What questions does the charity annual return ask?

Applies in: England and Wales

England and Wales: this page sets out the complete question set, with every gate. Scotland: partly covered — OSCR’s return has no single fixed question list at all, it varies by legal form; the three-section structure is set out below, but the individual questions were not read line by line. Northern Ireland: not researched for this page; do not read the England and Wales position across.

The charity annual return is the yearly online return a charity in England and Wales sends to the Charity Commission, completed by its trustees. Every CIO files one, and so does any other charity above an income floor. The full list of charity annual return questions, with every gate, is below.

No AI question and no cyber security question

The annual return has no AI question and no cyber security question. This site previously said otherwise, and this site was wrong.

The claim that the annual return added questions about AI use or cyber security has circulated widely across the sector. It is not true of the 2025 return and it is not true of the 2026 return.

Three things make that a settled answer rather than a failure to find something:

• The Charity Commission’s question guide was read end to end — all eight sections, in full, not by keyword search — and neither topic appears.
• One guide governs both the 2025 and the 2026 returns. There is no later document in which the questions could be hiding.
• The claim has now been independently disproved three times across this project, by different methods and in different hubs.

The practical cost of the myth is that charities have prepared answers, and in some cases commissioned policies, for questions that do not exist.

If you have been told to have an AI policy ready for the return, you have been told wrong. Two policies in the return’s list do sit near this territory, and both are real. They are a campaigns and political activity policy and a social media policy. Both appear under section 7 in the table of questions.

Charity annual return questions, with their gates

The table lists every question, what it asks, the gate that switches it on, and when it was introduced.

Ref	What it asks	Gate	Introduced
—	Financial period	None — every charity answers	Pre-2023
—	Gross income and gross spending, on the accounts basis used	None — every charity answers	Pre-2023
1.1	Number and total value of contracts from central government or a local authority	None — every charity answers	Pre-2023
1.2	Number and total value of grants from central government or a local authority	None — every charity answers	Pre-2023
1.3	Income breakdown across donations and legacies, charitable activities, other trading, investments	gross income £500,000 OR LESS **and** grants or contracts under 70% of income	2023
1.4	Single highest donation from a corporate donor, an individual, and a related party	gross income OVER £100,000	2023
2.1	Whether grant making is the main way purposes are carried out; grants to individuals, other charities, non-charities; whether any recipients are related parties	None — every charity answers	2023
2.2	What trustees were paid for (five options); whether any trustee resigned and took up employment	None — every charity answers	Pre-2023
3.1	Income from outside the UK by source type, and how much moved by a method other than the regulated banking system	No explicit income gate stated in the question guide for section 3 — see the note on the overseas questions after this table	Pre-2023 (non-banking breakdown: 2023)
3.2	Charitable activities delivered outside the UK; countries; formal written agreements with delivery partners	None — every charity answers	Pre-2023
3.3	Spending outside the UK, in total and by the same non-banking transfer methods as 3.1	No explicit income gate stated in the question guide for section 3 — see the note on the overseas questions after this table	Pre-2023 (transfer-method breakdown: 2023)
4	Trading subsidiaries: existence, dissolutions in the period, trustees who are also directors	None — every charity answers	Pre-2023
5	Property held by holding or custodian trustees, excluding the Official Custodian	Unincorporated charities only	Pre-2023
6.1	Headcount by employment type, how many work outside the UK, and total spent on employee payroll	None — every charity answers	2023
6.1	Employees with total benefits above the trigger, by band, and the highest paid employee’s total benefits	£60,000 benefits trigger	Pre-2023
6.2	Estimated number of volunteers, excluding trustees, active in the UK	None — every charity answers	Pre-2023
7	Which named policies and procedures were in place at period end	None — every charity answers	Pre-2023
8.1	Whether services were provided to children and/or adults at risk	None — every charity answers	2023
8.1	Whether DBS checks were obtained at the required level for all eligible roles	None — every charity answers	Pre-2023
8.2	Whether all serious incidents have been reported, including historical ones	gross income OVER £25,000	Pre-2023
8.3	External risk and impact — estimated positive and negative impact across named categories	Conditional — included only in exceptional circumstances	Pre-2023

Reading it, four things are worth knowing before you start.

Questions marked as introduced in 2023 are the only ones whose history the guide explains. The Commission’s guide includes a “why did we start to ask this question in 2023?” note for the 2023 additions and nothing for the rest.

So a question recorded as “pre-2023” means only “not introduced in 2023”. It does not pin down when the question was introduced.

That gap has been recorded honestly rather than guessed at. It matters because readers often mislabel older questions as new.

