How do we answer a query on our charity registration?

England and Wales: This page sets out the position in full. Scotland: covered, with a materially different and more elaborate route if OSCR refuses or removes you — a four-stage review and appeal chain, running through a body most older sources get wrong — see below. Northern Ireland: covered, with a distinctive option partway through: CCNI may offer to let you amend your governing document rather than simply refusing — see below.

What a registration query usually means

A charity registration query almost never means your application was a bad idea. It usually means the answer given was too generic to assess. The Charity Commission, OSCR and CCNI all query vague answers. Each handles a refusal in its own way.

This page assumes your application is in and the trustees have decided how to operate while you wait. It covers England and Wales, Scotland and Northern Ireland in turn. The Charity Commission’s stated reasons for querying or returning an England and Wales application include:

• not answering all the questions fully
• not using a model or approved governing document
• not writing the charity’s purposes clearly
• not fully explaining how the purposes are for the public benefit and how they will be carried out for it
• the charity’s purposes being new or unusual

One reason needs a closer look. It is new, and it may affect how you draft your own application. The Commission’s words are:

“you or a third-party adviser(s) have used generic text, including text generated through AI tools, which is not specific to the charity you want to register.”

This does not mean “do not use AI tools”. It means generic text fails review, whatever produced it. A response, or a first application, has to fit your charity’s own purposes. It also has to fit your own plan for carrying them out. It cannot be a template with the name changed.

Keep these terms apart. A query asks you for more details or clarification.

A return sends the whole application back for you to resubmit, because it is unclear or incomplete. A rejection is a decision that the application does not meet the charity test at all. Each has a different remedy, covered below for a rejection.

How long the Commission may take to come back to you

The Commission’s current wording covers times of high demand. At those times it may take up to 45 working days to come back to you with a query or a request for clarification. Treat this as a snapshot of current conditions, not a fixed service standard.

The Commission itself calls this a temporary position. That figure is also the time to raise a query, not the time to reach a final decision.

The total time to registration is the query wait, plus the time you take to reply, plus the Commission’s own assessment time. It can run to several times that figure. The explainer on what it costs and how long it takes sets out the whole wait.

Scotland: OSCR’s questions and the route to the Tribunal

OSCR can ask for any further information or documents it thinks it needs. It uses that power often, not as a last resort. An application must contain a fixed list set by law:

• your statement of purposes
• a copy of your constitution
• your latest accounts, if you have any

OSCR’s own guidance says vague or incomplete first answers are one of the most common reasons an application takes longer.

If OSCR refuses or later removes you, many older sources still describe the wrong way to challenge it. The “Scottish Charity Appeals Panel” no longer exists. It was abolished on 12 January 2018. Its functions passed to the First-tier Tribunal for Scotland.

Any source that still names the Panel describes pre-2018 law. Many other sources have never been updated.

The route that replaced it runs in stages. First, you ask OSCR for an internal review. The request is due within a fixed number of working days of the first decision. If OSCR confirms its decision on review, you can appeal to the First-tier Tribunal for Scotland. That appeal also has a fixed time limit, counted from the confirmation.

If the Tribunal sends the matter back, OSCR must reconsider within a further fixed, short period. It must then issue a fresh reasoned decision.

A narrow route to the Court of Session survives too. It is only for an appeal against a decision to suspend someone. It is not for a general challenge to a registration refusal.

This guide gives no figure for the time limits in that chain. See the Act itself, linked below, for the exact windows.

Northern Ireland: CCNI’s queries and the offer to amend

If CCNI needs more information on your application, it will contact you. It will say what it needs and by when. If you do not respond, the application may be delayed. In the end, CCNI may refuse it. A refusal means starting again with a fresh application, not just sending the missing piece.

CCNI’s own service standard: CCNI aims to complete assessment and decide 60% of applications within six months of submission — a service standard, not a statutory deadline. Speed depends on application quality, volume, complexity and whether further information was needed.

Unlike the Commission, CCNI may offer you the chance to amend your governing document during the process. For example, the change could remove a problem with the purposes or public benefit that would otherwise lead to refusal. The charity’s own trustees decide whether to accept that offer, not CCNI. If your application is refused after the offer was declined or never made, CCNI writes to explain the decision.

You may then reapply once you have amended your governing document so the purposes are exclusively charitable.

A decision may also be challenged in two ways. One is CCNI’s own decision review procedure. Where possible, the review goes to someone who did not make the first decision. The other is to seek a review from the Charity Tribunal for Northern Ireland.

CCNI shows a decision to register on the public register. It does not usually publish a decision not to register. It may do so if it sees a strong reason. One example is a decision that would set a precedent for other bodies.

If your England and Wales application is refused

If the Commission rejects your application, it confirms its reasons in writing. You then have three options. Over time, you can use more than one:

• reapply having addressed the reasons given
• ask the Commission to review the decision internally
• or appeal to the Charity Tribunal

Once the regulator accepts your application, the next step is to record your registration details.

Common mistake: resubmitting the same text with minor edits

The applicant thinks the first answer was good enough. They treat the query as a formality to clear. Generic wording and an incomplete explanation are among the Commission’s own named causes of query. Restating them brings another query and another wait, not a resolution.

Worked example

Wrenfield Village Hall applies to register. The regulator asks how its purposes will be carried out for the public benefit. The weak answer restates the purposes clause.

The answer that closes the query sets out how the hall will carry out its purposes. It says who the hall serves and what activities run there. It also shows how those activities produce the public benefit claimed. The answer does not repeat what the purposes already say. It adds the missing account of how they are put into practice.