Will my name be on the Scottish Charity Register, and can I stop it?

Scotland: This page is about the Scottish Charity Register, and it applies only to Scottish charities. England and Wales: this page is not about you. The Charity Commission’s register and what it publishes about trustees are a separate regime with no exemption route of the kind described here — see Step 5, Set up and keep your statutory registers. Northern Ireland: the same — CCNI keeps its own register under its own rules, and nothing on this page carries across.

When did trustee names start appearing on the register?

The law changed on 5 March 2026. But a name appears only when its charity submits trustee details, so there was no single switch-on date. This page is for trustees of charities on the Scottish Charity Register, and for boards recruiting them. OSCR runs the register.

The publication question belongs in the same conversation as the trustee eligibility check and the trustee induction. If a new trustee has had neither, start there.

This change is recent, and it was announced as a single dated event. Most of what has been written about it is wrong in at least one of these three ways.

The legal commencement date and OSCR’s go-live date are different. The amendment to s.3 of the Charities and Trustee Investment (Scotland) Act 2005 came into force on 5 March 2026.

OSCR began publishing on 9 March 2026, the following Monday. Both dates are real, and they mark different things: the law changing, and the regulator’s systems changing. The same pair of dates governs the publication of unredacted accounts, which what gets published, and by whom covers.

There was no flag day for charities already on the Register. Nothing happened to existing charities on either date. A name appears when the charity submits its trustee details — through the annual return, or through an update in OSCR Online.

Exposure is rolling and charity-specific. Two Scottish charities can be in completely different positions today. The difference is nothing to do with either of them choosing.

The date had already moved once. The go-live had previously been indicated for late 2025 and slipped. That is why a lot of 2025 sector content describes a timetable that never happened. It is also a reminder to check the date on anything you read about this, including this page.

What is published, and what OSCR holds but does not publish

The Scottish Charity Register is the public list of charities in Scotland that OSCR keeps under the 2005 Act. The Register publishes first name and last name for each charity trustee. That is the whole of it.

Section 3(3) of the 2005 Act lists what the Scottish Charity Register must contain. Since March 2026 that list includes the name of each of the charity’s trustees.

OSCR holds a good deal more than it publishes. Not published:

• home address
• email address
• telephone number
• date of birth
• date of appointment

So the answer to “how much of me goes online” is narrower than most people fear. The answer to “how much does the regulator know” is wider. Both are worth saying to a nervous candidate in the same sentence.

The exemption: the test, the window, and what the charity has to do

An exemption is possible. It is not a preference you express. It is an application, decided against a single statutory test in s.3(4) of the 2005 Act. The test is short, and it is narrow: publication would be likely to jeopardise the safety or security of any person or premises.

Four things follow from that, and each of them catches someone out.

It is a safety test, not a privacy test. Not wanting to be named is not the test. A concern about being contacted by the public is not the test. The question is jeopardy to the safety or security of a person or premises, and the application has to speak to that.

The window runs from the date the trustee is added, and it is short. OSCR’s published process gives an application period of 28 days. It asks the charity to flag the intention to apply at the point the trustee is added.

Miss that, and the name is published automatically. The question is then no longer whether it will appear, but how long it has already been there.

It is per charity. The scope is per charity — a trustee of several charities must apply separately for each. A trustee of three Scottish charities needs three applications. A refusal by one route is not a refusal for all.

A refusal can be reviewed, and the review also has a clock. OSCR’s process allows 21 days to ask for a review of a refusal. It says it aims to complete one in 21 days.

One thing we will not tell you is how long a decision takes. OSCR publishes no service standard for it. Its own answer is that it depends on the complexity of the application and how many it has.

Any source that gives you a turnaround time has invented it. Plan on the assumption that you do not control the timing. That is another reason to apply at appointment rather than later.

Does an exemption keep a name out of the accounts?

No. An exemption keeps a name off the Register, not out of the accounts the charity files. This is the trap that undoes the work.

Since March 2026 OSCR publishes the accounts a Scottish charity submits without redacting them. It does not remove personal information before publication. It says so plainly: the legislation requires it to publish the information in unredacted form.

A trustee’s name may appear in the trustees’ annual report, in a related-party note or in a signature block. If it does, that is what goes online, exemption or no exemption.

So the name has to come out of the charity’s own documents, before filing. OSCR disclaims responsibility for personal data left in what is submitted. OSCR is right to do so. Nobody else is in a position to know which name is the protected one. What gets published, and by whom sets out the accounts publication rule in full.

In practice, the exemption decision has two owners. The trustee owns the application. The charity owns everything it files afterwards, permanently.

When to tell trustee candidates about publication

Tell candidates before they agree to serve, because the exemption window starts when they are added. Whether there is a legal duty to warn a prospective trustee that their name will be published has not been established. We are not going to assert one.

Telling them early is nonetheless the only defensible practice. It is also what recruit your founding trustees already tells charities recruiting founding trustees.

The reason is practical rather than moral. The exemption window starts when the trustee is added, and the application has to be flagged at that point. A candidate who learns about publication a month after appointment has already lost the route that was available to them. Raising it in the recruitment conversation is the only way the option stays open.

It is also, for a small number of people, the thing that decides whether they can serve at all. A charity may discover this at the point of submission rather than the point of recruitment. If so, it has usually discovered it too late for the trustee it affects.

How to submit trustee details to OSCR

The submission itself is ordinary administration. Trustee details go in through OSCR Online, either as an update when the board changes or as part of the annual return. The annual return is the more common route. It is why a charity that has changed nothing about its board can still find names appearing. The return asks, and the submission publishes.

The return itself is covered in complete the OSCR annual return.

Before you submit, do three things. Confirm every trustee’s details are the ones you hold and check. Confirm whether any trustee has an exemption in place, or one pending. And check the documents going up with the return for names that have to come out first.

Common mistake: assuming names appeared automatically on the go-live date

The change was announced as a single dated event, so it reads like a switch. For charities already on the Register there was no flag day at all.

Names appear only when the charity submits, through the annual return or an OSCR Online update. So a charity can be months away from its own exposure and not know it. And a trustee can assume the question is settled when it has not yet arisen.

Common mistake: deciding about an exemption after the trustee has been added

It feels like an administrative afterthought, to be dealt with when there is time. The application window runs from the date the trustee is added, and the charity has to flag the intention to apply at that point. Miss it, and the name is published automatically. This is the single most consequential piece of timing in this whole process.

Common mistake: winning an exemption and then filing accounts containing the name

Register entries and accounts feel like separate systems, and until March 2026 they behaved like it. Accounts are now published unredacted.

OSCR publishes what it is given. It disclaims responsibility for personal data left in a submitted document. So the name comes out only if the charity takes it out. An exemption plus an unedited annual report leaves the trustee exactly where they started.

Worked example

A Scottish charity works with people affected by domestic abuse. It appoints a new trustee who has personal experience of it, and who does not want to be named publicly.

This is close to the kind of case OSCR publishes as approvable. The application speaks directly to the safety of a person, which is what the statutory test asks about. But the charity has to do two things, and the second is the one that gets forgotten.

First, flag the intended application at the point of adding the trustee, and submit it inside the window. Second, and permanently, keep the name out of everything the charity files — the trustees’ annual report, the accounts, any note that lists the board. The exemption protects the Register entry. Nothing protects the accounts except the charity’s own editing.

Done in that order, the trustee can serve. Done in the other order, the exemption arrives after the name is already public in two places.

The last step in this hub is to review and, where needed, amend your governing document.