Who are we actually helping?

England and Wales: This page sets out the position in full, including the two things the annual report has to contain. Scotland: covered, and different — one achievements narrative with no second statement, a regulator that expects you to show how you identify the people you help, and publication of the annual report since 5 March 2026; see below. Northern Ireland: covered, with its own regulations and its own second statement — parallel to England and Wales, not the same; see below.

Who are your charity’s beneficiaries, and why does it matter legally?

A charity’s beneficiaries are the people or causes it exists to help, within the limits of its stated purposes. Defining your charity’s beneficiaries precisely does legal work as well as measurement work. In all three UK nations, the trustees’ annual report is where you show who the charity’s work benefits. The rules differ between England and Wales (the Charity Commission), Scotland (OSCR) and Northern Ireland (the Charity Commission for Northern Ireland).

This step assumes you have already decided what you need to measure, and why; if not, start there.

In England and Wales, the annual report is governed by reg. 40 of the Charities (Accounts and Reports) Regulations 2008. It asks for the main activities the charity undertook, verbatim, “to further its charitable purposes for the public benefit”.

“For the public benefit” is a question about who benefits. So your definition of your beneficiaries is doing legal work in that report, whether you notice or not. Scotland and Northern Ireland reach the same question by different routes, which this step’s Northern Ireland and Scotland sections set out.

It is also why most impact measurement fails before it starts. A group you cannot describe is a group you cannot report on. It is also a group you cannot measure.

How narrow should the definition be?

Narrow enough that you could count the group from your own records. An outcome is a change in a group, and if you cannot count the group, you cannot show a change in it.

NPC defines outcomes as "Changes in your target group(s) that you believe will contribute to impact." That is good practice from a named body, not a legal rule, but it is the definition this hub uses. Separate outputs from outcomes from impact sets out all four of NPC’s words.

“Young people in the town” feels like a definition. It is in fact a purpose. Test yours against four questions:

• Who, exactly? Age, need or situation — whatever decides who you work with.
• Where? The area you serve in practice, not the one in your governing document if that is wider.
• How do you know someone is in the group? A register, a referral form, a sign-up sheet.
• Could you count them from your own records? If not, the definition is still too loose.

Write the answer to the third question beside the definition. That note — how you know — is half of this step’s deliverable. Point to the record, not just describe the group.

Public benefit: a test to register, a duty to report

Public benefit is both a test a charity passes to register and something it reports on every year. The starting-a-charity hub treats public benefit as the registration test, in Show public benefit and Public benefit in the three jurisdictions. This hub treats it as the annual reporting duty — the same concept, a different obligation.

Three nations, three mechanisms

The annual report duty is not one rule with local footnotes. England and Wales and Northern Ireland each have two obligations. Scotland has one, for a structural reason. The table sets the three side by side; the detail follows.

	England and Wales	Scotland	Northern Ireland
Where the duty sits	reg. 40 of SI 2008/629	SSI 2006/218 reg 9(1)(d) and Schedule 2 paragraph 9 (the SORP, for fully accrued accounts)	SR 2015/384 reg 32, extended by reg 33(2)
Activities framed “for the public benefit”	Yes	No — a summary of main activities and achievements	Yes
Separate statement about having regard to guidance	Yes — the Commission’s public benefit guidance	No	Yes — CCNI’s guidance

England and Wales: two obligations

In England and Wales, the reporting duty is not in section 17 of the Charities Act 2011. That section binds the Commission. Its one duty on trustees is to “have regard to” the Commission’s guidance — a duty to have regard, not a duty to report.

In England and Wales, the duty is in reg. 40 of SI 2008/629, and the report must contain two things:

• your activities and achievements, framed as furthering your purposes for the public benefit
• a separate statement of whether the trustees complied with the duty to have due regard to the Commission’s public benefit guidance

A report that does the first and leaves out the second is non-compliant. The second is the one most often missed. Write the public benefit statement for your annual report covers the wording.

Northern Ireland: its own duty, and its own second statement

In Northern Ireland, the duty is in SR 2015/384 reg 32(2)(b)(i). The report must explain, verbatim, “the main activities undertaken by the charity to further its charitable purposes for the public benefit”.

In Northern Ireland, reg 32(2)(c) of the same regulations adds a separate statement. It says whether the trustees have had regard to CCNI’s guidance under s.4(1) of the Charities Act (Northern Ireland) 2008.

In Northern Ireland, reg 33(2) extends both duties to charities that prepare a statement of accounts. So in Northern Ireland they are not confined to the smaller cohort that reg 32 names on its face.

CCNI publishes guidance on exactly this point, called ARR08. We confirmed that it exists and what it covers, but did not read its content, so nothing from it is quoted here.

