Every registered charity in England and Wales must prepare a trustees' annual report each year, whatever its income. There is no exemption for being small. What income changes is whether you have to send it to the Charity Commission — that duty starts above £25,000, or at any income if you're a CIO. This guide sets out exactly what has to be in the report, the six things small charities are specifically excused from, and the section boards most often get wrong.
Two different duties: writing it, and sending it
These get muddled constantly, so it's worth separating them at the outset.
Writing it is compulsory for everyone. The Charities Act 2011 requires the trustees of a charity to prepare an annual report for each financial year. No income threshold. If you're a registered charity, you write one.
Sending it to the Commission depends on your size. The duty to transmit the report and accounts kicks in where gross income exceeds £25,000. If you're a CIO, it applies whatever your income.
If you're below £25,000 and not a CIO, you don't send it routinely — but two duties still bite. The Commission can ask for it, and if it does you must send it. Where the request comes more than seven months after your year end, you have three months from the date of the request. And separately, you must make the report available to the public on request.
(On charging: the Charities Act lets you charge a reasonable fee to cover your costs when someone asks for your accounts. There's no equivalent statutory fee provision for the report itself.)
This is where small charities come unstuck. When the Commission reviewed the reporting of charities under £25,000, only 64% met the basic standard. Of the third that didn't, the failures split roughly evenly between one document being inadequate, only one document being produced at all, and neither being produced. Some trustees said they thought the annual return and the accounts were the same thing. Others believed no report was needed "because their charity did not carry out much activity". Neither is right: a quiet year still needs a report, and the report is not the return.
(Those figures are from the Commission's 2018 accounts-monitoring reviews. They're the most recent published reviews of report quality we could find, so treat them as indicative of the pattern rather than as today's numbers.)
What must be in it
There's no required template and no minimum length. Trustees "may choose how they lay out their annual report, provided all the legal requirements are met". The content is prescribed by the Charities (Accounts and Reports) Regulations 2008, and the Commission sets it out under ten headings, of which these six are the ones that apply to a small charity.
One reassuring point before the list: under the 2008 Regulations the reporting requirements are identical whether you prepare receipts-and-payments accounts or accruals accounts. If you prepare accruals accounts you must also follow the SORP, which adds a little on top — see the SORP 2026 section below. Everything in this section applies to you either way.
1. Reference and administrative details
The factual front page:
- the charity's name, and any other name it operates under
- its registration number, and company number if it's a charitable company
- the address of its principal office
- the names of all the trustees at the date the report is approved
- the names of anyone who was a trustee at any point during the year
- the name of anyone acting as a custodian or holding trustee for the charity, both at the approval date and during the year
If naming a trustee or giving an address would put someone at real personal risk, the Commission can authorise leaving it out — but that's a specific authorisation, not something you decide yourselves.
2. Structure, governance and management
Short and factual for most small charities: what your governing document is and when it was made, and whether anybody outside the board has the right to appoint trustees — and if so, who.
3. Objectives and activities
A brief summary of your charity's purposes, and a summary of the main activities you undertook to further those purposes for the public benefit.
Note the wording. Not "our purposes are X" and stop — the activities have to be tied to the purposes. This is where the public benefit statement lives too (see below).
4. Achievements and performance
Here the rules are explicitly lighter for smaller charities. Charities not subject to a statutory audit "may limit their disclosures within this section to a brief summary of the achievements of the charity during the year".
A brief summary. Not an impact framework, not a theory of change. What did you actually manage to do this year?
5. Financial review
Two things, one of which applies to every charity:
Reserves. Your policy on reserves, the level of reserves held, and why they're held. Where you've designated funds for particular purposes, quantify and explain them. And critically — if you have no reserves policy at all, say so explicitly. Silence isn't an option. This applies to every charity, not just larger ones.
Deficits. Where any fund is materially in deficit, explain the circumstances and what you're doing about it.
Our reserves policy guide and free reserves policy template cover the first of these if you don't yet have one.
6. Funds held as custodian trustee
Only if that applies to you. Most small charities can skip it.
And then: sign and date it
The report must be dated and signed by one or more trustees who have been authorised by the board to do so. A typed or electronic signature is fine unless your governing document says otherwise.
