Nothing below comes from a critic, a former member or a newspaper. It comes from the church's own recordings and handbooks, from companies the church owns, and from filings it has made to regulators in Britain, Australia and New Zealand. Set against what the church has told two parliaments, it describes a different organisation — one with a centre, a budget, a membership register and a commercial purpose. And one that, on its own account, exists because somebody at the top said it should. Understanding why the church answers as it does means understanding what the alternative answers would cost it.

What the church says

Lloyd Grimshaw, for the church, to the Joint Standing Committee on Electoral Matters, 21 August 2026:

“We have no constituent governing document other than the Holy Bible. These assemblies and congregations are unincorporated associations and autonomous in their functions, and there's no centralised recordkeeping.”

“There are no employees in the church, there are no official positions or titles.”

“There is no such thing as a Brethren business because the church does not have any businesses, it doesn't have any vested interests.”

Bruce Hales, in his written submission of 5 October 2026 — twenty-seven questions he wrote himself, answered himself, and on the strength of which he asked to be excused from appearing:

“The Plymouth Brethren Christian Church has no hierarchical structure, no clergy and no appointed ministers.”

“I do not have authority over members' political choices, their businesses, or how they take part in civic life.”

“There is no register of members' private activities, no command structure, and no officer who could truthfully answer for 16,000 private citizens.”

Why every answer has the same shape

There is a reason the church's position is always that individual members acted of their own accord, and it is worth setting out, because it explains the architecture of every denial in this inquiry.

Two bodies of Australian law meet here. Under electoral law, an organisation whose electoral expenditure passes the statutory threshold must register with the Australian Electoral Commission and disclose what it spent and where the money came from. Under the Charities Act 2013, a registered charity may campaign on law and policy — that is expressly permitted — but it may not have as a purpose “promoting or opposing a political party or a candidate for political office”. That is a disqualifying purpose.

So there are three possible accounts of what happened in 2025, and only one of them is free.

  1. The church organised it. Then an organisation running a dozen charities with hundreds of millions in assets has been acting for a purpose the Charities Act disqualifies.
  2. Some entity organised it, but not the church. Then that entity was conducting electoral activity, and the question becomes what it spent, whether it should have registered with the AEC, and who paid.
  3. Thousands of members each decided independently. No charity has a disqualifying purpose, no organisation has electoral expenditure to declare, and nobody has to answer for any of it.

The third is the church's answer. It is also the only answer that costs nothing — and the only one that requires thousands of people in a dozen cities to have had the same idea in the same week.

We are not lawyers, and whether a disqualifying purpose exists is for the charities regulator, not for us. But the committee can ask a narrower question with a documentary answer: somebody, at some point in 2025, worked out that no registration was required. Who did that work, what were they told, and did anyone consider what registering would mean for the church's charitable status? Advice of that kind is written down.

What follows is the record against the third answer.

One — It was instructed, and the instruction is on the record

At Strive 23, the church's annual funding event in late 2022, Bruce Hales told the worldwide membership how the money system began. He takes them back to a meeting in the early 1990s about how the church's new school would pay for itself:

“We'd paid for the buildings, but that's all debt-free. How are we going to keep going?… And the two things he said were, that I clearly recall, was put the school into business and start an endowment fund.”

He describes reviving it himself: “We've been wanting to revive this concept of an endowment fund for quite some years. Finally, we decided that we'd waited long enough.” And he tells members what to give, working the arithmetic aloud: “So if you've got a million bucks, you give half away, you've still got half a million… Instead of buying $100 pairs, buy $50 pairs.”

Against: “My role includes giving spiritual guidance to members… it is not my role to direct what members do.”

Two — It has a centre, and the centre has a name

From the church's own annual business events, in its officers' words. Jeremy Joyce on the Global Advisory Panel: “when questions came up through the ecosystem entities, they came to GAP for direction.” Logan Currie on the money: “We roll up each of the entity in the ecosystem. Each of the regional budgets get rolled up into a global budget.” And on control: “Each month there is a meeting of each of these entities with a representation in each region, which GAP helps to facilitate… they discuss income versus budget, expenses versus budget.”

