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By Brian Crocker, CharityProof

Trustees' Annual Report: What to Include and How to Write It

The trustees' annual report is the document where charity trustees account to the public for how their charity has used its resources over the past year. It sits alongside the charity's accounts and is submitted to the Charity Commission as part of the annual return. Together, the report and accounts are the public record of a charity's work.

For many small charities, writing the trustees' annual report feels like a compliance chore. Done well, it is also the charity's most powerful public-facing document — an honest account of what it set out to do, what it achieved, and what it plans to do next.

Who must produce a trustees' annual report?

Whether you must file the report turns on legal structure as well as income. A charitable company or unincorporated charity with income over £25,000 must submit a trustees' annual report alongside its annual return to the Charity Commission; below £25,000 it submits the return but is not required to file the report. A CIO must file its trustees' annual report and accounts whatever its income — section 163(3)(a) of the Charities Act 2011 applies that duty to a CIO "whatever the charity's gross income is", and CC15d puts it as "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." Preparing one is not merely good practice in any case: under section 162 of the Charities Act 2011 the trustees of every charity must prepare an annual report for each financial year, whatever the income. The £25,000 figure is the s.163(1) filing threshold for non-CIO structures only. For the exact annual return thresholds, see the gov.uk guidance on preparing a charity annual return.

What must the report include?

The Charity Commission's guidance on preparing a trustees' annual report sets out the required content. The current guidance — "Last updated: 16 September 2026" — splits the report by the type of accounts your charity prepares, not by income and not by asset value. GOV.UK's words: "If your charity prepares receipts and payment accounts, you can prepare a simple report." A charity preparing accruals accounts reports under the Charities SORP instead, and the depth of that report is set by its SORP tier. Income does still control one thing — how much detail the public benefit section needs — and that is dealt with separately below.

Charities preparing receipts and payments accounts (simple report)

You can decide how to present a simple report, but it must meet all the legal requirements and it "must specify the financial year to which it relates". GOV.UK sets out the content as follows, and where the regulations require something the guidance page does not spell out, the provision is named:

Reference and administrative details:

  • The name under which the charity is registered, and any other names the charity uses
  • The charity's registration number
  • The address of the charity's main or head office
  • The names of all trustees on the date the report was approved, or who served as a trustee in the reporting period. Where there are more than 50 trustees, at least 50 must be named, including the chair and treasurer
  • Where the charity has a corporate trustee, the names of that corporate trustee's directors on the date the report was approved
  • For a charitable company, also its company registration number and the address of its registered office (reg 40(3)(b) and (c))
  • The name of anyone who is a trustee for the charity — a holding trustee, as distinct from a charity trustee — on that same date, and of anyone who held that role at any time during the year (reg 40(3)(f) and (g))

Structure, governance and management:

  • What the charity's governing document is — for example, "trust deed dated (give the date), constitution dated (give the date)"
  • Whether any person or organisation is entitled to appoint trustees, and the name of that person or organisation — with "a description of the method provided by those trusts for such appointment" (reg 40(3)(i))

Objectives and activities:

  • The charity's purposes
  • A description of "the charity's main activities in the year that have helped it carry out its purposes for the public benefit"
  • A statement as to whether the trustees "have had regard to the Commission's public benefit guidance"

Achievement and performance:

  • A summary of the charity's main achievements during the year. This could include how the charity's work has made a difference to its beneficiaries, and any wider benefits to society as a whole

Financial review:

  • Any policy the charity has for determining the level of reserves, the amount of those reserves and why they are held — and where no such policy has been adopted, "a statement to that effect" (reg 40(3)(p)). GOV.UK adds that you should also give the reasons for not having one, which is good practice rather than a legal requirement
  • Any designated funds, and the amount and purpose of any material commitments and planned expenditure
  • Where any fund of the charity is in deficit, how the deficit occurred and the steps being taken to remove it

Funds held as a holding trustee:

  • Only if the charity held property on behalf of another charity during the year: a description of the assets held in that capacity, the name and purposes of the charity they are held for and how that activity falls within your own purposes, and the arrangements for safe custody and segregation

Declaration:

  • The report "must be dated and signed by one or more trustees who have been authorised to do this by the other trustees"

That list is the Commission's presentation of the statutory requirements in reg 40(3) of the Charities (Accounts and Reports) Regulations 2008, which is where the legal obligation sits and which applies whatever accounting basis you use.

