If you are financing an Australian film or television production, your lender will almost certainly require a QAPE opinion before releasing funds. Understanding QAPE opinion Australia requirements is essential for any producer seeking offset finance.
A QAPE opinion is a formal assessment prepared by an independent accountant — specifically a Certified Practising Accountant (CPA) or Chartered Accountant (CA) — that estimates how much of your production budget qualifies as Qualifying Australian Production Expenditure for the purposes of the Producer Offset.
QAPE Opinion vs QAPE Audit: A QAPE opinion is a forward-looking document prepared during pre-production based on estimated budgets. The QAPE audit is a backward-looking review of actual expenditure required by Screen Australia for the Final Certificate — a separate process that happens after production wraps.
QAPE Opinion Australia: Why Lenders Require One
When a lender cashflows your Producer Offset, they are advancing money against a future government rebate. The QAPE opinion analyses your production budget line by line, classifying each expense as QAPE or non-QAPE — similar to the ongoing QAPE tracking process during production — based on the rules in Division 376 of the Income Tax Assessment Act 1997. The resulting estimate determines the anticipated Producer Offset amount — and this is the figure your lender uses to calculate how much they will advance.
Loan Sizing
Lenders typically advance up to 90% of the anticipated Producer Offset. Your QAPE opinion determines the base figure. If your estimated QAPE is $2 million on a feature film, your anticipated offset is $600,000 (at 30%), and the lender may advance up to $540,000.
Risk Mitigation
If actual QAPE turns out lower than estimated, the Producer Offset will be smaller and the lender’s security is diminished. An independent QAPE opinion provides a professional assessment of this risk.
Independent Verification
Producers have an inherent incentive to overstate QAPE. A third-party opinion from a qualified accountant provides an unbiased assessment that protects both parties in the financing arrangement.
Legal Accountability
Unlike a quick estimate, a formal QAPE opinion from a qualified accountant carries professional liability. If the opinion proves materially inaccurate due to negligence, the lender has recourse.
QAPE Opinion Australia: Which Lenders Require One?
All major Australian film finance lenders require a QAPE opinion as part of their due diligence process. The three largest specialist lenders are:
Fulcrum Media Finance
Fulcrum is the market-leading cashflow financier for film and television in Australia and New Zealand. Based in Sydney and backed by Media Super, Fulcrum has provided cashflow finance to over 455 screen productions, deploying more than $847 million. They cashflow the Producer Offset, PDV Offset, Location Offset, state-based incentives, and international presales. Producers typically ask Fulcrum to cashflow 90% of their anticipated offset rebate.
Mind the Gap Film Finance
Founded by Michael Agar in 2016 and based in Melbourne, Mind the Gap has financed more than 250 productions across scripted and unscripted formats, including Oscar-nominated Memoir of a Snail and Sundance-premiering Jimpa. They specialise in the lower-budget sector of the Australian screen industry, lending against the Producer Offset, PDV Offset, distribution guarantees, and gap financing against unsold territories. In 2025, Mind the Gap was acquired by US indie financier TPC.
Head Gear Films
Head Gear Films is an international film financier founded in 2002 that has financed over 550 titles and deployed more than $400 million USD in capital. They offer gap funding, bridge financing, and lending against government incentives including the Australian Offset. While London-based, Head Gear actively finances Australian productions and requires QAPE verification as part of their incentive lending process.
Other Lenders
Other lenders who may require QAPE opinions include Icon Film Finance (part of the Dendy Icon Group), Jake Film Finance, and government-backed facilities such as Screen Queensland’s Revolving Film Finance Fund (RFFF). Screen Queensland’s RFFF guidelines explicitly require “a third-party opinion as to the QAPE addressed to Screen Queensland from a reputable Certified Practising Accountant or Chartered Accountant.”
