• The current thresholds for determining large proprietary companies will double with effect from 1 July 2019.


  • Proprietary companies need to be aware of these changes, especially when considering whether they trigger the threshold requirements.

Earlier this month, the government registered the Corporations Amendment (Proprietary Company Thresholds) Regulations 2019 (Cth) which will amend the Corporations Regulations 2001 (Cth) to double the current thresholds for large proprietary companies from 1 July 2019.

The increase of the thresholds is set to reduce the financial reporting obligations and costs placed on smaller proprietary companies, as most are only required to keep written financial records. However, these changes may also come at the price of reduced financial transparency.

New thresholds

The increase in thresholds will mean from 1 July 2019 that a proprietary company will be considered ‘large’, for a financial year, where it satisfies at least two of the following thresholds:

  • $50 million or more in consolidated revenue;
  • $25 million or more in consolidated gross assets; or
  • 100 or more employees.

Once a proprietary company meets at least two of the threshold requirements during a financial year, the company will then need to prepare and lodge an audited financial report, a director’s report and an auditor’s report with ASIC for each financial year in which it continues to satisfy at least two of the threshold requirements.

It’s worth noting that when counting employees for the purpose of the third threshold, part-time employees are to be taken into account as an appropriate fraction of a full-time equivalent.


We recommend that these changes to the thresholds are raised with clients before 1 July 2019, so consideration can be given as to whether they are likely to satisfy at least two of the threshold requirements; particularly, the employee threshold, which (as external advisers) we may have less visibility over.

We would be pleased to assist further with any consideration of the application of these new thresholds.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.