How often should a board update its conflict of interest register?

Update it at two points: annually, when every director completes a full declaration of interests, and at every meeting, where directors declare any conflict relevant to the items on that agenda before the matter is discussed. The register should be a standing agenda item.

What should a conflict of interest register include?

For each declared interest: the date, the person and their role, the nature of the interest, the related party or entity, whether it's financial or non-financial, whether it's actual or perceived, whether it's material to a current matter, how it's being managed (for example recusing from the discussion and vote), and when it was reviewed.

Conflict of Interest Register: what to record & how to run one

Q: What is a conflict of interest register?

A conflict of interest register is a running record of the actual, potential and perceived conflicts of interest declared by a board's directors and officers, along with how each conflict is being managed. It's a key piece of evidence that a board is meeting its governance duties.

A conflict of interest register is one of the simplest tools a board has — and one of the most telling. A well-kept register is strong evidence that directors understand their duties; an empty or stale one is a red flag to auditors and regulators alike.

What is a conflict of interest register?

It's a running record of the actual, potential and perceived conflicts of interest that your directors and officers declare, together with how each one is being managed. A conflict of interest simply means a director's personal interests — or the interests of someone close to them — could influence, or appear to influence, their decisions on behalf of the organisation. Having a conflict isn't wrong; failing to declare and manage it is.

Why your board needs one

Disclosing conflicts of interest is an explicit duty of Responsible People under ACNC Governance Standard 5, and directors of companies have equivalent duties under the Corporations Act. Beyond compliance, a good register protects the board: it shows decisions were made in the organisation's interests, and it protects individual directors if a decision is ever questioned.

What to record

For each declared interest, capture:

Column	What goes here
Date declared	When the interest was first disclosed.
Name & role	The Responsible Person and their position.
Nature of the interest	A plain description — e.g. "owns a business that supplies IT services".
Related party / entity	The company, person or organisation involved.
Type	Financial, non-financial, or a duality of interest (two competing duties).
Perceived or actual	Is it a real conflict now, or one that could reasonably be perceived?
Material to a current matter?	Does it touch anything currently before the board?
How it's managed	The action taken — e.g. recuse from discussion and vote, leave the room.
Noted at / review date	The meeting where it was noted, and when it will be reviewed.

How often to update it

Annually — every director completes a full declaration of interests, whether or not anything has changed.
Every meeting — "declarations of interest" is a standing early agenda item; directors declare any conflict relevant to that agenda before the item is discussed.
As they arise — a new interest is declared as soon as a director becomes aware of it, not saved for the next annual round.

Managing a conflict once it's declared

Declaring is only half the job. Depending on how material the conflict is, the board might: note it and allow the director to participate; ask the director to take part in discussion but not vote; or ask them to leave the room for both. Whatever you decide, record the decision and the reason in the minutes — the register and the minutes should tell the same story.

Keep it maintained automatically

A spreadsheet works until someone forgets to update it. BoardTable keeps your interest register live alongside your meetings, prompts declarations as a standing agenda item, and links each managed conflict to the minute that records it — so your register and your decisions always match.

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This guide is general information only and is not legal or compliance advice.

The conflict of interest register, done properly