Caleb Hall, for UBT, names the body above him — “the Global Board” — and its commercial objective: to “double total client net profit by 2030” and see that “all of our 56,000 members prosper globally.”

The Global Funding Team handbook, copyright The Grace Trust, sets a National Target, divides it into area targets, allocates five to ten named donor households to each delegate and reports monthly on shortfalls. Its own word for the process is “Sales Planning”.

Against: “No hierarchical structure, no clergy and no appointed ministers.” “Autonomous in their functions.”

Three — It keeps a register of its members, and a company maintains it

Connect is a members-only directory application. Its published privacy notice records that it holds each member's photograph, name, email, telephone, address, place of worship, links to other family members, connections by marriage and information as to employment. Submissions are “checked first by UBT staff… to ensure that personal information aligns with PBCC member records”, and on deletion UBT will “continue to hold it on our database… for the purposes of verification and ongoing recordkeeping for the PBCC”.

There is also a Household Vision Survey — “understanding the data globally on all our households” — reporting household debt, age profile and a net change of 295 households worldwide; and a Business Vision Survey, run globally since 2014, tracking members' business revenue and profit and reported back by region.

And a form you fill in before you may move house

We hold a church document headed “COMMENDATION FOR RELOCATION – Checklist”, and beneath that, in brackets, “(Not to be read out publicly)”. It is the paperwork a Brethren household completes in order to move to another town.

It asks eleven questions. Among them:

“Where do you want to go and why?”
“Are you and your family settled that you have the Lord’s mind in regard to your exercise?”
“Are all the children at home, your married children, and your parents willing to support your exercise?”
“Are your financial affairs all in order?”
“How will you and those moving with you earn a living now and in the long term future?”
“Are you and your household committed to the teachings of the Holy Scriptures and all the Great Ministries, including Mr Bruce Hales’ letter dated May 5 2003?”
“Who is the brother in your new locality committed to providing a lasting interest in your household?”

It is then signed off three times over. The form carries three signature blocks: “Commended by – Sending Locality”, “Commended by – Receiving Locality” and “Commended by – Country Commission”, each with space for three names.

Two data sheets travel with it. Sheet A records the household, both localities, whether the new one has been visited, the home address, and for every person in the family their age, occupation, employer and “Special Needs re Health/Education” — together with the father’s parents, the mother’s parents and the married children. Sheet B, headed “Financial Summary”, records the estimated value of the existing house, the bank mortgage, the private mortgage, other loans and borrowings, the net balance, the estimated cost of the new house, the resulting surplus or deficit, other savings, investments and pension — and, for the present and the proposed employer alike, the company name, gross salary, net salary, other income, whether there is a company car and whether fuel is paid.

Each sheet ends “Completed By … Date … Initials”.

Our copy has been redacted to protect the household concerned; the questions and headings are the form’s own. It post-dates 5 May 2003, because it requires commitment to a letter of Mr Hales of that date.

Against: “There’s no centralised recordkeeping.” “There is no register of members’ private activities, no command structure, and no officer who could truthfully answer for 16,000 private citizens.” “A member’s life is governed by Scripture and by their own conscience before God… ultimately, their choices are their own.”

Four — The church owns a trading company, and its spokesman is a director of it

PBCC Services Pty Ltd, ACN 165 353 131, at The Precinct, Sydney Olympic Park. Registered in 2013 as Universal Support Team Pty Ltd; renamed in July 2021. Its share register has one entry: all twelve ordinary shares, fully paid and beneficially held, owned by Plymouth Brethren Christian Church, ACN 158 542 075 — the entity Lloyd Grimshaw appeared for.

It trades. Its 2022 accounts record revenue of $1,166,866, including $337,916 of “Client Subscription Charges” and $106,651 of “Entity Management”. Among its directors is Merrick Lloyd Grimshaw — the same Lloyd Grimshaw.

