The essential trustee (CC3): What the 2026 update means for charity trustees

This article is part of a suite of charity law updates on the Autumn 2026 Charity Commission guidance. 

The Charity Commission updated CC3 in September 2026 to reflect SORP 2026 and the revised accounting thresholds. The six core trustee duties are unchanged. This section covers what trustees must now file, when, and the continuing expectations around serious incident reporting and resource management.

What's changed?

CC3 ('The Essential Trustee'), was updated on 16 September 2026. This isn't a full rewrite but rather an update to reflect the new SORP 2026 framework, updated accounting thresholds and current regulatory expectations. The six core trustee duties remain unchanged.

The six main duties and legal responsibilities remain: ensure your charity is carrying out its purposes for the public benefit; comply with your charity's governing document and the law; act in your charity's best interests; manage your charity's resources responsibly; act with reasonable care and skill; and ensure your charity is accountable.

Resources and risk

Trustees must act responsibly, reasonably and honestly. They must make sure the charity's assets are only used to support or carry out its purposes; avoid exposing the charity's assets, beneficiaries or reputation to undue risk; not over-commit the charity; take special care when investing or borrowing; and comply with any restrictions on spending funds or selling land.

The updated guidance continues to emphasise that risk management and a robust reserves policy are integral to the duty to manage resources responsibly. 

Accountability obligations: What must be filed

Registered charities with income up to £10,000 should complete the relevant sections of the annual return, which include updates to trustees. Those with income above £10,000 and all CIOs must prepare and file an annual return form. 

Those with income above £25,000 and all CIOs must also file copies of their trustees' annual report and accounts (see Section 1 on the new accounting thresholds and Section 6 on the content of the trustees' annual report).

Filing deadlines and corrections

The annual return must be submitted within 10 months of the end of the charity's financial year. It must be completed by the charity itself; the Charity Commission cannot make amendments on its behalf. If information needs to be changed after submission, the charity must apply in writing to request a full reset, then resubmit all required details.

Failure to submit accounts and accompanying documents to the Commission is a criminal offence. The Commission also regards it as mismanagement or misconduct in the administration of the charity. 

Serious incident reporting: A continuing emphasis

The Commission requires charities to report serious incidents - adverse events, whether actual or alleged, which result in or risk significant loss of money or assets, damage to property, or harm to the charity's work, beneficiaries or reputation. If a serious incident takes place, trustees need to report what happened and explain how they're dealing with it.  

This duty is separate from and in addition to any reporting obligation to the police or other regulators. Charities with income over £25,000 must also declare that there are no unreported serious incidents before submitting their annual return.

Key action points

• Ensure all trustees (particularly any recently appointed) have read and understood the CC3 guidance. It is the Commission's baseline expectation.
• Check that your charity's accounting and reporting obligations (annual return, accounts, trustees' annual report) are being met on time and that someone has clear responsibility for the filing calendar. The annual return must be submitted within 10 months of the end of the financial year. 
• Ensure you have a clear process for identifying and reporting serious incidents to the Commission. If in doubt about whether an event meets the threshold, report it - the Commission takes the view that late or missed reporting is itself a governance failure.
• Review delegation arrangements: trustees can and should delegate day-to-day management, but they cannot delegate overall responsibility. Ensure reporting lines back to the board are clear and functioning.