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. The Charity Commission alone removed over 1,900 charities from the register in 2023 for late annual returns. 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:

Under £10,000: Report income and spending figures only.

£10,000 to £25,000: Answer questions about your charity's activities and finances. No separate accounts submission required.

Over £25,000: Submit your trustees' annual report, accounts, and independent examiner's or auditor's report alongside the return. You must also declare there are no unreported serious incidents.

Audit thresholds (changing October 2026): A statutory audit is currently required if gross income exceeds £1 million, or if gross assets exceed £3.26 million and income exceeds £250,000. From 1 October 2026, the audit threshold rises to £1.5 million income, and the independent examination threshold rises from £25,000 to £40,000.

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

If your charity's income exceeds £10,000, you must prepare a trustees' annual report alongside your accounts. 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 under £500,000 income can use a simplified report format. SORP 2026 introduces a new Tier 1 framework that reduces reporting complexity for smaller charities — see section 7 below.

Charities over £500,000 follow the full SORP format, including detailed strategy, risk assessment, and achievement reporting.

The Charity Commission publishes detailed guidance on preparing your trustees' annual report.

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.

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.

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.

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 trustee duties 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.

Additional policies to consider: volunteer management 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.

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.

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 Statement of Recommended Practice (SORP) 2026 was published on 31 October 2025 and applies to accounting periods starting on or after 1 January 2026. The biggest change is a new three-tier reporting system:

• Tier 1 (under £500,000 income): Simplified reporting — covers the majority of small UK charities
• Tier 2 (£500,000 to £1 million): Intermediate reporting requirements
• Tier 3 (over £1 million): Full SORP reporting

Key changes for small charities:

• Proportionate reporting on reserves, risks, and strategy
• New requirements for environmental, social, and governance (ESG) disclosure, scaled to charity size
• Changes to how charities account for leases and revenue recognition

Threshold changes from October 2026: The statutory audit threshold rises from £1 million to £1.5 million income. The independent examination threshold rises from £25,000 to £40,000 income. If your charity currently sits near these thresholds, check whether the new levels change your reporting obligations.

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