In Northern Ireland, legislation.gov.uk holds SR 2015/384 only as originally made, with no record of later changes to check. Treat any amendment since 2015 as unknown, not as absent.

This is a parallel duty in its own regulations. It is not “the same as England and Wales”.

Scotland: one narrative, and no second statement

In Scotland, the duty is in SSI 2006/218 reg 9(1)(d) and Schedule 2 paragraph 9. They require, verbatim, “A summary of the main activities of the charity undertaken and achievements in the financial year.”

For a Scottish charity preparing fully accrued accounts, OSCR says the SORP governs the report instead.

In Scotland, Schedule 2’s list never uses the words “for the public benefit”. Nor does Scotland ask for a separate statement about having regard to guidance. That absence was checked three ways.

The reason is structural. Scotland’s charity test is ongoing, not a one-off hurdle at registration. OSCR treats the same achievements narrative as both the report’s content and the evidence that the charity still meets the test.

So do not add a “had regard to guidance” statement to a Scottish report by analogy with England and Wales. It would be a requirement that does not exist.

Scotland: showing how you identify the people you help

OSCR expects a charity that relieves those in need to be able to say how it identifies them. Its guidance on the relief of those in need says this, verbatim. Organisations “should have criteria setting out what they mean by ‘in need’ and how they will identify people who are in need”. It adds: “We expect such organisations to be able tell us how they identify those in need of their help.”

That is regulator guidance, not statute. It still has teeth.

One of OSCR’s own published cases is a refusal. An organisation proposed a volunteer-staffed restaurant to reduce loneliness among its own volunteers. OSCR refused it: “the method of recruiting volunteers did not satisfy us that only those who were genuinely in need could benefit”.

Because the Scottish test is ongoing, this is not only a registration question. The same expectation can return whenever OSCR looks at a charity after it is registered. A Scottish charity should be able to say how it identifies the people it helps.

One limit on that. The guidance page is written for the relief-of-need purpose. Its general expectation reads as applying more widely, but we did not search for worked examples under other purposes.

Scotland: publication of your annual report

In Scotland, write the annual report knowing OSCR will publish it. In Scotland, section 45B of the Charities and Trustee Investment (Scotland) Act 2005 applies from 5 March 2026. It requires OSCR to keep each statement of account, verbatim, “for at least 5 years”, and to make it available for public inspection.

The statement of account includes the trustees’ annual report. OSCR publishes it as sent and no longer deletes personal information first. The only exclusion is the narrow safety one that already applies to a charity’s Register entry.

OSCR’s own advice is that “you may want to consider if it is appropriate to include the names and images of other volunteers or beneficiaries”.

The duty falls on OSCR, not on you, and nothing bans naming a beneficiary. But a Scottish charity describing identifiable people is writing for publication. Define the group, not the individuals. For stories, photographs and consent, see Can we use a photo of the people we help?

How to write the beneficiary definition

The deliverable is one sentence naming the group and one note saying how you know who is in it.

1. Name the group in one sentence, narrowly enough to count.
2. Write beside it how you know who is in it: the register, form or record.
3. Check it against your purposes as written in your governing document.
4. Reuse the same words in your annual report’s public benefit statement.
5. In Scotland, write it as a group, knowing OSCR will publish the report.

With the definition written, the next step is to build your theory of change on it. Everything downstream — indicators, baseline, report — measures change in this group.

Common mistake: defining the beneficiary group too loosely to count

“Young people in the town” feels like a purpose statement, and purposes are written broadly. But NPC defines outcomes as changes in a target group, and a group you cannot count cannot have a measured outcome. Everything downstream — indicators, baseline, report — fails before it starts.

Common mistake: treating public benefit as a question the starting-a-charity hub already settled

The same concept appears in two hubs under two obligations. In England and Wales, reg. 40 asks you to report the activities undertaken to further your purposes “for the public benefit”. That is a question about who benefits, so the definition does legal work in the annual report every year.

Scotland works differently again: its charity test is ongoing, and the annual narrative is how OSCR sees you still meet it.

Worked example

Tollgate Youth CIO’s draft says it helps “young people in the town”.

The manager applies NPC’s definition: outcomes are changes in a target group. So the group has to be one Tollgate can count from its own attendance records. She narrows the wording to the young people who attend Tollgate’s sessions and meet its age range, as recorded at sign-up. No figure is published for the group’s size or age range, so she takes both from Tollgate’s own records.

She writes “source: attendance and sign-up records” beside it. Tollgate is registered in England and Wales, so reg. 40 asks for its activities “for the public benefit” — which presupposes a defined group. The same definition goes, unchanged, into the public benefit section of the annual report.