How do we appoint a charity auditor?
- Time1–3 months if tendering
- CostSee cost.audit.median-by-income-band.uk; dated 2021 data
- Doing itYou need a professional
UK trustees appointing a charity auditor choose a registered auditor, tender if they have not done so recently, and confirm which statute governs the audit. For a charitable company, that may not be the statute you expect. The tests that require an audit differ between England and Wales, Scotland and Northern Ireland.
Do this first
England and Wales: This page sets out the position in full. Scotland: covered, with a different threshold and a different basis — the figure changed too, and it runs from the start of the financial year rather than the end, which produces real collision cases against the English test. Northern Ireland: covered, with a lower threshold than either — and, distinctively, no assets-based test at all.
When is a charity auditor needed in England and Wales?
In England and Wales the trustees must have the accounts audited when the charity meets either of two tests in the Charities Act 2011. Scotland and Northern Ireland set their own tests. Each nation also has its own regulator: the Charity Commission, OSCR and the Charity Commission for Northern Ireland. The table shows the England and Wales tests for a statutory audit.
| Test | A statutory audit is required where |
|---|---|
| Income test | gross income exceeds £1,000,000 for financial years ending before 30 September 2026; £1,500,000 for financial years ending on or after 30 September 2026 |
| Assets test: asset limb | gross assets exceed £3,260,000 for financial years ending before 30 September 2026; £5,000,000 for financial years ending on or after 30 September 2026 |
| Assets test: income limb | and, in the same year, gross income exceeds £250,000 for financial years ending before 30 September 2026; £500,000 for financial years ending on or after 30 September 2026 |
The asset figure never triggers an audit on its own. Whether the charity needs an audit at all, rather than an independent examination, is a separate question. It is settled at Does my charity need an audit, an independent examination, or neither?
The assets test and its income condition
The assets test only bites together with a gross income condition. Under it, a charity’s accounts must be audited only where both limbs are met in the same year. The asset limb is gross assets above £3,260,000 for financial years ending before 30 September 2026; £5,000,000 for financial years ending on or after 30 September 2026. The income limb is gross income above £250,000 for financial years ending before 30 September 2026; £500,000 for financial years ending on or after 30 September 2026.
This is the most often mis-stated fact in the whole hub. Almost every published summary of the 2026 changes gets it wrong or leaves it out. Why the income condition moves by itself is explained in determine your external scrutiny requirement.
A charity well above the old assets figure but below the income figure needs no audit under this limb at all. Do not rely on, or copy, a summary table that shows the two 2026 audit figures without this condition.
The assets test is measured before liabilities are deducted, at the year end.
The new lease rules come from FRS 102, and the current SORP applies them. Under them, many charities bring right-of-use assets onto the balance sheet for the first time. That can push gross assets over the line for a charity that was well below it before. The government gave this as one reason for raising the threshold.
Which statute governs a charitable company’s audit?
A charitable company has two possible audit regimes, and the Companies Act 2006 is tested first. Only one applies at a time. They apply in turn, not together. If the company’s accounts must be audited under Part 16 of the Companies Act 2006, that is the only statutory scrutiny that applies.
The Charities Act audit rules then switch off entirely, including the regulator’s own power to order an audit. Only if the company is exempt from a Companies Act audit do the Charities Act figures switch back on and decide the question.
This catches people out in the same way again and again. A charitable company can be well within “small” under company law and claim the small-companies audit exemption at Companies House (see file with Companies House). It can still need a full statutory audit for the charity regulator. That is because its income or assets cross the quite different charity thresholds.
Its Companies House balance sheet then carries an audit-exemption statement. Yet the same set of accounts carries a full Charities Act audit report for the regulator. That looks like a contradiction. It is correct.
Scotland: a different figure, on a different basis
Scotland’s own audit threshold is £500,000 for financial years beginning before 1 January 2026; £1,000,000 for financial years beginning on or after 1 January 2026. It also runs on a different basis from the English test. Scotland’s threshold applies to financial years beginning on or after the change date. The England and Wales test applies to years ending on or after its own change date.
So a Scottish charity and an English charity with the same year-end dates can land on different rule sets. It depends on when each one’s year began. One basis runs off the start of the year and the other off its end. It is a real collision case, not an edge case to wave away; the year-by-year table is in set your financial year end.
Northern Ireland: the lowest threshold, and no assets test at all
Northern Ireland’s audit threshold is £500,000. It is unchanged since 2008, and now the lowest of the three UK nations by a wide margin. Note the wording with care: the statute says a charity’s income must exceed that figure, not “£500,000 or more”. A Northern Ireland charity with income of exactly that figure does not need an audit, where the equivalent Scottish wording would catch it.
