Queensland's 2021 BCCM disclosure reform.

What changed on 1 March 2021

The Queensland Government, following the QUT Property Law Review, replaced the previous BCCM regulation modules with five new modules: the Standard Module, Accommodation Module, Commercial Module, Small Schemes Module, and amendments to the Specified Two-lot Schemes Module. All commenced on 1 March 2021 and together govern the procedural operation of every body corporate in Queensland under the Body Corporate and Community Management Act 1997.

The headline change for transparency was the tightening of commission disclosure. Under the new regulation modules — specifically regulation 156 of the Standard Module and equivalent provisions in other modules — body corporate managers and caretaking service contractors must give the body corporate written notice of any commission, payment, or other benefit they are entitled to receive in connection with a contract the body corporate is considering, including the actual monetary amount.

Previously, disclosure could be made in generic terms ("the manager receives a 10% commission on insurance premiums"). After 1 March 2021, that generic disclosure was no longer compliant. The notice must include the dollar value of the commission so the body corporate can see exactly what is being paid and to whom before making its decision on the contract.

How the disclosure obligation operates in practice

The mechanics of the disclosure are set out in the regulation modules. Three key features stand out.

Disclosure must be in writing

Verbal disclosure at a committee meeting is not enough. The manager or caretaking service contractor must provide written notice to the body corporate. This creates a documentary record that can be inspected later — a critical evidentiary feature if a dispute arises.

Disclosure must precede the decision

The notice must be given before the body corporate makes its decision on the contract. After-the-fact disclosure does not satisfy the regulation. In practice, this means insurance commissions, contractor referral fees, and supplier rebates must all be on the table when the committee or general meeting is voting.

The relationship trigger is broad

The regulation captures any commission, payment, or benefit from any source connected with a contract the body corporate is considering. This includes insurance commissions from brokers, referral fees from preferred contractors, volume rebates from suppliers, and similar payments. The owner of the obligation is the manager or caretaking service contractor — not the third party paying the benefit.

Wider changes in the 2020 modules

The 2021 reform was not limited to commission disclosure. The new regulation modules also introduced several other significant procedural changes that have shaped how Queensland body corporates operate today.

Electronic voting on all motions. Electronic voting (including secret ballots) is now permitted on all motions and ballots in general meetings, where previously paper voting was the default. This has made participation in general meetings substantially more accessible.

Lot owner motion rights. Lot owners are entitled to submit up to six motions in any 12-month period to the committee, which must make a decision within six weeks (extendable by a further six weeks in certain circumstances). This empowers individual owners to bring issues forward without waiting for the AGM cycle.

Power of attorney restrictions. A person may hold a power of attorney to vote on behalf of only one other person, unless they are a family member or it is a developer-related power under sections 211 or 219 of the BCCM Act. This closed the loophole that allowed a single person to "farm" powers of attorney and control general meeting outcomes.

Building defects assessment motion. A body corporate is now required to include on the agenda of its second AGM a motion to decide whether to have a building defects assessment carried out. This brings defect investigation into the standard scheme lifecycle rather than leaving it to be triggered by problems.

Major spending limits. Adjustments to committee spending limits and rules about how the major spending limit operates for insurance policy inception or renewal.

What this means for committees in 2026

Five years after the regulation modules took effect, three practical implications continue to matter for body corporate committees in Queensland.

You are legally entitled to ask for the dollar amount. If your body corporate manager presents a contract for consideration and you do not see a written disclosure of any commission or benefit they receive in connection with it, the absence is itself a compliance issue. You can ask for the disclosure in writing, and the manager is required to provide it before the decision is made.

Insurance is the highest-value disclosure to focus on. Strata insurance commissions are typically the largest single payment a manager receives from a third party. A 15% commission on an $80,000 premium is $12,000 — paid annually, often without owners knowing the dollar figure. Asking specifically for the dollar value of insurance commissions before approving the renewal is the highest-impact exercise of the disclosure right.

Contractor referral fees are the next layer. Beyond insurance, the same disclosure obligation applies to commission, payment, or benefit received from contractors. If your manager regularly engages the same plumber, painter, or electrician, you can ask whether they receive any payment from that contractor in connection with the work. The regulation requires disclosure of the dollar amount.

How Queensland compares to NSW now

For four years between March 2021 and February 2025, Queensland was meaningfully ahead of NSW on commission transparency. The QLD requirement for monetary disclosure preceded the NSW statutory framework by nearly four years, and the principles of the QLD reform shaped the design of subsequent NSW legislation.

Today, the regimes are convergent. NSW now requires detailed insurance quote breakdowns under the Strata Managing Agents Legislation Amendment Act 2024, and SCA NSW has gone further with an outright commission ban for members from 1 January 2026. QLD's regulatory baseline remains the monetary-amount disclosure, with no statutory equivalent of the SCA NSW ban — but the disclosure obligation is genuinely enforceable, and breach can be raised with the Office of the Commissioner for Body Corporate and Community Management.

Frequently asked questions

Does the disclosure obligation apply to all body corporate managers?

Yes — regulation 156 of the Standard Module and equivalent provisions in the Accommodation, Commercial, Small Schemes, and Two-lot Schemes Modules apply to all body corporate managers and caretaking service contractors operating in Queensland community titles schemes.

What if my manager has not disclosed monetary amounts in writing?

The first step is to request the disclosure in writing, citing the regulation. If the request is refused or the response is inadequate, the matter can be raised with the Office of the Commissioner for Body Corporate and Community Management for guidance or conciliation. Persistent non-disclosure may justify escalation to adjudication.

Does this apply retrospectively to existing contracts?

The obligation applies to disclosures made in connection with body corporate decisions on contracts from 1 March 2021 onward. It does not retrospectively invalidate disclosures made before that date, but does apply to all renewals, variations, and new contracts considered after commencement.

Are committee members also subject to disclosure?

Committee members have separate conflict-of-interest obligations under regulation 79 of the Standard Module. A committee member may not receive a direct or indirect benefit from a caretaking service contractor or service contractor unless authorised by ordinary resolution of the body corporate.