Charity law update Autumn 2026: A guide for trustees on the latest Charity Commission guidance

Q: Sustainability reporting

Tier 3 charities (income over &pound;15m): mandatory sustainability reporting - ensure a process is in place. All charities: consider whether a proportionate sustainability statement would be appropriate.

15 October 2026

Nathalie Jacoby-Danesh

This autumn brings significant regulatory change for charities in England and Wales. In September and October 2026, the Charity Commission published updated versions of its core guidance suite, covering accounting thresholds, SORP 2026 implementation, reserves management, risk management and reporting, and safeguarding.

Together, these updates represent a significant overhaul of charity reporting and accounting. This briefing sets out what’s changed, what remains the same and, most importantly, what trustees should do now.

This guide contains

Section 1 - New accounting thresholds and independent examination from 30 September 2026: Key changes to thresholds, choosing the right examiner, and independence requirements.
Section 2 - SORP 2026: An overview of the new three-tier reporting framework - and the updated trustees' annual report headings, including public benefit reporting.
Section 3 - Sustainability reporting under SORP 2026: mandatory requirements for Tier 3 charities, and practical considerations for smaller charities approaching ESG reporting.
Section 4 - Updated guidance on reserves (CC19): Higher expectations on reserves policies, disclosure requirements, and the treatment of designated funds.
Section 5 - Updated guidance on risk management (CC26): The new emphasis on high-impact low-likelihood risks, and changes to the heat map scoring approach.
Section 6 - The trustees' annual report: Updated requirements covering financial review, fundraising, and holding trustee disclosure, electronic signatures, and personal data.
Section 7 - The essential trustee (CC3): A refresher on the six core duties, with updated guidance on accountability, filing obligations, and serious incident reporting.
Section 8 - Safeguarding: The Commission's updated guidance on protecting people, covering the 2026 DBS changes, online risks, and grant-making charities.

Here is a consolidated checklist of the key actions arising from this update.

Establish which new thresholds apply to your next financial year-end.
Review your current accounts preparation and external scrutiny arrangements.
Check governing document and funder requirements before making any change.

Confirm whether SORP 2026 applies to your current financial year (it does if your year started on or after 1 January 2026).
Update your annual report template to SORP 2026 headings.
Identify your SORP tier and ensure the level of detail in your report matches.

Tier 3 charities (income over £15m): mandatory sustainability reporting - ensure a process is in place.
All charities: consider whether a proportionate sustainability statement would be appropriate.

Review and refresh your reserves policy to ensure it is tailored, specific and genuinely explains your position.
Monitor reserves throughout the year, not just at year-end.
Scrutinise any designated funds for currency and proper use.

Review your risk register against the updated CC26 guidance.
Specifically consider high-impact, low-likelihood risks and linked/cumulative risk scenarios.
Ensure AI, cyber and environmental risks are captured.
Ensure your risk management statement in the annual report goes beyond boilerplate.

Ensure financial review, reserves statement and (where applicable) fundraising disclosure are all included.
Review for unnecessary personal data before filing.
Confirm electronic signatures are permitted under your governing document.

Ensure all trustees have read CC3.
Confirm your serious incident reporting process is clear and understood.
Identify AI use across the organisation and review governance and policy arrangements.
Review and update safeguarding policies and procedures, including DBS checking arrangements in light of the 2026 changes to regulated activity.
If operating online, assess compliance with the Online Safety Act 2023.
If working with children or adults at risk, ensure a safeguarding lead is in place and that policies align with the relevant local authority safeguarding partnership or board.
If making grants or working with partner organisations, carry out safeguarding due diligence before funding is provided and include clear safeguarding requirements in written agreements.

This update has been prepared by Browne Jacobson's Charity and Social Enterprise team. It reflects the Charity Commission's revised guidance suite published in September and October 2026 and other sector developments current as at the date of publication. It's intended as a general guide for trustees and doesn't constitute legal advice on specific circumstances. If you have any questions, please contact your usual Browne Jacobson adviser.

Nathalie Jacoby-Danesh

Partner

nathalie.jacoby-danesh@brownejacobson.com

+44 (0)330 045 2833

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Not for profit and charities

15 October 2026

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Charity law update Autumn 2026: A guide for trustees on the latest Charity Commission guidance

This guide contains

Autumn 2026 action list for trustees

Threshold changes

SORP 2026

Sustainability reporting

Reserves

Risk management

Annual report and accounts

Governance and safeguarding

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Nathalie Jacoby-Danesh

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