That authorisation matters, and it's a board decision — which means it should be in your minutes. If an examiner or a funder later asks who approved this report, the answer should be findable.
What small charities do not have to include
This is the part nobody tells you, and it saves real time. If your charity is not subject to a statutory audit, the Regulations specifically excuse you from reporting on:
- trustee induction and training policies
- a description of your organisational structure
- your grant-making policy
- investment performance
- investment policy
- your plans for future periods
That last one is worth flagging: under the 2008 Regulations, only charities subject to statutory audit have to set out plans for future periods. But if you prepare accruals accounts, SORP 2026 changes this — see below.
Public benefit: the paragraph most boards get wrong
Trustees have a legal duty to have regard to the Commission's public benefit guidance, and the report must contain a statement as to whether they have complied with it.
There is no prescribed wording, and public benefit doesn't have to be its own section. For a smaller charity, the Commission's position is that the report meets the requirement if it does three things: explains the charity's purposes, explains what the charity did to carry them out, and includes the due-regard statement.
So why is this the weakest section in most reports? Because boards write the third part and skip the first two. When the Commission reviewed public benefit reporting (a 2018 review, and note its sample was charities above the £25,000 filing threshold rather than the smallest), only 52% of reports demonstrated a clear understanding of the requirement. Two-thirds included the statement; two-thirds explained the activities; only half did the job properly. Its conclusion was blunt: the reports that met the requirement "were those where the trustees had appreciated that public benefit reporting is more than including a standard statement".
The practical test: could a stranger read your report and understand who benefits from your charity and how? If the answer is only "we confirm we have had due regard to the guidance", you have the statement without the substance.
Risk: only if you're audited
A statement that the trustees have reviewed the major risks and put systems in place to manage them is required only for charities subject to a statutory audit — currently income over £1 million, or gross assets over £3.26 million with income over £250,000.
Below that, it isn't required in the report. Managing risk is still part of the job, and a risk register is good practice, but you're not obliged to write the statement.
What SORP 2026 changes, and who it binds
If you prepare receipts-and-payments accounts, SORP 2026 does not apply to you. Stop here — nothing in this section is yours. One check first, though: receipts-and-payments accounts are only available to non-company charities below £250,000 of income (rising to £500,000 under the changes described at the end of this guide). A charitable company cannot use them at all, so if that's you, read on.
If you prepare accruals accounts, SORP 2026 applies to reporting periods beginning on or after 1 January 2026, and it sorts charities into tiers. Tier 1 is accruals charities with gross income of £500,000 or less — the lightest tier, and the one almost every small charity reading this falls into.
For Tier 1, the report requirements broadly track what's above — purposes and main activities, the public benefit activities and due-regard statement, a summary of main achievements, the financial and reserves review, the governing document and how trustees are recruited, and the reference and administrative details. Two things are worth calling out:
Volunteers. Tier 1 asks for an explanation of the scale and nature of volunteer involvement. If volunteers are how your charity actually functions, say so.
Plans for the future become a requirement. Under the 2008 Regulations, future plans were an audit-only item. Under SORP 2026 a summary of plans for the future is a Tier 1 "must". If you prepare accruals accounts, that's a genuinely new paragraph for you.
Going concern, if you hold nothing. Also new at Tier 1: where a charity has no reserves at all, or negative net assets, the report must explain why it is still operating as a going concern. Tier 1 also asks you to compare the reserves you actually hold against your policy, and to reconcile the figures to your accounts. If your answer to the reserves question is "we don't really have any", this is the paragraph that applies to you.
On impact reporting, be careful what you read. The published summary of changes says impact reporting is now a "must" for all charities. But in the SORP itself the explicit obligation to explain impact and consider long-term effects sits under Tier 2; Tier 1 requires "a summary of the main achievements", with the impact questions framed as prompts to consider rather than a checklist. If you're a Tier 1 charity and someone tells you the SORP now compels a formal impact assessment, that overstates it. Writing honestly about the difference you made is good practice and the direction of travel — but at Tier 1 it isn't the hard requirement the headline suggests.
