Charity Commission Annual Return 2026: Step-by-Step Walkthrough
Every charity registered in England and Wales must send the Charity Commission an annual return, or at least report its income and spending, within 10 months of its financial year end. Under £10,000, report income and spending only; £10,000 to £25,000, the annual return questions with no documents; over £25,000, add accounts, a Trustees' Annual Report and the examiner's or auditor's report. A Charitable Incorporated Organisation files whatever its income. The scrutiny thresholds change for financial years ending on or after 30 September 2026 — both sets are live at once, and which applies depends on your year end, not on today's date. Filing late is a criminal offence committed by each trustee, with a defence and a statutory route to ask for longer.
Corrected 2 September 2026. An earlier version of this article said the 2026 annual return added questions about AI use and cyber security. It does not. The Charity Commission’s question guide, which covers both the 2025 and 2026 returns, contains no such questions — we read it end to end and got this wrong. The walkthrough below now follows the form’s real structure, and the scrutiny thresholds are shown with the transition that applies from 30 September 2026.
Every charity registered in England and Wales must send the Charity Commission an annual return, or at least report its income and spending, within 10 months of its financial year end. What you file scales with income. A Charitable Incorporated Organisation files whatever its income. Filing late is a criminal offence committed by each trustee — with a defence, and with a statutory route to ask for more time.
This article covers England and Wales. Scottish charities file with OSCR (nine months, no income floor); Northern Irish charities file the annual monitoring return with CCNI (ten months). Both are covered at the end.
Who has to file what
| Gross income in the year | Charitable company or unincorporated charity | CIO |
|---|---|---|
| Under £10,000 | Report income and spending only, through the annual return service | Full annual return questions, plus trustees’ annual report and accounts |
| £10,000 – £25,000 | Annual return questions. No documents | As above |
| Over £25,000 | Annual return questions, plus trustees’ annual report, accounts, and the examiner’s or auditor’s report. You also declare that every serious incident has been reported | As above, plus the examiner’s or auditor’s report and the serious-incident declaration |
Two things trip people up here.
“Under £10,000 means I do nothing.” No — you still report the year’s income and spending, every year, through the same service. The Commission uses those two figures to keep the register accurate, and a charity that reports nothing for years is treated as one that has stopped filing.
“Our CIO is tiny, so the threshold applies.” It does not. The £10,000 annual-return exemption and the £25,000 accounts trigger are both switched off for CIOs by the Charities Act itself — sections 169 and 163, two separate parenthetical overrides that are easy to miss. A CIO with £500 of income owes the full return, its accounts and its trustees’ report.
The deadline: 10 months from your year end
The deadline runs from the end of the financial year, not from the date the trustees approved the accounts. A late board meeting does not move it.
| Year end | Deadline |
|---|---|
| 31 March 2026 | 31 January 2027 |
| 30 June 2026 | 30 April 2027 |
| 30 September 2026 | 31 July 2027 |
| 31 December 2026 | 31 October 2027 |
One thing almost no guidance mentions: section 163(1)(b) of the Charities Act 2011 lets the Commission allow “such longer period as the Commission may for any special reason allow” for the report and accounts, and the annual return deadline is defined by reference to that date. If you can see you are going to be late, ask before the deadline, with the reason. Asking is not a formality — it is the difference between a late filing and an agreed extension.
Do your accounts need checking first?
Over £25,000 you upload an examiner’s or auditor’s report with the return, so the scrutiny question comes first. These thresholds are changing — and the change attaches to when your financial year ends, not to a switchover date. For about a year, two sets of figures are live at the same time.
| External scrutiny (England and Wales) | Financial years ending before 30 Sept 2026 | Financial years ending on or after 30 Sept 2026 |
|---|---|---|
| No external scrutiny required below (gross income) | £25,000 | £40,000 |
| Examiner must be professionally qualified above | £250,000 | £500,000 |
| Audit required — gross income over | £1 million | £1.5 million |
| Audit required — gross assets over, with income over | £3.26 million, with £250,000 | £5 million, with £500,000 |
“From 30 September 2026” is the wrong shorthand. The instrument says the amendments “do not apply in relation to any financial year of a charity ending before 30th September 2026”. A charity with a 31 March 2026 year end files in January 2027 under the old column and needs an independent examination. The same charity’s 31 March 2027 year falls under the new column: no external scrutiny is required at all — but the accounts and report must still be filed, because the £25,000 filing trigger did not move.
