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

The Charity Commission updated its trustees' annual report guidance in September 2026, reflecting the new SORP 2026 structure and revised accounting thresholds. This section covers what must now be included in the financial review, fundraising disclosure, and holding trustee sections, along with important reminders on electronic signatures and personal data.

What's changed?

The Charity Commission's guidance on preparing the trustees' annual report was updated on 16 September 2026. The update is largely consequential on SORP 2026 (Section 2 above) and the threshold changes (Section 1). The key practical points are set out below.

Financial review: What must be covered

Charities preparing receipts and payments accounts must: 

• Explain any policy for determining the level of reserves.
• State the amount of those reserves and why they're held.
• Identify any designated funds and the amount and purpose of any material commitments and planned expenditure.
• Where any funds are in deficit, explain how the deficit occurred and the steps being taken to remove it. 
• If there's no reserves policy, a statement confirming this with reasons must be included.

Fundraising disclosure: Larger charities

If a charity must have its accounts audited, the report must also cover fundraising: 

• The approach taken.
• Whether a professional fundraiser or commercial participator was involved.
• Whether the charity is registered with the Fundraising Regulator.
• Any failure to comply with the Code of Fundraising Practice.
• How the charity monitored fundraising activities.
• The number of complaints received.
• Steps taken to protect vulnerable people from unreasonable intrusion on privacy, unreasonably persistent approaches or undue pressure to give.

Holding trustee disclosure

A charity that has acted as holding trustee during the reporting period must disclose in the trustees' annual report: a description of the assets or categories of assets held; the name and purposes of the charity on whose behalf the assets are held and how this falls within the holding charity's purposes; and details of the arrangements for safe custody and segregation of such assets from the charity's own assets. 

Electronic signatures: Confirmed as acceptable

An electronic signature can be a typed or scanned version of a handwritten signature. If the governing document doesn't say anything about signatures, electronic signatures can be used for balance sheets, accounts, trustees' annual reports and the independent examiner's report, including copies kept and copies sent to the Commission.

Personal data: Important reminder

The Charity Commission publishes charity annual reports and accounts on its register, accessible to everyone. It cannot remove personal data and can only redact data in very limited circumstances. 

Charities must comply with UK GDPR rules on publishing personal information and must check carefully that any personal data included in accounts and annual reports is necessary, fully justified and not excessive.

Key action points

• Update your annual report template to reflect the new SORP 2026 headings (including the Sustainability heading if applicable to your tier).
• Ensure your financial review section addresses reserves policy, designated funds, and any deficit - in clear language that non-specialist readers can follow.
• If your accounts are subject to audit, double-check that the fundraising disclosure requirements are fully covered.
• Before filing, review the annual report for unnecessary personal data - names, contact details or other information about individuals that does not need to be publicly available.
• Electronic signatures are acceptable if your governing document does not require wet ink signatures.