One further caveat, if you're a non-company charity preparing accruals accounts. The regulations that govern your accounts still name the old SORP — the 2005 version — because they haven't been updated yet, and a new SORP can't formally be adopted until they are. In practice preparers are working around it, but if your independent examiner raises the point, they're right to. It's a genuine loose end, not them being difficult.
When it's due, and what becomes public
Same deadline as the annual return: ten months after your financial year end. A 31 December 2025 year end means 31 October 2026.
If you're over £25,000 or a CIO, the report is uploaded as a PDF alongside your accounts and the annual return. See the annual return walkthrough for the mechanics.
And be aware: the Commission publishes filed trustees' annual reports on the register in full. Everything in it is public, including any personal detail. That's a reason to write about beneficiaries carefully, and never to paste a home address into the document.
A note on the £25,000 line — it isn't moving
From 30 September 2026, several accounting thresholds are expected to rise. The independent examination threshold is expected to go from £25,000 to £40,000, and the receipts-and-payments limit from £250,000 to £500,000.
The £25,000 threshold for filing your report and accounts is not among them. The government has said it proposes to retain it. So from late 2026 the two thresholds come apart: a charity with £30,000 income will still have to file its trustees' annual report and accounts, but may no longer need an independent examination. The government has itself acknowledged this creates "an additional threshold for small charities to be aware of".
Treat the September date as provisional until the regulations are actually made — the official wording is still "expected".
Making next year's easier
The reason trustees find this document hard is rarely the writing. It's that the raw material — what the board decided, what changed, what you achieved — is scattered across a year of emails and half-remembered meetings, and someone has to reconstruct it in a fortnight.
The charities that find it easy are the ones where the report is assembled from decisions that were recorded when they were made. If your minutes say what the board agreed and why, the achievements section writes itself. See what your charity minutes should include and the trustee action log.
Common questions
Does a very small charity really have to write a trustees' annual report? Yes. Every registered charity in England and Wales must prepare one, whatever its income — there is no small-charity exemption from writing it. What changes with income is whether you have to send it to the Commission routinely. Below £25,000 you keep it, provide it to anyone who asks, and send it to the Commission if it asks.
What's the difference between preparing it and filing it? Preparing is compulsory for everyone. Filing routinely with the Commission is compulsory if your income is over £25,000, or if you're a CIO at any income. Below that, two things still apply: the Commission can ask you for it and you must then send it, and you must make it available to the public on request.
How long does it need to be? There is no minimum length and no set format. Trustees may lay it out however they like, provided everything legally required is in there. For a small charity a few well-judged pages is normal — the Commission's complaint is almost never that reports are too short, it's that they don't explain what the charity actually did.
Do we have to write about public benefit? Yes, and it's the part most often done badly. There's no prescribed wording. For a small charity the minimum is: explain your purposes, explain what you did to carry them out, and confirm the trustees have had due regard to the Commission's public benefit guidance. A bare statement with no explanation is exactly what the Commission flags.
Do we need a reserves policy even if we have almost no money? You need to say something about reserves either way. The requirement applies to all charities, not just larger ones — and if you have no reserves policy, the report should say so explicitly rather than staying silent.
Do we have to include a statement about risk? Only if your charity is subject to a statutory audit. Below the audit threshold the risk statement isn't required in the report — though thinking about risk is still part of being a trustee.
Does SORP 2026 change our report? Only if you prepare accruals accounts. If you do receipts-and-payments accounts, SORP doesn't apply to you at all. If you do accruals and your income is up to £500,000 you're Tier 1, the lightest tier, and the notable change is that a summary of your plans for the future becomes a requirement.
This guide covers charities registered in England and Wales. Scotland (OSCR) and Northern Ireland (CCNI) set their own reporting requirements and thresholds. Requirements were checked against the Charities Act 2011, the Charities (Accounts and Reports) Regulations 2008, current Charity Commission guidance and SORP 2026 in August 2026; where the government's own wording was still "expected" rather than settled, we've said so. The Commission's own guidance on trustees' annual reports carries a note that it will be updated during 2026 to reflect SORP 2026.
Filing season? See the annual return walkthrough and SORP 2026 for trustees. Or browse the full guides library and try it with your board.