That gap is new, and it is not a drafting error. From 30 September 2026 there is a band of charities that must file accounts which by law nobody has to examine.
Source: The Charities Acts 1992 and 2011 (Substitution of Sums) Order 2026 (SI 2026/427), article 5(6). Full table: charity audit thresholds and independent examination.
Walkthrough of the form — what it actually asks
The Commission publishes one question guide for the 2025 and 2026 returns. The form has eight sections. Several questions appear only if your charity meets a condition; those are marked.
Financial period. Confirm the period. Unincorporated charities and CIOs can have a period of 6 to 18 months; companies follow company law. If the dates shown are wrong, correct them through “update charity details” before you start.
Income and spending. Gross income and gross spending, on the basis your accounts use. For receipts and payments accounts, gross income is total receipts minus endowment received, loans and asset-sale proceeds, plus any endowment transferred into income funds. For accruals accounts it is total income on the SoFA, adjusted for endowment the same way. Revaluation and investment gains are not income here.
1. Income
- 1.1 Number and total value of contracts from central government (including the NHS) or a local authority.
- 1.2 Number and total value of grants from the same bodies. Grants and contracts are separate questions.
- 1.3 Income split across donations and legacies, charitable activities, other trading, investments. Only if gross income is £500,000 or less and grants and contracts are under 70% of income.
- 1.4 Your single highest donation from a corporate donor, from an individual, and from a related party. Only if gross income is over £100,000.
2. Spend
- 2.1 Whether grant making is the main way you carry out your purposes; value of grants to individuals, to other charities, to non-charities; whether any recipient is a related party.
- 2.2 What, if anything, trustees were paid for — being a trustee, a role in a subsidiary or connected organisation, goods or services, anything else, or nothing. Out-of-pocket expenses do not count. And whether any trustee resigned and took up employment with the charity.
3. Activities outside the United Kingdom
Income received from outside the UK, by country and by source (governments, NGOs, companies, individuals, unknown) and by transfer method — including any money that arrived outside the regulated banking system. Whether you delivered charitable activities abroad, in which countries, and whether you have formal written agreements with partners delivering on your behalf. Spending outside the UK, and how much moved outside the banking system.
4. Trading subsidiaries
Whether you have any; whether any dissolved in the year; how many trustees are also directors of a subsidiary.
5. Property
Unincorporated charities only. Whether any property is held by holding or custodian trustees other than the Official Custodian.
6. Employees and volunteers
- 6.1 Headcount at year end by type — permanent, fixed-term, self-employed — and how many work outside the UK. Total spent on payroll. Whether anyone received total benefits of £60,000 or more, in bands, and the highest-paid employee’s total benefits, excluding employer pension contributions.
- 6.2 An estimate of active volunteers in the UK, excluding trustees.
7. Governance
Which of thirteen named policies and procedures you had in place at the end of the period: financial controls, safeguarding, reserves, complaints, serious incident reporting, risk management, trustee expenses, conflicts of interest, investments, campaigns and political activity, bullying and harassment, social media, and engaging external speakers.
The Commission says it expects most charities to have policies on financial controls, reserves, risk management, trustee expenses, conflicts of interest and serious incident reporting. The rest depend on what you do. There is no AI policy and no cyber security policy on the list.
8. Safeguarding and risk
- 8.1 Whether you provided services to children and/or adults at risk in the period. Then — excluding basic checks — whether you obtained the required level of DBS check for all eligible roles: standard, enhanced, or enhanced with barred lists. The level is set by law, not by how cautious you want to be; the form points you to the DBS eligibility tool.
- 8.2 Whether all serious incidents, including historical ones you became aware of in the period, have been reported. Only if gross income is over £25,000. If anything is unreported, report it before you submit.
- 8.3 External risk and impact — a positive/negative impact grid. Included only in exceptional circumstances such as a pandemic; the Commission announces in advance if it is switched on.
What the form does not ask
Because so much has been written about questions that do not exist, it is worth listing them. The 2025–26 return does not ask whether you use AI, whether you had a cyber incident, whether you have a cyber policy, how many safeguarding incidents you logged, when you last reviewed a policy, how many trustee meetings you held, whether trustees had training, or how many beneficiaries you reached.
The large expansion of the return happened in 2023 — income analysis, largest donations, trustee payments, related-party grants, overseas activity — and that is still what catches charities out three years on.
Source: Charity Annual Return 2025 and 2026: question guide — GOV.UK.
Documents to gather first
Have these to hand before you open the form. The questions above tell you why each one is needed.
