New charity accounting thresholds and independent examination rules from 30 September 2026
This article is part of a suite of charity law updates on the Autumn 2026 Charity Commission guidance.
From 30 September 2026, the Charity Commission has raised all key accounting and audit thresholds for charities in England and Wales. This section explains what has changed, what this means for your examiner appointment, and the steps trustees should take now.
What's staying the same?
The thresholds for submitting an annual return (income over £10,000) and for filing the trustees' annual report and accounts with the Commission (income over £25,000) are unchanged. The new thresholds only affect what type of accounts you prepare and what level of external scrutiny is required.
What's changed?
For financial years ending on or after 30 September 2026, all the key accounting thresholds have increased for all charity legal structures (including Charitable Incorporated Organisations (CIOs), charitable companies, trusts and unincorporated associations). The principal changes are:
| Threshold | Previously | From 30 September 2026 |
|---|---|---|
| No scrutiny required (income threshold) | £25,000 or less | £40,000 or less |
| Can prepare receipts and payments accounts (unincorporated/CIOs) | Income £250,000 or less | Income £500,000 or less |
| Must prepare accruals accounts | Income over £250,000 | Income over £500,000 |
| Professionally qualified independent examiner required | Income over £250,000 | Income over £500,000 |
| Statutory audit required (income threshold) | Income over £1,000,000 | Income over £1,500,000 |
| Statutory audit required (combined threshold) | Income over £250,000 and assets over £3,260,000 | Income over £500,000 and assets over £5,000,000 |
| Group accounts and audit required | Group income over £1,000,000 | Group income over £1,500,000 |
Choosing the right examiner
Trustees have a legal duty under the Charities Act 2011 to appoint "an independent person who is reasonably believed by the trustees to have the requisite ability and practical experience to carry out a competent examination of the accounts." The skills required depend on the charity's gross income and the complexity of its accounts.
Once income exceeds £500,000 (under the new thresholds), the examiner must be a member of one of the accountancy bodies listed in the Charities Act 2011. For charities below that threshold preparing accruals accounts, a qualified examiner is not legally required but is strongly recommended.
Key independence requirements
The examiner must be independent of the charity. Situations that could call an examiner's independence into question include where they are an employee of the charity or its bookkeeper; serve on a sub-committee overseeing the charity's finances; are a major donor to or beneficiary of the charity; have a significant financial or commercial relationship with the charity or its trustees; or have a close relationship with the trustees or other related parties.
Key action points
- Check which financial year-end date triggers the new thresholds for your charity. The change applies to financial years ending on or after 30 September 2026, not to earlier year-ends.
- Review the type of accounts you are preparing and the level of scrutiny you are arranging in light of the new thresholds.
- If your income has previously sat just above a threshold, re-assess whether you remain above the new higher threshold; you may have more flexibility than before.
- Check your governing document and any funder agreements. These may impose more demanding requirements than the statutory minimum, regardless of the new thresholds.
- If you currently have an auditor in post and your income has dropped below the new £1.5m audit threshold, discuss with your finance team and auditor whether switching to independent examination would be appropriate and cost-effective.
- If your income now falls between £500,000 and £1.5m, ensure your independent examiner is a member of one of the professional bodies specified in the Charities Act 2011.
- Re-confirm your examiner's independence and relevant qualifications at the start of each year, particularly if your charity's income has changed significantly.
- Allow enough time: the process of finding and appointing an examiner can take time and should not be left until the trustees' annual report and accounts are due for filing.
Charity law update Autumn 2026: Contents
- Section 1: New accounting thresholds and independent examination from 30 September 2026
- Section 2: SORP 2026
- Section 3: Sustainability reporting under SORP 2026
- Section 4: Updated guidance on reserves (CC19)
- Section 5: Updated guidance on risk management (CC26)
- Section 6: The trustees' annual report
- Section 7: The essential trustee (CC3)
- Section 8: Safeguarding
Contact
Nathalie Jacoby-Danesh
Partner
nathalie.jacoby-danesh@brownejacobson.com
+44 (0)330 045 2833