Charities preparing accruals accounts (SORP 2026)

If your charity is required to prepare accruals accounts, or chooses to, the report follows the Charities SORP rather than the simple-report list above. GOV.UK: "For financial years starting on or after 1 January 2026, if your charity is required to or chooses to prepare accruals accounts, you must prepare a trustees' annual report that complies with the Charities SORP 2026." For financial years starting on or before 31 December 2025 it is SORP 2019 instead. The SORP 2026 requirements run under nine headings — objectives and activities, achievements and performance, financial review, plans for future periods, structure governance and management, reference and administrative details, sustainability, exemptions from disclosure, and funds held as a holding trustee. "The level of detail in your report will depend on which SORP tier your charity is in" — the tier bands are set out in the next section.

Two additional requirements sit on top, and both turn on whether the charity's accounts must be audited rather than on any report-format figure:

  • Fundraising information. GOV.UK: "If your charity must have its accounts audited, your report must also include information on fundraising." That means the fundraising approach taken, whether a professional fundraiser or commercial participator was used, whether the charity is registered with the Fundraising Regulator and commits to the Code of Fundraising Practice, whether there was any failure to comply, how the charity monitored fundraising carried out on its behalf, the number of fundraising complaints received, and what the charity has done to protect vulnerable people and other members of the public.
  • The statutory content floor. Reg 40 of the Charities (Accounts and Reports) Regulations 2008 applies whatever accounting basis you use — it is the source of the basic items in the simple-report list above as well — and where it asks for more than those basics it keys the extra content to whether the charity is "an auditable charity", not to any figure of its own. Reg 40(2)(b)(ii) gives an auditable charity "a review of the significant activities undertaken by the charity during the relevant financial year", and reg 40(7) provides that six of the content requirements in reg 40(3) "do not apply to a charity which is not an auditable charity". An "auditable charity" is "a charity the accounts of which for the financial year in question are required to be audited in pursuance of any statutory requirement" — so the gate is the audit test below, and the figures are the ones in that test. There is no £500,000 report-format threshold and no asset limb in either the regulations or the current guidance.

In practice, that is where the extra content in a larger charity's report comes from:

  • A description of the aims and objectives the trustees set for the year, the strategies adopted, and performance measured against those objectives (reg 40(2)(b)(ii)(aa) and (bb))
  • A statement as to whether the trustees "have given consideration to the major risks to which the charity is exposed and satisfied themselves that systems or procedures are established in order to manage those risks" (reg 40(2)(b)(ii)(ee)) — see our charity risk register guide. This is the report content rule; the separate CC26 expectation of a formal risk management statement also attaches to charities under a legal requirement to have their accounts audited, so in practice the two move together
  • A description of any policies adopted for the induction and training of trustees, and of the charity's organisational structure (reg 40(3)(j) and (k))
  • A description of any policies adopted for selecting who receives grants or other financial support out of the charity's assets (reg 40(3)(m))
  • A statement on the performance of the charity's investments, and where material investments are held, the policies for their selection, retention and realisation (reg 40(3)(n) and (o))
  • A description of the aims and objectives set for the future and the activities contemplated in furtherance of them (reg 40(3)(q))

Reporting on public benefit

Every report must explain how the charity has carried out its purposes for the public benefit, whatever its size. What income controls is the depth — and this is the only place a £500,000 figure appears in the current guidance. GOV.UK: "If your charity has a gross annual income of £500,000 or less, you can choose how you report on this." As a minimum you still have to say what the purposes are, what the charity did during the year to carry them out for the public benefit, and that you took the Commission's public benefit guidance into account. Above that: "If your charity has a gross annual income over £500,000 you will need to provide extra information. The level of detail in your report will depend on what SORP tier your charity is in."

Whether your accounts must be audited or examined

Scrutiny is a separate question from report format, but it is the question the report's statutory content floor turns on. Under section 144 of the Charities Act 2011, for a financial year ending on or after 30 September 2026, an audit is required where the charity's gross income for the year exceeds £1.5 million, or where it "exceeds the accounts threshold and at the end of the year the aggregate value of its assets (before deduction of liabilities) exceeds £5 million" — "the accounts threshold" being "the sum for the time being specified in section 133", which is now £500,000. Both limbs of that second test have to be met. Where no audit is required but gross income exceeds £40,000, section 145 requires the accounts to be either independently examined or audited, at the trustees' election.

Those are the figures as amended by SI 2026/427, which came into force on 30 September 2026. For a financial year ending before 30 September 2026 the earlier figures still apply (art.5(6)): £1 million of income, £3.26 million of assets, a £250,000 accounts threshold and a £25,000 examination threshold — see our independent examination guide for both sets side by side. The practical consequence for the report: a charity with £600,000 of income and £1 million of assets is not an auditable charity under either set of figures, so reg 40's fuller content and the fundraising disclosures do not apply to it — even though its income is over £500,000.