Nothing about the company is improper: it is a registered charity and its constitution restricts its income to charitable objects. That is the point. There was nothing to hide, and a committee was told it did not exist.

And the separateness is thin on the ground as well as on paper. They share a floor. The Rapid Relief Team (RRT) Ltd, ABN 61 166 059 392, and OneSchool Global Australia Ltd, ABN 88 613 500 182, both give their address on the charities register as Level 6, 10 Herb Elliott Avenue, Sydney Olympic Park. PBCC Services and UBT Marketing give the same floor of the same building; Vision Invest gives it as its head office. The Daily Telegraph counted eight registered charities at that address, each with current Brethren members on their boards, holding $240 million between them. A global charity, a global school, a global consultancy and a global investment manager, on one floor in Sydney.

Alongside it, UBT sold £107.8 million of services in Britain in 2024 on a corporation tax charge of £5,970, and turns over about $200 million a year in Australia. In March 2024 the Australian Taxation Office raided UBT's head office at The Precinct. UBT has since paid several million dollars under a voluntary disclosure covering fringe benefits tax and salary splitting, with two further matters open.

Against: “The church does not have any businesses, it doesn't have any vested interests.” “PBCC has no business interests and does not trade.”

Five — It accumulates, by design, and says so

Charles Hales put the running cost of the whole structure at “about 430 million per annum… and the school makes up 370 of that.” The annual shortfall — “the one number” — was A$255 million for 2025 and A$260.61 million for 2026, raised in a one-week pledge campaign with local teams contacting each household.

Above it sits the Vision Foundation, which the church calls, in its own words, “our community endowment fund”. It held A$262,315,240 at 30 June 2025, having grown from A$123 million two years earlier. In its last reported year it took in A$44.1 million and spent A$2.0 million in total.

Why it gives so little away is not a mystery. The church has explained it: “we continue the accumulation phase… we're aiming to grow it by a further 15%. To achieve this we will be relying heavily on donations from successful business sales. To support these sales we've hired a team of professionals to work with business owners who are looking to sell.” Some members, it reports, have donated up to 15% of the proceeds of selling their companies. The benchmark is Harvard's endowment; the target is $500 million at a 20% return, to throw off $100 million a year.

Beneath it, a licensed New Zealand fund takes Brethren families' savings from $250 and lends them to Brethren businesses against personal guarantees, with everything earned above a rate the manager sets passing up to the Foundation.

Against: “It doesn't have any vested interests.”

Why this matters on Friday

Taken separately, each item has an innocent explanation and most of them are entirely lawful. Taken together they describe one organisation: a centre that gives direction, a consolidated global budget reviewed monthly by region, a verified register of every member household, a company the church owns, a commercial target for members' profits, and a quarter of a billion dollars accumulating against a target set by reference to Harvard.

And on the church's own telling, it exists because it was decided upon. Put the school into business. Start an endowment fund. Revive it when the time is right. Give half. Those are not descriptions of a fellowship of autonomous congregations. They are instructions, and the man who repeated them to 56,000 people is the man who has told the committee he has no authority over any of it.

The committee does not have to resolve whether this is a church. It has to resolve whether it was told the truth.

