How do we choose and appoint an independent examiner?

England and Wales: This page sets out the position in full. Scotland: covered, with a different trigger — the qualification requirement turns on whether you prepare accruals accounts, not on an income figure, so read the Scotland section before assuming the English figure applies. Northern Ireland: covered, with a different income figure and a different list of eligible bodies from both England and Wales and Scotland — see below.

Who can be an independent examiner?

An independent examiner is a person, independent of the charity, whom the trustees appoint to examine its accounts. The mistake the regulators see most often is to appoint a trustee, or someone else who is not independent. It feels efficient, not risky. Someone on the board has the skills and will do the work for free.

The Charity Commission said a charity that did this was “in clear breach of both the trustees’ and the examiner’s duty to ensure that the person carrying out the examination is independent of the charity.” OSCR in Scotland has found the same thing.

Checking for conflicts is not a courtesy. It is one of the examiner’s own binding Directions. These are the rules an examiner works to, and they carry legal force.

In England and Wales, Scotland and Northern Ireland alike, the examiner must be independent. What differs is when they must also be qualified. This page assumes the charity needs an examination rather than an audit. If that is not settled, first determine your external scrutiny requirement.

When must the examiner be qualified in England and Wales?

In England and Wales the examiner must be qualified above £250,000 for financial years ending before 30 September 2026; £500,000 for financial years ending on or after 30 September 2026. A qualified examiner is one who is also a member of a professional body listed in the Charities Act 2011. Fellows of the Association of Charity Independent Examiners count too.

Below that figure a lower bar applies. The examiner need only be an independent person who the trustees reasonably believe has the ability and practical experience needed. The law asks for nothing more.

The law also sets a floor below that bar. At or below £25,000 for financial years ending before 30 September 2026; £40,000 for financial years ending on or after 30 September 2026 a charity has no statutory duty to have its accounts examined or audited. The accounts and trustees’ annual report still have to be prepared.

A separate, lower income figure can still require you to send them to the regulator. That figure has not changed. No examination does not mean no paperwork. The band that files accounts nobody has to check sets out what that gap does and does not change.

Being qualified makes a difference you can measure. In the Commission’s own 2019 review, 44% of accounts checked by a qualified examiner met the external scrutiny benchmark. For an unqualified examiner the figure was only 18%.

Raising the threshold moves every charity between the old and new figures out of the group with the higher pass rate. It moves them into the group with the lower one. Those charities save money, and the Commission’s own data shows accounts reviewed by unqualified examiners met the benchmark far less often.

Trustees in that band can weigh this up. They may still choose a qualified examiner, even where the law no longer needs one.

Which Scottish charities need a qualified examiner?

In Scotland the need for a qualified examiner turns on preparing accruals accounts, not on any income figure. So it catches:

• every charitable company, at any income level
• every registered social landlord, community benefit society and further or higher education body
• any small charity that prepares accruals accounts by choice, or because a funder requires it

Calling the Scottish rule “£250,000“, by analogy with the old English figure, greatly understates who it reaches. If a Scottish charity prepares receipts and payments accounts instead, no qualification is needed. An independent person who the trustees reasonably believe is competent is enough. This is the same lower bar as in the English test.

The list of eligible examining bodies also changed outright from 1 January 2026. The Association of Authorised Public Accountants was removed. The Institute of Chartered Secretaries and Administrators was renamed the Chartered Governance Institute.

Neither change was put off to later financial years. Both took effect at once. That includes the examination of earlier years carried out after that date. Check the current list before you appoint. Regulator guidance pages sometimes lag behind a change like this.

Northern Ireland: its own figure, and its own list

Northern Ireland sets its own trigger for a qualified examiner at £250,000. This figure has not changed since 2016. It differs from both the English and Scottish figures. Its list of eligible bodies also split from Scotland’s on the day the Scottish list changed.

Northern Ireland’s list still includes the Association of Authorised Public Accountants. It still uses the old name for the Chartered Governance Institute. It also includes the Certified Public Accountants Association, which neither of the other nations does. An examiner who qualifies in one nation does not automatically qualify in another.

The engagement letter: agreeing the scope in writing

An engagement letter is the signed letter that sets out the examiner’s scope in writing. It confirms independence and records the qualification check. It also says whether preparing the accounts is part of the job. That last point matters most.

Agree in writing whether the examiner will also prepare the SORP-format accounts, or only check them. Leaving this open is the single largest driver of cost. It is also the most common cause of fee disputes.

Two quotes that trustees compare are often not like for like. One may be for the examination alone. The other may also cover preparing the accounts from a trial balance.

Preparing the accounts also raises its own question of independence. You have to manage it actively, not assume it away.

What does an independent examiner cost?

There is no set fee. No professional body sets, caps or recommends an examiner’s fee. The examiners’ own association, the Charity Commission and several other bodies confirmed this. Rough figures run from about £360 at the smallest income band to about £900 near the qualified-examiner threshold.

These figures are dated. They show the bottom of the market, not a benchmark. Fees rise well beyond them, often several times over, once preparing the accounts is part of the job.

VAT matters more here than it might elsewhere. Most charities cannot get it back, so the price with VAT is the real cost. The reliefs a charity can get are in identify and claim your VAT reliefs. Some small examiners are not VAT-registered at all. In effect that is a discount at the same headline price.

With the engagement letter signed, the next step is to prepare the scrutiny file the examiner will work from.

Common mistake: appointing a trustee, or someone otherwise not independent

Someone on the board has the skills and will do it for free. It feels efficient, not risky. The Commission and OSCR have both found charities in clear breach of the duty to make sure the examiner is independent. Checking for conflicts is one of the examiner’s own binding Directions, not an optional courtesy.

Common mistake: an unqualified examiner once income passes the threshold

The charity has used the same person for years. Nobody checks again when income crosses the line. The examination is then invalid and must be redone. The regulator has required this.

The reverse also happens. When a threshold rises, some charities no longer need a qualified examiner at all. Yet the Commission’s own data shows a qualified examiner gets a much better result.

Common mistake: not agreeing in writing whether the examiner is also preparing the accounts

Some trustees assume it is part of the job, others assume it is not, and nobody checks. This is the single largest cause of cost differences at the small end, and the source of most fee disputes. It also raises its own question of independence, which then has to be managed.

Common mistake: the examiner’s report signed by a firm rather than by the named individual

In audit it is normal for a firm to sign, so it feels like the safe default here too. OSCR found this in its own published samples. It had to contact the charities to put it right. The report must be signed by the named person who carried out the examination.

Worked example

Tollgate Youth CIO needs an independent examination, and its income sits below £250,000 . It gets two quotes before it appoints anyone. One is for the examination alone. The other, from a different firm, turns out to include preparing the SORP-format accounts from Tollgate’s own trial balance.

The figures cannot be compared until that is spelled out. Once it is, the board can see that the second quote is not just more costly. It is a different piece of work. The engagement letter that goes out states the scope in one sentence: examination only, accounts already prepared in-house.