Everything you need to know about the new XRB reporting thresholds for your PBE entity

Jadene Windley
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The External Reporting Board (XRB) has released updated reporting thresholds for public benefit entities (PBEs):

Tier Old criteria New criteria
Tier 1* Total expenses greater than $30m Total expenses greater than $33m
Tier 2 Total expenses less than $30m Total expenses less than $33m
Tier 3 Total expenses less than $2m Total expenses less than $5m
Tier 4 Total operating payments $140,000 No change

*Note; an entity is also required to apply Tier 1 if it has "public accountability".

This decision is welcome as many PBE entities will see a reduction in reporting requirements and compliance costs.

These thresholds have not been updated since 2012; in that time, various new pieces of legislation have been introduced and inflation has pushed many entities from Tier 3 to Tier 2 reporting without becoming any larger or more complex.

Several new PBE standards have also been issued over the last decade, causing concerns that the costs of reporting exceeded the benefit to users under the previous size thresholds.

Research by the XRB on the expenditure of PBE entities shows there is substantially less clustering around the $5 million threshold, compared to the $2 million threshold. In total there are 33 entities with total expenditure between $4.8 million and $5.2 million, while there are 115 entities with total expenditure between $2.8 million and $3.2 million.

When does this change apply?

The new thresholds are mandatory for periods beginning after 28 March 2024, which impacts 31 March 2025 balance dates onward.

However, the change can be applied for periods that end after the standard takes effect (28 March), so those preparing reports for 31 March 2024 balance dates onward are also eligible. 
This news is timely for Incorporated Societies applying XRB PBE reporting standards for the first time under the Incorporated Societies Act 2022, as more Incorporated Societies will also now have lower reporting requirements.

Determining your expenditure

Total expenses for the purpose of determining a reporting threshold include all of an entity’s operating expenditure. This includes grants or donations made by an entity, but does not include capital expenditure (assets) or loan payments. 

How does it work in practice?

If you now find yourself eligible to apply a lower reporting tier due to this change, it can be implemented immediately. 

However, you need to consider future expenditure as you may end up transitioning back quickly if this grows year on year. It’s also important to think about consolidation requirements if your entity sits within a group, so that a change in reporting tier at the entity level doesn’t interfere with group reporting. 

PBEs can apply requirements of a higher tier if they want to, so if you are happy to stay at the current reporting tier – that’s fine. For example, we have seen this with recently established PBEs that knew they would exceed the previous $2m expenditure threshold in future years, so they start by adopting Tier 2 rather than waiting until they hit the threshold.

If your PBE previously applied Tier 1 requirements and you are transitioning to Tier 2 requirements due to your expenditure, the recognition and measurement accounting policies will remain the same, but there will be less disclosure requirements in the notes to the financial statements. 

Tier 2 and Tier 3 reporting requirements have some differences, mainly around presentation of revenue and expenses, and accounting for property, plant and equipment, investment property and publicly traded financial investments.

Entities that previously applied Tier 2 requirements and are transitioning to Tier 3 can choose to either provide comparative data in accordance with Tier 2 requirements (i.e., leave it as it was) or restate them in line with Tier 3.

If your entity is thinking about transitioning reporting tiers, start engaging in the process early so you can navigate this transition which can be deceptively complex at times.