work benefits people beyond our immediate network
Tip: ACNC uses the “public” test to exclude organisations that are essentially private benevolent funds.
Institutional Form
✓ We are a functioning institution
- We are a functioning institution, not just a grant-making trust or informal collective
- We conduct or directly manage our own programs and services that deliver relief
- We have ongoing governance, staff or volunteers, systems, and infrastructure to deliver those programs
Tip: “Institution” implies continuity, structure, and recognised existence—not a temporary project or an unincorporated fund.
Organisational Integrity
✓ Our governance aligns with PBI requirements
- Our governing document aligns with ACNC’s charity and PBI definitions
- Our activities match our stated purpose—no drift toward unrelated work
- We keep public accountability mechanisms: annual reporting, transparent finances, conflict-of-interest policies
- Our board is not controlled by one family or a closed set of interests
Tip: If you’re a small incorporated association, consider transitioning to a company limited by guarantee to strengthen institutional standing.
Tax and DGR Eligibility
✓ We understand our tax obligations and opportunities
- PBI registration is the gateway to DGR endorsement under Item 1 of the Income Tax Assessment Act 1997
- We’ve reviewed readiness for tax concessions: income tax exemption, GST, FBT
- We can maintain proper records for donations, receipts, and use of funds
Tip: Most PBIs also register for DGR—but endorsement isn’t automatic. The ATO assesses this separately after ACNC registration.
Activities and Evidence
✓ We can demonstrate the connection between activities and relief
- We can show how our programs respond to identified social or humanitarian need
- Our relief is non-discriminatory and not conditional on religion, politics, or membership
- We keep documentation: needs assessments, data on recipients, and program evaluations
Tip: Documentation is key—case studies and service data help substantiate “benevolent relief”.
Advocacy, Education, and Systemic Work
✓ Our advocacy supports our relief purpose
- Education or advocacy is clearly tied to our relief work (e.g., training peer advocates)
- We can show that advocacy is incidental or ancillary to our relief purpose
- We avoid activities that are overtly political or partisan
Tip: You can still do powerful advocacy—just ensure it’s purpose-linked (e.g., “advocating for better mental-health services to relieve distress”).
Partnerships and Collaborations
✓ We partner in ways that strengthen our mission
- We partner with other charities to strengthen our relief mission
- We maintain control over our charitable funds and activities
- If we sub-grant, recipients are also charitable and use funds for benevolent relief
Tip: When partnering with advocacy-only groups, clarify which entity is doing the relief work.
Ongoing Compliance
✓ We are prepared for long-term compliance
- We’re prepared to submit annual ACNC reports and maintain records for at least seven years
- We keep track of ACNC guidance updates, especially the “Commissioner’s Interpretation Statement on PBIs”
- We regularly review whether our activities still meet the benevolent-relief test
Tip: Schedule an annual PBI eligibility review as part of your governance cycle.
Quick Diagnostic Summary
✓ Final readiness assessment
| Criterion | Ready? | Notes / Actions |
|---|---|---|
| Clear benevolent-relief purpose | ||
| Serves an appreciable public | ||
| Operates as an institution (not a fund) | ||
| Governance and activities aligned | ||
| Tax / DGR readiness | ||
| Advocacy tied to relief | ||
| Evidence of impact and need | ||
| Compliance systems in place |
Next Steps
If your organisation scores highly on this checklist, you may be ready to pursue PBI status. Consult a legal or tax advisor with charity expertise to review your documents and prepare your application to the ACNC and ATO.
Remember: PBI status is a powerful tool for mission-driven organisations. It requires rigorous alignment between purpose, structure, and practice. Use this checklist not just as a gatekeeper, but as a roadmap to strengthen your impact and integrity.