- Signed accounts and the examiner’s or auditor’s report, where required
- Signed trustees’ annual report
- The SoFA or receipts and payments statement — for gross income, gross spending and the 1.3 split
- A list of government contracts and government grants received, with values
- Your three highest donations by donor type, if income is over £100,000
- The notes to the accounts on trustee payments and related parties
- Overseas: countries, sources, partners and transfer methods, if any
- Year-end headcount by employment type, total payroll, and pay bands over £60,000
- An estimate of active volunteers
- The list of policies in place at year end, with dates
- Confirmation from your safeguarding lead that DBS checks were obtained at the required level for every eligible role
- Your serious incident log for the year
From CharityIQ
Most of the return is data you already hold. CharityIQ pre-fills the income, spending, trustee and staffing answers from your charity’s records, flags which conditional questions apply to you, and keeps the audit trail. You review and submit. See compliance in CharityIQ.
Common errors that trigger Commission queries
1. Gross reported as net. Income after fundraising costs where gross is required. The figures must reconcile to the accounts; the Commission cross-checks.
2. Grants and contracts mixed up. Public-sector income put in the wrong box changes whether question 1.3 applies to you at all.
3. Trustees on the register not updated. Resignations and appointments are made through “update charity details”, not the return — but the return will not look right until they are.
4. A CIO that assumed it was exempt. It is not, on either the return or the accounts.
5. Fixing an error with a reset. The return cannot be partially edited. To change a submitted answer you apply in writing for a full reset and resubmit everything — and the new submission date is what appears on the register. If that date falls after your deadline, the register shows the return as late even though the original was on time. Re-uploading accounts, by contrast, does not need a reset.
What happens if you file late
The real escalation looks nothing like a tidy timetable of reminders.
- The register entry shows the documents as outstanding, visible to anyone — including funders — searching for you.
- A final written warning with a compliance deadline.
- Charities in default for two or more of the last five years are pulled into the double defaulter class inquiry under section 46, where the Commission can use information orders and directions.
- Three exits from that inquiry: comply and leave; removal from the register under section 34; or referral to a separate, named inquiry.
Underneath all of that sits section 173 of the Charities Act 2011: failing to transmit the accounts, report or return by the deadline is an offence committed by each person who was a trustee immediately before the deadline — a fine plus a daily fine for as long as you remain a trustee. Prosecution is not the Commission’s visible practice, but the offence is real and it is personal. The defence is having taken all reasonable steps to comply in time — which is one more reason to ask for the extension before the date, not after.
Scotland and Northern Ireland
Scotland. Every charity on the Scottish Charity Register files an annual return, accounts and trustees’ report with OSCR within nine months of the year end. There is no income floor at all — dormant charities file too. The question set varies with legal form, and OSCR revised it for years ending on or after 30 June 2025. Scotland’s own accounting thresholds also moved, separately and earlier, by SSI 2025/341, and on a period-beginning basis rather than a period-ending one.
Northern Ireland. Registered charities file the annual monitoring return, accounts and report with CCNI within ten months of the year end.
How to never miss the deadline
Put the deadline in three calendars the day you file this year’s return. Hold the board meeting that approves the accounts and report at least twelve weeks before the deadline. And store the answers that do not change — registered details, policies, structure — so next year starts from a pre-filled draft rather than a blank form.
Annual return done in 30 minutes, not a weekend.
Start a free 14-day CharityIQ trial. Pre-population, deadline alerts, audit trail.
Start free trial →
Frequently asked questions
10 months after your financial year end. The date is shown on your charity's entry on the register. It runs from the year end, not from the date the trustees approved the accounts.
Ask the Commission for a longer period before the deadline, giving the reason — section 163(1)(b) allows it for a special reason. If you have already missed it, file as soon as you can; the register updates once the documents are in.
Yes — report the year's income and spending through the annual return service. A CIO must file the full return, accounts and report whatever its income, because sections 163 and 169 switch the thresholds off for CIOs.
Nothing. The 2025 and 2026 returns share one question guide, and the last substantial change was in 2023. There are no questions about AI use or cyber security — an earlier version of this article said otherwise and was wrong.
Only if your financial year ends on or after 30 September 2026. The change attaches to your year end, not to a switchover date, so for about a year two sets of figures are live at the same time.
Only by applying in writing for a full reset and resubmitting the whole return — and the new submission date is the one shown on the register, which can make an on-time return look late. Accounts can be re-uploaded without a reset.