Charity Commission annual return 2026: a trustee's walkthrough

The annual return for financial years ending in 2026 opened on 31 July 2026. You have ten months from the end of your financial year to file, so a charity whose year ended on 31 December 2025 must file by 31 October 2026. What you actually have to send depends on your income — and on whether you're a CIO, which changes the rules entirely. This walkthrough covers who files what, every section of the form, and the policy question that catches most small boards out.

First: what is the annual return, and what isn't it?

The annual return is an online form. You log in, answer questions about your charity, and submit.

It is not your accounts. It is not your trustees' annual report. Those are separate documents that you may also have to upload at the same time.

This sounds obvious written down, and it is still the single most common misunderstanding the Charity Commission finds. When it reviewed small charities' reporting, it found trustees who "believed that the annual return and the accounts are the same thing" and others who "thought that completing an annual return was all that they needed to do". If you take one thing from this guide, take that: for most charities over £25,000 there are four things, not one — the online return itself, plus three documents you upload with it.

Does this apply to your charity, and what must you send?

Work down this list and stop at the first row that describes you.

If your charity is a CIO — any income at all. You file a full annual return, and you send your trustees' annual report and your accounts, whatever your income. There is no small-CIO exemption. This is set out in the Charities Act 2011 itself, not just in guidance: the under-£10,000 relief from filing a return expressly does not apply to a CIO, and the duty to send the annual report applies to a CIO "whatever the charity's gross income is". If you registered in the last few years, there's a good chance you're a CIO — check your entry on the register if you're not sure.

Income under £10,000 (and not a CIO). You only need to report your income and spending. Select "Annual return" from your available services when you log in. You aren't taken through the full question set, and you don't upload documents.

Income between £10,000 and £25,000. You answer the annual return questions. You do not need to include any other documents.

Income over £25,000. You answer the annual return questions, and you upload three documents: your trustees' annual report, your accounts, and your independent examiner's report — or your auditor's report, if you need an audit. You'll also be asked to declare that there are no serious incidents you haven't already reported.

Do you need an audit rather than an examination? Currently an audit is required if income is over £1 million, or if gross assets are over £3.26 million and income is over £250,000. Below that, an independent examination is enough. Note that these thresholds are expected to change from 30 September 2026 — see the end of this guide.

Your deadline

Ten months from the end of your financial year. The Commission's own worked example: "if your financial year end is 31 December your deadline is 31 October the following year."

Applying that rule to the common year ends:

The law does allow the Commission to permit a longer period "for any special reason", but there is no published process for asking, so treat the ten months as firm.

One practical trap before you start: if a previous year's return is still outstanding, the system will not let you file this year's. You must clear the backlog first. If you've just taken over as treasurer or chair and inherited a mess, that is the thing to check today rather than in October.

A second trap: if your financial year end has changed and the period shown on the form is wrong, the trustees have to get the Commission's records corrected before the return and accounts can be submitted. That takes time you won't have in the last week.

What you'll be asked, section by section

The question guide is organised into eight numbered sections, after a couple of preliminaries. Which ones you see depends on your income — the questions are grouped so that smaller charities answer fewer of them. Every charity in scope answers the core set; extra questions unlock above £25,000, above £100,000, and above £500,000. Charities over £500,000 face a substantially longer financial section that asks for the accounts data line by line, which isn't covered in detail here.

Financial period. Confirming the year you're reporting on.

Income. Your total gross income, then a breakdown by source. Take care here — gross income is not the same as total money received, and the calculation differs depending on how you do your accounts.

If you do receipts-and-payments accounts, start from total receipts, then:

• take off endowment received, loans received, and proceeds from selling fixed assets or investments
• add anything transferred out of endowment into income funds

If you do accruals accounts, start from total income in your statement of financial activities, take off endowment received, and add transfers out of endowment. The loan and sale-proceeds deductions don't arise, because those were never income in the first place.

Either way, gains on revaluing assets or investments are not income.

Getting this wrong is common. The last time the Commission checked (a 2018 review of 2015 returns), only 62% of small charities had income and expenditure figures that agreed with their own accounts — against 89% for charities over £25,000.

You're also asked, whatever your size, for the number and total value of any contracts and any grants you received from central government or a local authority. Those are easy to answer if you track them and painful if you don't, so it's worth knowing before you open the form.

Spend. Your total expenditure, and where it went. If you make grants, note that the grant-making questions only open up if making grants is the main way your charity carries out its purposes — not if you happen to have made one.

Activities outside the UK. Whether you received income from outside the UK or spent money outside it, which countries, and how the money moved. There are specific questions about money moved outside the regulated banking system. "Country" here means where the money actually came from or was spent, not where the donor or beneficiary lives — the Commission's own example is that a grant to people displaced from Ukraine but living in Poland is money spent in Poland.