SORP 2026 changes for small charities

SORP 2026 applies to accounting periods starting on or after 1 January 2026 and introduces a three-tier framework. The tiers cover charities preparing accruals accounts, and within that population para 38 sets the tier by gross income alone; para 35 sends non-company charities with gross income of £250,000 or less that have chosen receipts and payments accounts to their own jurisdiction's regulatory requirements instead (see charitiessorp.org for the published SORP document):

  • Tier 1 (accruals accounts, gross income not more than £500,000): The majority of UK charities fall here. Table 1 of SORP module 1 gives Tier 1 one "Achievements and performance" paragraph, 1.27: the report "must contain a summary of the main achievements of the charity", and two questions about the difference the work made "should be considered by trustees". The duty to "explain the impact the charity is making" is para 1.30, which sits under the heading "Tier 2 – in addition to tier 1 requirements" — so it does not bind Tier 1, which para 1.13 merely encourages to include the additional tier 2 and tier 3 information. Reporting outcomes (what changed for beneficiaries) rather than only outputs (what activities were delivered) is still the direction of travel and what most funders now expect.
  • Tier 2 (above £500,000, up to £15 million): Standard SORP requirements.
  • Tier 3 (above £15 million): Additional disclosures — Tier 3 is the only tier required to produce a statement of cash flows unconditionally. SORP Table 14.1A exempts Tier 1 and Tier 2 charities only "where they meet the definition of a small entity, in accordance with paragraph 7.1B of FRS 102", and records that the exemption "is not available to tier 3 charities even in those cases where they meet the definition of a small entity" — so a Tier 1 or Tier 2 charity outside the small-entity definition must still prepare one. Tier 3 is also the only tier for which reporting on environmental, governance and social matters is a "must" rather than a "may".

The practical implication for Tier 1 charities: if your report has historically said "we ran 12 support sessions for 48 people," para 1.27 asks trustees to consider what changed for those people as a result, and adding it is the single most useful improvement you can make to the report even though the SORP does not compel Tier 1 to. It does not need to be an academic impact evaluation — "participants reported improved confidence and reduced isolation" based on end-of-session feedback is sufficient.

How to structure the report

For a small charity preparing receipts and payments accounts, a practical structure is:

1. Reference and administration — statutory information, one page. Names, addresses, constitution type, trustee list.

2. Structure, governance and management — half a page. How the charity is governed, how trustees are appointed, any affiliations.

3. Objectives and activities — one to two paragraphs. State the charitable purposes in plain English. Describe the main activities.

4. Achievements — one to two pages. What the charity did and what changed as a result. Be specific: numbers of people helped, services delivered, outcomes reported. This is the public benefit section.

5. Financial review — one page. Key financial figures (total income, total expenditure, net movement, closing balances). Reserves policy and current reserve level. Any significant financial issues.

6. Plans for next year — half a page. What the charity intends to do in the coming year.

7. Declaration — signed by at least one trustee.

The whole document for a small charity does not need to be more than five to eight pages, including the financial review. A dense report that takes ten minutes to read is less useful to donors, funders, and the Commission than a clear one-pager per section.

Common mistakes

Writing about activities, not outcomes. "We ran a food bank for 200 families" is activity. "200 families accessed emergency food support; end-of-year surveys showed 84% of repeat users experienced reduced financial stress" is outcome (illustrative example). SORP 2026 expects the latter.

Copying last year's report. The objectives and activities section should reflect what the charity actually did in the year, not what it planned to do. If the charity's plans changed during the year, the report should acknowledge that.

Missing the public benefit statement. The report must include an explicit statement of how the charity delivers public benefit. The Charity Commission expects trustees to confirm they have considered this, not assume it is obvious from the charity's name.

Unsigned reports. A trustees' annual report that has not been signed and dated by at least one trustee is not valid.

Submitting the report

The trustees' annual report is submitted to the Charity Commission as part of the annual return. For charities above £25,000 income, the report and accounts — plus the independent examiner's report (or audit report) where the accounts had to be examined or audited — are uploaded as PDFs through My Charity Commission Account. The report must be approved by the full board before submission — it cannot be submitted by one trustee without board approval.

For a step-by-step guide to the submission process, see our charity annual return guide.


This guide applies to charities registered with the Charity Commission for England and Wales. SORP 2026 applies to accounting periods starting on or after 1 January 2026. This is general guidance, not legal advice.

Sources

Last reviewed: 5 October 2026

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