The Complete Charity Compliance Checklist for 2026

Small UK charities answer to the Charity Commission, HMRC, the DBS service, and the ICO — each with different deadlines, forms, and reporting requirements. Keeping on top of it is measurably hard: the Charity Commission's 2023-24 annual report records that only 81% of charities had an up-to-date annual return at the year end, down from 91% the year before. Add the 2025 Governance Code refresh and SORP 2026 reporting changes, and it's a lot to track across spreadsheets and shared drives.

This checklist covers every compliance obligation a small charity registered in England and Wales needs to manage in 2026, with specific deadlines, thresholds, and links to official guidance.

1. Annual return to the Charity Commission

Every registered charity must submit an annual return within 10 months of its financial year end. If your year ends 31 March, your deadline is 31 January the following year.

What you need to prepare depends on your income and on your legal structure. The bands below are the ones GOV.UK sets out for charitable companies and unincorporated charities; CIOs have their own rule, stated directly underneath them:

Under £10,000: Report income and spending figures only. Nothing to upload, unless your charity is a CIO (see below).

£10,000 to £25,000: Answer questions about your charity's activities and finances. Unless your charity is a CIO (see below), no separate accounts submission is required.

Over £25,000: Submit your trustees' annual report and accounts alongside the return, plus the independent examiner's or auditor's report if your accounts had to be examined or audited — examination is required above £40,000 for a financial year ending on or after 30 September 2026, and above £25,000 for an earlier year (see the thresholds below). You must also declare there are no unreported serious incidents.

CIOs — whatever your income: A charitable incorporated organisation must include copies of its trustees' annual report and accounts with every annual return, with no income floor. Under section 163(3)(a) of the Charities Act 2011 the s.163(1) transmission duty applies to a CIO "whatever the charity's gross income is", and CC15d says the same: "all charitable incorporated organisations (irrespective of income) and those registered charities with a gross income in the financial year exceeding £25,000 must file their accounts and an annual report with the Commission." The scrutiny threshold still matters to a CIO — above it a CIO must also have its accounts independently examined and submit the examiner's report. That threshold is £40,000 for a financial year ending on or after 30 September 2026, and £25,000 for an earlier year.

Audit thresholds (changed for financial years ending on or after 30 September 2026): For a financial year ending before 30 September 2026, a statutory audit is required if gross income exceeds £1 million, or if gross assets exceed £3.26 million and income exceeds £250,000. For financial years ending on or after 30 September 2026, SI 2026/427 — in force since 30 September 2026 — moves all of these: the audit income threshold rises from £1 million to £1.5 million and the gross assets leg of the audit test rises from £3.26 million to £5 million (art.3(4)), with the income figure paired to that asset test moving from £250,000 to £500,000; the independent examination threshold rises from £25,000 to £40,000 and the income level above which the examiner must be a qualified member of a listed body rises from £250,000 to £500,000 (art.3(5) makes both of those substitutions, in s.145(1) and s.145(3) respectively); and the threshold for preparing full accruals accounts instead of receipts and payments rises from £250,000 to £500,000 (art.3(3), in s.133). If your charity's financial year ended before 30 September 2026, the previous thresholds still apply to that year, even if you prepare the accounts after that date. Our independent examination guide explains what an examiner actually checks and how to appoint one.

Submit through your My Charity Commission Account. Review the question guide before you start so you know what information you'll need.

For a step-by-step walkthrough, see our annual return preparation guide.

2. Trustees' annual report

Under section 162 of the Charities Act 2011, the trustees of every charity must prepare an annual report for each financial year, whatever the charity's income — the duty has no income threshold. What changes with income is what the report has to contain (scaled by the Charities (Accounts and Reports) Regulations) and, for some structures, whether you have to file it. If your charity is a charitable company or an unincorporated charity, you only send a copy to the Commission with your annual return where your income is over £25,000 — the s.163(1) filing threshold. If your charity is a CIO there is no such threshold: s.163(3)(a) applies the filing duty "whatever the charity's gross income is". The report covers:

• Your charity's name, registration number, address, and trustee names
• Objectives and activities during the year
• How your charity has delivered public benefit
• A financial review, including your reserves policy
• Plans for the next reporting period

Charities preparing receipts and payments accounts can use a simplified report format. That is the gate — the accounting basis, not an income figure. GOV.UK: "If your charity prepares receipts and payment accounts, you can prepare a simple report."