The overseas questions want data most charities do not keep. Sections 3.1 and 3.3 ask for income and spending outside the UK, broken down by country, by source type and by transfer method. They include how much moved outside the regulated banking system.

That data is not in most charities’ accounts. It is the most common reason a return stalls half-finished.

The return computes gross income its own way. It is not the total income line in your statement of financial activities. Endowment received in the year comes out. Endowment converted into income funds goes back in. Revaluation and investment gains are left out. Use the return’s computation, not the accounts’ headline.

Section 7 asks about thirteen policies. The Commission says it expects six of them. 13 policies are asked about; 6 are the ones the Commission expects a charity to have. Answering honestly that you do not have the other seven is not an admission of failure.

The gate that runs backwards

For one question, growing means answering less. Most people assume that growing means answering more questions.

Question 1.3 asks for a breakdown of income across donations and legacies, charitable activities, other trading and investments. Only charities at or below an income ceiling, whose grants and contracts are under a share of total income, answer it. A charity whose income rises through that ceiling stops having to answer it. The gate is in the row for 1.3 in the table of questions; do not restate it from memory.

Other gates run the ordinary way:

• the single-largest-donation question switches on above an income figure
• the serious incident declaration switches on above another income figure
• the highest-paid-employee bands switch on above a benefits figure
• the custodian trustee property question applies to unincorporated charities only

One question, on external risk and impact, is conditional. It is included only in exceptional circumstances.

The declaration that carries criminal risk

One question in the return carries criminal risk: the serious incident declaration. Most of the rest is data collection.

The serious incident declaration — confirming that all serious incidents have been reported, including historical ones — is what gives serious incident reporting its legal force. It reads like a tick-box and it is not one. Giving the Commission false or misleading information, knowingly or recklessly, is an offence. On indictment it carries a much heavier penalty than most trustees assume.

Practically: do not answer that question until any outstanding incidents have been reported. If you find one while completing the return, report it first and then come back. Whether an event counts is set out where you recognise a serious incident.

Who has to file an annual return?

The annual return is a separate filing from the accounts and the trustees’ annual report, with its own trigger.

• Below an income floor, no annual return is required; the mechanism is recorded.
• The floor does not apply to a CIO. A CIO files a return whatever its income; what else it owes is set out where you confirm which filings actually apply to you. This is one of two separate overrides, in brackets, in two different sections of the Act. The other does the same job for the annual report. Both are easy to miss.
• The content of the return is prescribed by regulations made by the Commission, not by the Act. That is why the question set can change without any change in the law.
• The Commission may dispense with the requirement for a charity or a class of charities.
• The deadline runs to the same date as the annual report deadline — 10 months from the financial year end.

One drafting oddity, recorded honestly. The deadline provision sets the return’s date by reference to another date. That is the date on which the trustees are required, by virtue of the annual report provision, to transmit the report.

But that provision by its own terms bites only above the report filing trigger. For a non-CIO charity between the return floor and the report trigger — which does owe a return — the referenced date is not cleanly fixed. The natural reading is that the period is imported by reference regardless. The Commission runs one deadline for all returns in practice.

This is untidy drafting, not an uncertain deadline. Do not treat it as licence to file late.

Scotland and Northern Ireland

Both have their own returns, and neither’s question set matches this page’s England and Wales list. Do not read this page’s gates or question numbers across to either.

Scotland is different, not unresearched. OSCR’s return has no single fixed question list at all. The questions vary by legal form and other circumstances. So no Scottish list can be complete or incomplete in the way the England and Wales list is.

What is established is the form’s three-section structure. More important, there is no income floor. Every registered Scottish charity files everything, every year, from zero income upward, dormant charities included. The individual questions within each section were not read line by line for this page. Scottish deadlines and submission contents are covered where you complete the OSCR annual return.

Northern Ireland: not researched for this page; do not read the England and Wales position across. CCNI’s own annual monitoring return has not been read question by question.

Preparing and filing the return

• Step 6 — Gather your annual return data. Work against the question list before you log in, not after. The overseas transfer-method fields are the ones nobody has to hand.
• Step 7 — Complete the annual return, and record the submission reference.

If you have found an unreported serious incident while reading this, deal with that first: Step 18 — Make a serious incident report.

The serious incident declaration is the one place in the return where a careless answer creates criminal exposure. If you are unsure whether something should have been reported, the Commission answers questions free. LawWorks and Advocate give free legal help to charities.

Correction note. An earlier version of this site stated that the annual return asks about artificial intelligence and cyber security. It does not, and did not. Logged in the corrections journal.