What changed, and whether it changes anything for you

What the Bank actually said

In a letter to reporters dated 24 June 2026, the CBA advised that it has amended its reporting requirements to include a threshold applying to all foreign assets and liabilities accounts. Reporting is mandatory only for holders of accounts with balances or annual transactions of Afl. 1,500,000 or more. Qualifying entities were required to submit a new Notification form Foreign Assets and Liabilities Accounts — the NFALA, schedule code NFALAX — through the Vortex web portal by 24 July 2026.

The amendments are formalised through three decrees issued with that letter: the Decree concerning Foreign Exchange Transactions (general exemption); the Decree on Balance of Payments Reporting Instructions 2026; and the Decree concerning transfers to notified foreign bank and intercompany accounts.

The test is “or”, not “and”

This is where companies will get it wrong. You are inside the obligation if either your balances or your annual transactions reach Afl. 1,500,000. Which means you are only outside it if both are below.

Gross movement is what catches people. Every payment in and every payment out counts toward the year’s transactions; they do not net off. An account that never holds more than Afl. 40,000 can still push well past a million through twelve months of ordinary supplier payments — and that account is still reportable.

Two deadlines, both already passed

• If you are at or above the threshold: a new NFALA was due through Vortex by 24 July 2026. If nobody in your organisation submitted one, you are overdue on a mandatory notification, not merely behind on a monthly return.
• If you now fall below it: you were required to send an email notification to the Statistics Department together with the entity’s latest annual report. Quietly stopping your filings without that notification is not the same as being released from the obligation.

The part nobody is talking about: free transfers

The third decree removes the reporting pre-requisite for transferring freely from local commercial bank accounts to foreign bank and intercompany accounts, for holders below the threshold.

Read that in reverse and it tells you what the arrangement has always been: notification and reporting were the condition on which money moved freely across the boundary. That is why this matters beyond the paperwork — for entities above the threshold, the notification is not an administrative return. It is what underwrites the ability to transfer.

What has not changed

• The Foreign Exchange Commission. These decrees address foreign exchange transactions, balance of payments reporting and transfers. Commission obligations are a separate regime and are assessed separately.
• Prior periods. A threshold applying from 2026 does not excuse periods when you were above it, or periods you never filed at all.
• Next year. The test runs against each year’s figures. Below the line in 2026 does not mean below it in 2027, and nothing about how you trade has to change for you to cross back over.