What counts as a gift for AEC disclosure

Updated 22 July 2026. This article was first published on 21 May 2026. It has been corrected since: the lodgement deadlines were stated for one entity type only, and the reporting period and threshold sections predated the AEC's transitional rules, which took effect on 1 July 2026. The gift definition and the recognition habit the article is about are unchanged.

The support a campaign or a charity receives that is hardest to account for is often the most generous. The pub that lets you have the function room for the launch. The design shop that runs the printing at cost because it believes in what you are doing. The lawyer who looks over a candidate's eligibility for nothing. None of it arrives as a tagged deposit in the bank account, and that is the honest reason it slips past even a careful treasurer: it does not look like a donation, it looks like people helping.

Under the Commonwealth Electoral Act, though, a lot of that help is a gift. The threshold and the lodgement form are the visible end of disclosure. The earlier and more interesting question is what counts as a gift in the first place, and it is one you can get firmly on top of with a single change of habit. This article is mostly about that habit.

The threshold is the visible part

The disclosure threshold is more than $17,300. That figure covered the 2025-26 financial year, and it did not index on 1 July 2026, so it still applies through the transitional period running from 1 July 2026 to 31 December 2026. The period is worth as much attention as the number: it is a six-month reporting period rather than a financial year, created by the transitional rules that have applied since 1 July 2026 to entities already carrying obligations under the existing scheme. From 1 January 2027 the threshold drops to $5,000, indexed on each 1 January that follows a general election, under the funding and disclosure reforms in the Electoral Legislation Amendment (Electoral Reform) Act 2025. The Special Minister of State moved the commencement date from 1 July 2026 to 1 January 2027 on 31 March 2026, but the transitional rules mean the transition has already started rather than sitting entirely ahead of you.

The threshold is only the most visible part of those reforms. The same package brings in donation caps, expenditure caps, expedited near-real-time disclosure, and a move from financial-year to calendar-year reporting. This article stays with the threshold and the gift definition, because that is where the day-to-day recognition work sits, but it is worth knowing the 2027 change is broader than a smaller number.

A threshold is easy to apply once you know what you are counting. The work that rewards attention is one step earlier.

What the Act actually calls a gift

The Commonwealth Electoral Act 1918 defines a gift as a disposition of property made by one person to another without consideration in money or money's worth, or with inadequate consideration. The provision of a service for no consideration or for inadequate consideration is included. Volunteer labour is excluded, and so are annual party-membership subscriptions.

Most of that definition is plain enough. The phrase that does the quiet work is "or with inadequate consideration". It is easy to read "without consideration", picture an outright free gift, and stop there. The benefits that are easiest to overlook live in the inadequate-consideration half of the definition: things that were paid for, just not at their full value.

The benefits that are easy to overlook

Four kinds come up again and again.

Donated goods are the first. Corflutes a printer runs off for nothing, an office lent to the campaign rent-free, a box of branded shirts a supplier adds to the end of a longer print run. None of it touches the bank account. Disclose it at the fair value the goods would have on the open market.

Donated services with real commercial value are the second. The pro bono legal opinion, the accountant who keeps the books for a retainer that does not cover the hours. These are services provided for inadequate consideration, so they are gifts. The exclusion is for volunteer labour, not for all donated work, and the difference is worth a section of its own below.

Discounts beyond normal commercial terms are the third. A supplier who takes 10 per cent off a quote, where 10 per cent is what they would offer anyone, has not made a gift. A supplier who takes 70 per cent off, where 10 is their usual ceiling, has given the extra 60. AEC disclosure guidance is clear that a discount given other than in the normal course of business is a gift-in-kind.

Excessive payment is the fourth, and it is the same idea the other way around. Someone pays well over the odds for a raffle ticket, or for a table at a fundraising dinner. The difference between what was paid and the fair value of what was received is a gift.