Charities preparing accruals accounts follow the Charities SORP, and how much detail the report needs depends on which SORP tier the charity is in — see section 7 below. Income does set the tier, and it separately sets how much detail the public benefit section needs: at a gross annual income of "£500,000 or less, you can choose how you report on this", and above it "you will need to provide extra information". Neither rule turns on the charity's assets, and neither is what triggers the risk statement in the annual report — that is the statutory audit requirement, covered in our charity risk register guide.

The Charity Commission publishes detailed guidance on preparing your trustees' annual report. For a section-by-section walkthrough, see our trustees' annual report guide.

3. Charity Governance Code 2025 self-assessment

The Charity Governance Code was refreshed in November 2025 with eight principles:

1. Foundation — your governing document, legal form, and charitable purposes
2. Organisational Purpose — clear mission, strategy, and plans
3. Leadership — effective board leadership and chair role
4. Ethics and Culture — values, behaviours, and organisational culture
5. Decision Making — informed, transparent, and documented decisions
6. Managing Resources and Risks — financial oversight and risk management
7. Equity, Diversity and Inclusion — board diversity and inclusive practices
8. Board Effectiveness — skills, development, and performance review

The Code uses an "apply or explain" approach: your board assesses itself against each principle and either demonstrates how it applies the principle or explains why it has taken a different approach. This is not a pass/fail exercise — it helps boards identify areas for improvement.

New in 2025: The Code now recommends charities establish a policy for the use of technology and AI tools. Equity, diversity, and inclusion has been elevated to a standalone principle.

The Code applies to all registered charities regardless of size, though smaller charities will naturally apply some principles differently.

Use our free Governance Code Self-Assessment tool to work through each principle with your board. For a detailed breakdown of the 2025 changes, read our Charity Governance Code 2025 guide.

4. Required policies

There is no single statutory list of "mandatory policies" for charities, but the Charity Commission, the Governance Code, and sector regulators expect charities to maintain several core policies. Missing these can trigger regulatory inquiries. See our full breakdown of what policies are required by law for UK charities for which are statutory, which are Charity Commission expectations, and which are good practice.

Policies every charity should have:

Safeguarding policy — Required if you work with children or vulnerable adults. Cover recruitment checks (DBS), behaviour codes, reporting procedures, and a designated safeguarding lead. Even charities without direct beneficiary contact should have a basic safeguarding statement. See our full safeguarding policy guide for what to include and a template.

Data protection (GDPR) policy — The UK GDPR and Data Protection Act 2018 apply to all charities that process personal data, regardless of size. Your policy should cover lawful bases for processing, data retention periods, subject access requests, and breach notification procedures. See our GDPR guide for charities for the full picture.

Complaints procedure — The Charity Commission expects all charities to have a formal complaints process with clear timeframes for acknowledgement, investigation, and resolution.

Reserves policy — Explains how much unrestricted money your charity holds and why. Trustees should agree a target range and review it annually. The Charity Commission frequently queries charities with high reserves and no clear policy.

Financial controls policy — Covers authorisation levels, segregation of duties, bank account management, and expense claims. Essential for preventing fraud and meeting charity trustee roles and responsibilities under the Charities Act 2011.

Conflict of interest policy — Trustees must declare and manage conflicts of interest. Your policy should cover how conflicts are identified, recorded in the minutes, and managed during board decisions. See our conflict of interest policy template for charities for the Charity Commission's five-step process.

Additional policies to consider: volunteer management policy, a charity expenses policy, health and safety policy, equality and diversity policy, fundraising policy, risk management framework, and a trustee code of conduct.

Check which policies your charity needs with our free Compliance Checklist Generator.

5. Gift Aid claims to HMRC

Gift Aid lets your charity claim 25p for every £1 donated by UK taxpayers. To claim:

• Register with HMRC for Gift Aid (separate from your Charity Commission registration)
• Hold a valid Gift Aid declaration from each donor — this must include the donor's full name, home address, and confirmation they are a UK taxpayer
• Submit claims through HMRC's Charities Online service

Claims can cover donations received in the last 4 years, so there is no need to claim in real time. Most small charities batch claims quarterly or annually alongside their annual return preparation. See our complete Gift Aid guide for the step-by-step HMRC process.

Common pitfalls: Invalid declarations (missing donor details or undated forms), claiming on donations where the donor has not paid enough income or capital gains tax to cover the Gift Aid amount, and failing to keep adequate records. HMRC can — and does — claw back Gift Aid claimed incorrectly. Gift Aid is not the only HMRC obligation charities miss — see our guide to VAT for charities.

6. DBS checks for trustees and volunteers

Whether your charity needs DBS checks depends on your activities:

Working with children or vulnerable adults: Enhanced DBS checks are required for trustees and volunteers in regulated activity. Standard checks may be sufficient for supervised roles. Check the DBS eligibility guidance to confirm which level applies.