Trading subsidiaries. Whether you have any, and their details.

Property. Only unincorporated charities — trusts and unincorporated associations — see this, and it asks one narrow thing: whether any of the charity's properties were held on its behalf by holding or custodian trustees during the year, excluding the Official Custodian for Charities. It is not a general question about what you own. If you're a CIO or a charitable company, you skip it.

Employees and volunteers. Headcount split by permanent, fixed-term and self-employed; how many work outside the UK; total payroll spend; whether anyone received total employment benefits of £60,000 or more, and if so the salary bands, plus the total benefits of your highest-paid employee. You're also asked for an estimate of volunteer numbers, excluding trustees.

Governance. Trustee payments, conflicts, and the policy question below. On trustee payments you're asked what any trustee was paid for, excluding out-of-pocket expenses — being a trustee, a role in a trading subsidiary or connected organisation, providing goods or services, other, or none. You're also asked whether any trustee resigned and then took up employment with the charity.

Safeguarding and risk. Whether you provide services to children or adults at risk, and if so whether you've obtained the required level of DBS check for every eligible role — explicitly excluding basic DBS checks. Plus the serious incident declaration.

One thing that is not in the 2026 return, despite trustees often expecting it: there is no general question about your fundraising.

The policy question — the one worth preparing for

In the governance section you'll be asked which policies and procedures your charity had in place at the end of the financial period. It's tick-all-that-apply, and the list runs to thirteen:

• internal charity financial controls
• safeguarding
• financial reserves
• complaints
• serious incident reporting
• internal risk management
• trustee expenses
• trustee conflicts of interest
• investing charity funds
• campaigns and political activity
• bullying and harassment
• social media
• engaging external speakers at charity events

Nobody expects a small charity to tick all thirteen. What matters is which ones the Commission says it expects. In its own words, it "expects most charities to have" policies and procedures on: internal financial controls, financial reserves, risk management, trustee expenses, trustee conflicts of interest, and serious incident reporting. It adds that it "may also be appropriate" to have policies on investing charity funds, political activity, and bullying and harassment.

That's a clear steer. If you're missing one of those six, the honest answer is to leave the box unticked — never tick a box for a policy you don't have — and then put writing it on the agenda for your next meeting.

We publish free, plain-English templates for several of these, with no sign-up: reserves, risk management, conflicts of interest, safeguarding and complaints. If you want the full picture first, what policies does a charity need maps all of them against what actually forces you to have one.

What becomes public

Your trustees' annual report and accounts are published on the register in full — including any personal information inside them, which is worth remembering before you paste a home address or a beneficiary's story into the report.

Also published: your charity's public address (and the Commission warns that if you give a private address here, that is what gets published), trustee details and trustee payments, and the salary bands you enter for anyone on total employment benefits of £60,000 or more. Separately, employment details of individuals named inside your accounts or report are published only where the charity has three or more employees.

Not published: the name, email and telephone number of whoever submitted the return, and the headquarters administrative address.

The Commission keeps the latest five years of returns and accounts on the public register.

If you miss the deadline

It shows. Your entry on the public register displays your filing status — charities that are up to date show "Charity reporting is up to date (on time)", and those that aren't show either the number of days late or "Overdue", with a running count.

Beyond the public record, the Commission is direct about how it views this: "Failure to submit the annual documents to the Commission may be a criminal offence. The Commission also regards it as misconduct and/or mismanagement in the administration of the charity."

In practice, it runs a standing "double defaulter" inquiry into charities that have defaulted two or more times in the last five years. In its 2024–25 report on that inquiry it used its statutory information powers 78 times and issued 130 orders directing trustees to file. Two charities were found to have ceased to exist or stopped operating — one was removed from the register and one was in the process of being removed. There is no published evidence of financial penalties for filing late, but being named in a statutory inquiry is not a small thing for a charity that depends on funders' confidence.

Fixing a mistake after you've submitted

The Commission cannot amend a submitted return for you.

If the error is in the return itself, you have to apply in writing to request a full reset. After the reset you complete the whole return again and resubmit.

Weigh that up before you ask. The Commission warns that when a return is resubmitted, the new submission date is the one that appears on the public register — so correcting a small error in November, having filed on time in September, can turn an on-time entry into a late one. Judge the materiality of the mistake against that.

If the error is only in the documents — the accounts or the trustees' annual report — you can simply re-upload the correct versions through your account. No reset needed. That's a much easier path, so it's worth establishing which kind of error you actually have before you write to anyone.

How you actually file

Through My Charity Commission Account. Each person needs their own account with their own individual email address and password — not a shared login.