Ten questions for the committee

  1. To Mr Grimshaw. You told this committee the church “does not have any businesses”. Plymouth Brethren Christian Church, ACN 158 542 075, owns all twelve shares in PBCC Services Pty Ltd, a trading company of which you are a director. Its constitution gives its object as providing “administrative, financial and other support to a range of registered charitable entities” and “acting as trustee”; until recently the Vision Foundation’s registered contact on the charities register was a director of that company, at a pbccservices.com address. The Vision Foundation in turn owns Vision Invest, which manages a licensed fund lending Brethren families’ savings to Brethren businesses. How do you reconcile that chain with the church having no businesses and no vested interests — and who decided to change those contact details?
  2. To Mr Hales. Who sits on the Global Advisory Panel and the Global Board, how are they appointed and who removes them; who approves the consolidated global budget; and who sets the annual global funding target that local teams then collect against?
  3. UBT's published privacy notice says member submissions are checked against “PBCC member records”. What are those records, which entity holds them, how many people are on them, and under what legal basis are they kept?
  4. UBT's stated goal is to double total client net profit by 2030. Who set that target, and what follows for a member's business that does not meet it?
  5. To Mr Hales. At Strive 23 you told the membership: “if you've got a million bucks, you give half away”. Is that spiritual guidance, or is it financial instruction?
  6. To Mr Hales. Your son Charles has described you asking him “what happened to the ratio that you agreed?”, after which 58 people lost their jobs in eight weeks. Do you set operating ratios for businesses owned by members of your church?
  7. The Vision Foundation holds A$262 million, reported A$44.1 million of revenue against A$2.0 million of total expenses, is in a stated “accumulation phase” and employs advisers to help members sell their businesses. What is its charitable purpose, and when will it distribute?
  8. Who determined that no entity connected with the church needed to register as a significant third party for the 2025 election, on what basis, and was the effect on the church’s charitable status considered?
  9. Fringe benefits tax and salary splitting are matters for an employer. Why did the voluntary disclosure to the ATO come from UBT, rather than from the individual businesses concerned?
  10. To both witnesses. Mr Grimshaw told this committee that the words quoted from the April 2025 recording were spoken in a Bible meeting and taken out of context. Mr Hales has since written that they were never spoken at all. Which account is correct, and will the church produce the recording?

And one question that contains all the others

If the committee asks nothing else, it could ask this.

Mr Hales — in an organisation that says it has no hierarchy and no positions, but which keeps a verified list of all its members worldwide; which holds an annual event its households are expected to attend; in which a household must complete a form disclosing its mortgages, savings, investments, pension and both salaries, and obtain three sets of signatures, before it may move house; which runs a global charity in the Rapid Relief Team, a global school in OneSchool Global, a global fundraising operation with a single annual target, and a global endowment fund — all operating from the same floor of the same building in Sydney; and in which a deed approved by a charity regulator makes your written declaration conclusive evidence of whether any person is in fellowship with you — is it credible that thousands of your members independently decided, at the same time and in the same way, to campaign in an Australian election?

Every element of that question is documented above. None of it is in dispute. It is the answer that matters.

Where the evidence is

How this was put together

Every quotation above is sourced in full in the articles linked. In summary: evidence to the Joint Standing Committee on Electoral Matters is from the official transcript of 21 August 2026 and from Submission 366, dated 5 October 2026. The remarks of Bruce Hales, Charles Hales, Jeremy Joyce, Logan Currie and Caleb Hall are from recordings and transcripts of Strive 23, Strive 25 and Strive 26, the church's annual business and funding events. The Global Funding Team handbook is copyright The Grace Trust. The Connect material is from UBT's published privacy notices and the app store listings.

The “Commendation for Relocation” checklist and its two data sheets are a church document held by Brethren Intelligence, redacted to protect the household concerned. The questions, headings and signature blocks quoted are the form’s own.

Company and charity information is from public registers: PBCC Services Pty Ltd from the Australian Securities and Investments Commission, its constitution and its filed financial statements; the Vision Foundation from the Australian Charities and Not-for-profits Commission; UBT (EU) Ltd and the Grace Trust from Companies House and the Charity Commission for England and Wales; the Vision Income Fund from the New Zealand Disclose Register. The March 2024 ATO raid and UBT's voluntary disclosure are the reporting of James Willis in the Daily Telegraph, 25 November 2025.

Nothing here alleges that the church, any charity, any company or any individual named has acted unlawfully, and most of what is described is plainly lawful. The church denies involvement in the 2025 Australian federal election and denies controlling its members' businesses. Where this article states something, it rests on a document on a public register or a document we hold.

Brethren Intelligence has investigated the Plymouth Brethren Christian Church since 2020. The directory holds 8,409 companies and 9,000 individuals across 20 countries. The hundred largest companies by revenue are listed free here.

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