The volunteer-labour line

The volunteer-labour exclusion is the part of the rule that is genuinely soft, and it is worth being honest about that. It exists for a good reason: the alternative would have campaigns putting a dollar value on every Saturday doorknocker, which would be unworkable and would miss the point of the exclusion entirely.

The AEC does not publish a test for where that line sits, so what follows is our own practical rule rather than guidance from the Commission: if the person doing the work would, in their own business, send an invoice for the same task, treat it as a service for inadequate consideration rather than volunteer labour. A partner from a law firm advising the committee on electoral law is not volunteering in the sense the Act means. The same partner letterboxing their own street on a Saturday is. The test is not who the person is; it is whether the activity is the kind they are normally paid for.

Value it at what it is worth

For anything other than cash, the figure you disclose is the fair value of what was received: what the goods or services would have fetched on the open market. Not the cost to the donor, not a friendly invoice, and not nil because no money changed hands. AEC disclosure guidance is direct on this: a gift-in-kind is disclosed at an amount that reflects its fair value.

This is the rule that has operations staff going back to a donor for a market quote, which can feel awkward when the donor was simply being kind. It is far less awkward at the time than later. Asking a printer at the point of delivery what the job would have cost a paying customer is an ordinary conversation. Asking the same printer in November about a job from March is not.

The habit that takes most of the sting out of 2027

While the disclosure threshold sits above $17,300, as it does until 31 December 2026, in-kind support that an organisation never quite recognised often stays below the line anyway. At $5,000 it will not. A single donor's in-kind help totalling $10,000 falls short of the current threshold and clears the new one. Watch the period as closely as the figure: totals aggregate against the financial year up to 30 June 2026, then against the six-month transitional period to 31 December 2026, then against the calendar year from 1 January 2027.

This is less daunting than it first sounds, because the response is the same whatever the threshold is. An organisation that records in-kind support when it arrives already has most of what it needs. It is not quite a non-event, though: the reform also amends the inclusions and exclusions in the definition of a donation, and adds donation caps and per-donation disclosure notices, so the definitional work needs a fresh read rather than a straight carry-over. The recognition habit is the expensive part, and that part transfers. The lower threshold only troubles the organisations reconstructing a year of generosity from a bank statement in the fortnight before the deadline, and that was hard work at any threshold.

So the useful response to 2027 is not worry. It is to move recognition earlier, starting now, while there is still time to make it routine.

A simple practice

The change that does the work is small: recognise an in-kind gift at the moment it happens, not at year-end. When someone provides a venue, donates a service, or applies a discount well outside their normal terms, the value goes into the donor record that week.

A short check the committee can run each month:

• Did anything used this month, on or off the bank statement, come to the campaign for free or well below market price?
• For each yes, what would the market price have been?
• For each yes, who provided it, and where does the year's running total against that donor now sit?

Three questions, once a month, is a light load. There are three deadlines ahead, and they do not work the same way, so it is worth checking which applies before you diarise anything.

For the 2025-26 financial-year return, the date depends on what kind of entity you are: registered political parties, their state and territory branches, significant third parties and associated entities lodge by 20 October, while annual donors, members of parliament and senators, and third parties lodge by 17 November. Next comes the return covering the six-month transitional period, 1 July to 31 December 2026, which is due from all individuals and entities by 11 March 2027; that one is a single date for everyone, so do not carry the entity distinction forward to it. After that the new scheme takes over and annual returns move onto the calendar year, falling due eight weeks after it ends. One thing to note if you are on the donor side: donors drop out of annual returns altogether from 1 January 2027, and lodge donation disclosure notices instead.

Whichever date applies, the work to meet it is either spread gift by gift across the year or compressed into the last fortnight. Spread thin, it is genuinely manageable. The habit is the whole game.

This is general information about the Commonwealth Electoral Act disclosure regime, not legal advice. Confirm your own obligations with the AEC, and seek professional advice where whether a particular benefit is a gift is not obvious.