Not working with these groups: Basic DBS checks may still be appropriate for trustees handling finances or sensitive personal data.

DBS checks for volunteers are free. Checks do not have a formal expiry date, but the Charity Commission recommends renewal every 3 years as good practice. With multiple volunteers, tracking who needs renewal and when is one of the most common compliance gaps flagged in charity governance reviews.

7. SORP 2026 reporting changes

The Charities Statement of Recommended Practice (SORP) 2026 applies to accounting periods starting on or after 1 January 2026. The biggest change is a new three-tier reporting framework. The tiers cover charities preparing accruals accounts, and within that population SORP para 38 sets the tier by gross income alone — a charity "must assess their tier each year based on their annual gross income only". Check the scope limit in para 35 first, though: non-company charities with gross income of £250,000 or less that have chosen to prepare receipts and payments accounts sit outside the tiering altogether, and are directed instead to "refer to the regulatory requirements of their jurisdiction(s) for reporting purposes". If that is your charity, the tiers below do not set your reporting duties.

• Tier 1 (accruals accounts, gross income not more than £500,000): Simplified reporting — covers the majority of small UK charities
• Tier 2 (above £500,000, up to £15 million): Standard SORP requirements
• Tier 3 (above £15 million): Extra disclosures — the only tier required to produce a statement of cash flows unconditionally, and the only tier for which sustainability (ESG) reporting is a "must" rather than a "may". SORP Table 14.1A relieves Tier 1 and Tier 2 charities of the cash flow statement only "where they meet the definition of a small entity, in accordance with paragraph 7.1B of FRS 102", so a Tier 1 or Tier 2 charity that is not a small entity must still produce one; the same table notes that exemption "is not available to tier 3 charities"

Key changes for small charities (Tier 1):

• A summary of the charity's main achievements is mandatory (SORP para 1.27 — the only "Achievements and performance" paragraph Table 1 assigns to Tier 1), and trustees "should" consider what difference the charity's work made. The fuller duty to "explain the impact the charity is making" is para 1.30, printed under "Tier 2 – in addition to tier 1 requirements", so Tier 1 charities are encouraged to add an outcomes narrative (para 1.13) rather than required to
• Option to present income and expenditure by natural classification (donations, grants) rather than by activity
• ESG reporting remains optional for Tier 1 and Tier 2 charities
• Cash flow statement generally not required for Tier 1 charities qualifying as small entities under FRS 102

For the full picture of what Tier 1 charities need to change, see our SORP 2026 explained guide.

Threshold changes for financial years ending on or after 30 September 2026: The Charities Act 2011 statutory audit threshold rises from £1 million to £1.5 million income, and the gross assets limb of the audit test rises from £3.26 million to £5 million (with its paired income figure moving from £250,000 to £500,000). The independent examination threshold rises from £25,000 to £40,000 income, and the income level above which the independent examiner must be a qualified member of a listed body rises from £250,000 to £500,000 (art.3(5) makes both substitutions, in s.145(1) and s.145(3)). The threshold for preparing full accruals accounts (instead of receipts and payments) rises from £250,000 to £500,000 (art.3(3), in s.133). These apply by your charity's year end, not a fixed date — if your year end falls before 30 September 2026, check whether the new levels change your reporting obligations for the following year instead.

Use our free SORP 2026 Tier Calculator to check which tier applies to your charity.

Your compliance calendar

Here is when to schedule each obligation across your financial year:

Throughout the year:

• Record Gift Aid declarations for each donation
• Log DBS check dates and schedule renewals
• Document trustee meeting minutes and decisions

After year end (within 10 months):

• Prepare accounts and trustees' annual report
• Submit annual return to the Charity Commission
• Submit Gift Aid claims to HMRC

Annually:

• Review all core policies (safeguarding, GDPR, complaints, reserves, financial controls, conflict of interest)
• Conduct Governance Code self-assessment with your board
• Review and update your risk register

Every 3 years (good practice):

• Renew DBS checks for trustees and volunteers (DBS checks do not formally expire, but periodic renewal is widely recommended)
• Review your governing document and consider updates

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This guide applies to charities registered with the Charity Commission for England and Wales. Regulations differ in Scotland (OSCR) and Northern Ireland (CCNI). This is general guidance, not legal advice — consult a solicitor or your independent examiner for advice specific to your charity.

Sources

• Prepare a charity annual return — GOV.UK
• Prepare a charity trustees' annual report — GOV.UK
• Charity Governance Code 2025
• Claim Gift Aid — GOV.UK
• DBS eligibility guidance — GOV.UK