Northern Ireland also has no assets-based audit trigger at all. Applying the England and Wales or Scottish assets test to a Northern Ireland charity is the wrong test.
The one place an assets figure appears in the Northern Ireland law is for group accounts. That provision cannot operate, because the sum it depends on has never been prescribed.
Audit fees and choosing a charity auditor
No published fee scale exists for charity audit, any more than it does for independent examination. Rough median fees by income band come from a December 2021 sector survey. They have not been uprated since. They run from a median of around £1,420 at the smallest band surveyed to several times that as income rises.
The range within each band is wide. Quote the medians with their spread, never a single figure. Fees have risen a lot since that survey. Treat the figures as dated evidence of how pricing is shaped, not as current numbers.
In the same survey, more respondents named fee as an important factor in choosing an auditor than named technical competence. Fee-related concerns were also the largest single type of complaint about auditors in the same data. Charity audit needs SORP expertise. Choosing on fee alone is linked with the same complaint pattern the sector’s own data records.
Once the auditor is appointed, the next step is to prepare the scrutiny file the audit will work from.
Common mistake: not knowing which regime the audit is under
Most charities have only one possible regime. A charitable company has two, and only one applies. Which one applies turns on whether the Companies Act requires an audit at all.
Getting this wrong means the audit report cites the wrong statute. That is a benchmark failure in its own right.
Common mistake: selecting on fee alone
Fee is the easiest factor to see and compare. The sector’s own survey data shows it is the factor named most often. It ranks ahead of technical competence.
Charity audit needs SORP expertise that a general practice audit does not. Choosing on fee is linked with the largest single type of complaint the same survey records.
Common mistake: leaving appointment until after the year end
The audit requirement only becomes certain once the year’s figures are known. So it is tempting to leave the appointment until then.
Suppose an auditor has not observed a year-end stock or cash count, or checked opening balances during the year. That auditor may have to issue a modified opinion for lack of evidence. Lack of evidence was the largest single cause of modified opinions in the regulator’s own data.
Worked example
Saltmarsh Trust is a charitable company with a trading subsidiary. It sits below the Companies Act 2006 size limits and claims the small-companies audit exemption at Companies House. Its balance sheet there carries an audit-exemption statement. Its income and assets are still well above the Charities Act 2011 audit thresholds.
So it needs a full statutory audit for the charity regulator, whatever its Companies House filing says. Both things are true about the same set of accounts at the same time. Saltmarsh’s engagement letter names the Charities Act as the statute the audit is carried out under. The auditor, the trustees and the regulator then have no doubt about which regime produced the report.
What you should have at the end
A signed audit engagement letter with a registered auditor.
The letter fixes, in writing, which statutory regime the audit is carried out under, what the auditor needs, and by when. The answer then does not depend on anyone's memory once fieldwork starts.
Common questions
Appoint the auditor before the financial year ends. The need for an audit only becomes certain once the year's figures are known. But an auditor appointed later cannot observe a year-end stock or cash count. That auditor may then have to issue a modified opinion for lack of evidence.
A registered auditor can audit a Scottish charity's accounts. The Scottish accounts regulations also admit the Auditor General for Scotland and auditors appointed by the Accounts Commission for Scotland.
The Companies Act 2006 comes first. Where Part 16 of that Act requires an audit, the Charities Act (Northern Ireland) 2008 audit rules do not apply. Only if the company is exempt from a Companies Act audit do the Northern Ireland charity rules decide, as in England and Wales.
Terms on this page
Sources
- The Charities Acts 1992 and 2011 (Substitution of Sums) Order 2026 (SI 2026/427)
- Charities Act 2011, section 144 — Audit of accounts of larger charities
- Charities Accounts (Scotland) Amendment Regulations 2025
- Policy Note to the Charities Accounts (Scotland) Amendment Regulations 2025
- Charities Act (Northern Ireland) 2008, section 65 — Audit or examination of accounts
- Charities Act 2011, section 147 — Accounts required to be audited under Companies Act
- Charity reporting and accounting: the essentials (CC15d)
- Charity Audit Survey 2021 (Charity Finance magazine, December 2021)
- Statutory audit costs
- The Charities (Accounts and Reports) Regulations (Northern Ireland) 2015 (SR 2015/384)
- Accounts monitoring review: auditors' and independent examiners' compliance with their responsibilities