The charity contact is the primary administrator and can see all services. Trustees can be invited to set up their own accounts and get access to everything except other trustees' personal details. You can also invite a third party — a bookkeeper or an examiner — and give them access to specific services only.

Whoever submits has to give their name, role, phone number and email in a declaration. It is worth being clear-eyed about that declaration: it is a criminal offence to knowingly or recklessly give the Commission information that is false or misleading in any significant way.

If you get stuck, the Commission's contact centre is on 0300 066 9197.

Has anything changed for 2026?

For the annual return itself: no. The content is set by the Charities (Annual Return) Regulations 2024, which apply to financial years ending on or after 1 January 2025, and the Commission published a single question guide covering both 2025 and 2026. The question set you'll see this year is the one you saw last year.

What has changed is everything around it, and two of those changes are easy to confuse with the return:

SORP 2026 applies to reporting periods starting on or after 1 January 2026. For most charities that means it affects the accounts you'll file in 2027 or 2028, not this year's. It only applies at all if you prepare accruals accounts. See SORP 2026 for trustees.

The accounts thresholds are expected to change from 30 September 2026, for accounting years ending on or after that date:

• independent examination: £25,000 → £40,000
• the point at which your examiner must be professionally qualified: £250,000 → £500,000
• the receipts-and-payments option: £250,000 → £500,000
• audit on income: £1 million → £1.5 million
• audit on assets: £3.26 million → £5 million, and the income condition attached to that asset test rises from £250,000 → £500,000

That last one matters to charities that are asset-rich and income-poor. A village hall with £300,000 of income and £4 million of land currently needs a full audit; on these figures it would not.

Two cautions. First, the date is not settled: the Commission says 30 September 2026 and the government's response to its own consultation says 1 October 2026, and the official wording is still "expected" — so treat it as provisional until the regulations are actually made.

Second, and this is the one that catches people: the £25,000 threshold for filing your report and accounts is not changing. The government has said it intends to keep it. So from late 2026 the filing threshold and the examination threshold come apart — a charity with £30,000 of income will still have to file its report and accounts, but may no longer need an independent examination.

Neither of these changes the annual return's own income thresholds, which are fixed by the 2024 Regulations.

A sensible way to run it

Put the deadline in the board calendar the day your year ends, not the month before it's due. Decide at that meeting who is doing it — in most small charities it's the treasurer with the chair checking — and minute that decision, because the person who files needs to be able to show the board approved the report and accounts they're uploading.

Then, when the form asks which policies you have, you're reading off a list you already maintain rather than trying to remember in October what the board agreed in March.

Common questions

When is our annual return due? Ten months after the end of your financial year. If your year ended 31 December 2025, your deadline is 31 October 2026. If it ended 31 March 2026, you have until 31 January 2027.

Our income is under £10,000. Do we still have to file? You still have to report your income and spending — but you're not asked the full question set. The exception is a CIO: if your charity is a CIO you file a full annual return whatever your income, and you send your report and accounts too.

What's the difference between the annual return and the accounts? They're two different things, and confusing them is one of the most common mistakes the Charity Commission finds. The annual return is an online form of questions about your charity. The trustees' annual report and accounts are separate documents you upload alongside it if your income is over £25,000, or if you're a CIO.

The form asks which policies we have. Do we need all thirteen? No. It's a tick-all-that-apply list, not a checklist you must complete. The Commission says it expects most charities to have six of them: financial controls, reserves, risk management, trustee expenses, conflicts of interest, and serious incident reporting.

What happens if we file late? Your entry on the public register shows it — it will say how many days late you were, or "Overdue". The Commission treats persistent default seriously and runs a standing inquiry into charities that default two or more years in five. It says failure to file may be a criminal offence.

We've realised we made a mistake on a return we already submitted. Can we change it? The Commission can't edit it for you. For the return itself you have to write and ask for a full reset, then complete it again — but weigh that carefully, because the Commission warns the resubmission date is what appears on the public register, so a late correction can turn an on-time filing into a late one. If it's only the accounts or report that were wrong, you can simply re-upload the correct documents — no reset needed, and no effect on your filing date.

Can't file because an old return is outstanding? That's by design. You must submit any annual returns from previous years before the system will let you submit the current one. If you've inherited a backlog, that's the first thing to clear.

This guide covers charities registered in England and Wales. Charities registered in Scotland (OSCR) or Northern Ireland (CCNI) have different returns, different deadlines and different thresholds — check your own regulator. Thresholds and dates were checked against Charity Commission guidance and legislation in August 2026; where the government's own wording was still "expected" rather than settled, we've said so.

Need the report that goes with the return? See the trustees' annual report for a small charity. To keep the decisions behind it somewhere your examiner can find them, see what your charity minutes should include. Or browse the full guides library and try it with your board.