What a QAPE Opinion Includes
Core Analysis
- Production details — project name, SPV entity, format, release method
- Line-by-line budget analysis with QAPE/non-QAPE classification
- Estimated QAPE total and resulting Producer Offset value
- QAPE threshold confirmation for the production’s format
Technical Assessment
- On-cost allocation — super, workers comp, multi-state payroll tax
- VFX splits between Australian and overseas work
- Interested party expenditure treatment
- Assumptions, limitations, and accountant qualifications
QAPE Opinion vs QAPE Audit
| Feature | QAPE Opinion | QAPE Audit |
|---|---|---|
| Timing | Pre-production / early production | Post-production (after wrap) |
| Purpose | Finance applications — loan sizing | Screen Australia Final Certificate |
| Based on | Estimated budget figures | Actual expenditure (general ledger) |
| Required by | Lenders (Fulcrum, Mind the Gap, etc.) | Screen Australia (POCU) |
| Prepared by | Independent CPA or CA | Registered company auditor |
| Regulatory basis | Commercial requirement | Producer Offset Rules 2018 (Rules 21 and 30) |
When to Get Your QAPE Opinion
You should commission your QAPE opinion as early as possible in the financing process — ideally once you have a locked or near-locked production budget. Most lenders require the opinion before they will issue a commitment letter or term sheet.
Lock your budget
Finalise your production budget with your line producer. The QAPE opinion is based on these figures.
Engage an independent accountant
Select a CPA or CA with film production experience. This cannot be your production accountant if they are involved in day-to-day accounting (some lenders require independence).
Provide documentation
Supply the locked budget, key contracts, deal memos, and details of any related party transactions.
Receive the opinion
A thorough QAPE opinion typically takes 5 to 10 working days depending on the complexity of the production.
Submit to lender
Include the opinion in your finance application alongside your Producer Offset provisional certificate and completion bond documentation.
Common QAPE Opinion Australia Classification Issues
Several budget areas frequently require careful analysis in a QAPE opinion:
- VFX and post-production splits — work performed overseas does not qualify as QAPE, so productions with international VFX vendors need clear allocation
- Interested party expenditure — payments to related parties require additional scrutiny under the Producer Offset Rules
- Multi-state payroll tax — productions filming across multiple states face different payroll tax rates and thresholds
- Development expenditure — costs incurred during development may or may not qualify depending on timing and structure
- Overseas shoot days — any portion shot overseas must be excluded from QAPE
- Goods and services from overseas — music licensing, stock footage, and overseas supplier costs are generally non-QAPE
Getting a thorough QAPE opinion Australia producers can rely on means working with an accountant who will identify these issues early and provide clear guidance on classification.
Frequently Asked Questions
Can my production accountant prepare the QAPE opinion?
It depends. Some lenders require the QAPE opinion to be prepared by an accountant who is independent of the day-to-day production accounting. If your production accountant is also providing the QAPE opinion, check with your lender whether they accept this arrangement. Screen Queensland’s RFFF guidelines specifically require a “third-party” opinion.
How much does a QAPE opinion cost?
QAPE opinion fees vary depending on the size and complexity of the production. For a typical Australian feature film with a budget between $2 million and $10 million, expect to pay between $3,000 and $8,000. The fee is itself QAPE-eligible expenditure. Contact us for a quote based on your specific production.
What qualifications does the accountant need?
The accountant must be a Certified Practising Accountant (CPA) or Chartered Accountant (CA) registered with a recognised Australian professional body. Beyond the formal qualification, lenders expect the accountant to have demonstrable experience in film production accounting and QAPE analysis.
Is a QAPE opinion required for the PDV Offset or Location Offset?
If you are seeking finance against the PDV Offset or Location Offset, lenders may require an equivalent opinion assessing qualifying expenditure under those programs. The principles are the same — the lender needs independent verification of the anticipated rebate amount — but the qualifying expenditure rules differ from the Producer Offset.
What happens if actual QAPE differs from the opinion?
The QAPE opinion is based on estimated budget figures and is not a guarantee. Actual QAPE determined during the final audit may be higher or lower. If actual QAPE is materially lower, the Producer Offset will be smaller, and the lender may require the shortfall to be covered from other production funds.
Do I need a separate QAPE opinion for each lender?
Not necessarily. Most lenders will accept a single QAPE opinion addressed to them (or jointly addressed to multiple parties). Discuss this with your accountant and lenders at the outset to avoid duplication.
See our QAPE opinion services page for details on our process and what we cover.
Get a QAPE Opinion for Your Production
$50M+ in production budgets managed. $5M+ in Producer Offsets claimed. We work with Fulcrum, Mind the Gap, Head Gear and all major Australian lenders.