Charity annual return: who files, by when, and the questions

The rule: section 169 of the Charities Act 2011

Section 169 of the Charities Act 2011 requires every registered charity in England and Wales to prepare an annual return for each financial year. Section 169(1) reads: “every registered charity must prepare in respect of each of its financial years an annual return in such form, and containing such information, as may be prescribed by regulations made by the Commission.” Section 169(2) lifts the duty in any year in which the charity's gross income “does not exceed £10,000”, and then adds “(but this subsection does not apply if the charity is constituted as a CIO)”. Charitable incorporated organisations (CIOs) therefore file a full annual return every year, whatever their income.

The charity annual return deadline is 10 months from the end of the financial year. Section 169(3) ties the return to the date by which the trustees must send their annual report under section 163(1). That subsection applies where gross income exceeds £25,000, and to every CIO under section 163(3)(a), and requires the report within “(a) 10 months from the end of that year, or (b) such longer period as the Commission may for any special reason allow in the case of that report”. The Commission's guidance, Prepare a charity annual return, puts it plainly: “You must submit your annual return within 10 months of the end of your financial year. For example, if your financial year end is 31 December your deadline is 31 October the following year.” The guidance applies the same 10 months to every charity that files a return.

A charity below £10,000 is not outside the system. The Commission's service page, Send a charity's annual return, says: “You must use this service to report your charity’s total income and expenditure, even if you do not need to send a full annual return.” The same page says the annual return is different from the charity's annual accounts and from the charity tax return sent to HMRC.

What each charity sends with its annual return

What registered charities must submit with the return depends on income and legal form. Under the heading “What charitable companies and unincorporated organisations need to submit”, the Commission's annual return guidance sets three tiers for charities that are not CIOs:

• Income of £10,000 or less (the page heads this “Income under £10,000”): “You only need to report your income and spending.”
• Income between £10,000 and £25,000: “You must answer questions about your charity in an annual return. You do not need to include any other documents.”
• Income over £25,000: the same questions, plus copies of the trustees' annual report, the accounts and the independent examiner's or auditor's report where the accounts must be examined or audited, and a declaration: “You will need to declare that there are no serious incidents that you have not reported to us. Report serious incidents before you submit your annual return.”

CIOs have their own section on the same page. A CIO answers the annual return questions and sends its trustees' annual report, its accounts and any examiner's or auditor's report at every income level; section 163(3)(a) of the Act applies the duty to send the annual report to every CIO whatever its income, and section 164 requires the accounts and any examiner's or auditor's report to go with it. “If your income is over £25,000 you also need to: declare there are no serious incidents you have not reported to us.” The £10,000 and £25,000 tiers above apply to charitable companies and unincorporated charities, not to CIOs.

The questions themselves also vary. The guidance says: “The questions you will be asked depend on your income, the type of charity and what the charity does.” Some questions are filtered by income: the income breakdown appears only at £500,000 or less, the largest-donation questions only above £100,000, and the serious incident question only above £25,000.

The serious incident declaration is a hard stop. The Commission's guidance How to report a serious incident in your charity says: “Until all serious incidents have been reported, you will not be able to make this declaration, or complete the annual return, which is a statutory requirement under section 169 of the Charities Act 2011.” The serious incident reporting guide covers what counts and how to report it.

The Charity Commission annual return questions for 2025 and 2026

The 2025 and 2026 annual returns use one question set: the Commission's Charity Annual Return 2025 and 2026: question guide, published on 22 May 2025, which exists “to help charities understand what information they will need to prepare for the Annual Return.” No question set for 2027 had been published on 30 October 2026.

The return opens with two checks before the numbered sections. First, the financial period: normally 12 months, but between 6 and 18 months for unincorporated charities and CIOs, and “If your charity’s financial end date has changed and the period displayed is incorrect, the trustees will need to update our records before the annual return and accounts can be submitted.” Second, gross income and spending for the period, calculated from the receipts and payments accounts or the accruals accounts the charity has prepared; gains on revaluing fixed assets or investments are not gross income. Then come eight sections:

• 1. Income. The number and value of contracts and of grants received from central government (including the NHS) or a local authority in the period. An income breakdown – donations and legacies, charitable activities, other trading activities, investments – asked only if gross income is £500,000 or less and grants or contracts are less than 70% of income. Above £100,000 income, the single highest donation from a corporate donor, from an individual and from a related party.
• 2. Spend. Whether grant making is the main way the charity carries out its purposes, the value of grants to individuals, other charities and other organisations, and whether any recipient is a related party. Then trustee payments: “Excluding out of pocket expenses, for what were any of the trustees paid during the financial period of this return?” – for being a trustee, for a role in a trading subsidiary or connected organisation, for goods or services, or otherwise – and “Did any of the trustees resign and take up employment with your charity in the financial period of this return?”
• 3. Activities outside the United Kingdom. Income from outside the UK by country and type of source; how it arrived, with the options “Informal Value Transfer Systems (IVTS)”, “Money Service Businesses (MSBs)”, payment services businesses, “cash couriers”, “cryptocurrency” and “other”; activities delivered abroad and whether the charity has formal written agreements with the partners delivering them; spending abroad, and how much of it went by a method other than the regulated banking system.
• 4. Trading subsidiaries. Whether the charity has any, whether any were dissolved in the period, and how many trustees are also directors of a subsidiary at the date of the return.
• 5. Property. For unincorporated charities only: whether any property was held by holding or custodian trustees, excluding the Official Custodian.
• 6. Employees and volunteers. At the end of the period, how many people were permanently employed, on fixed-term contracts or self-employed, and how many of them work outside the UK; total payroll for the period; whether any employee received total employment benefits of £60,000 or more, with the numbers in each band; the highest paid employee's total benefits, excluding employer's pension contributions; and an estimate of volunteers.
• 7. Governance. Which of 13 policies and procedures the charity had in place at the end of the period.
• 8. Safeguarding and risk. Whether the charity provided services to children or adults at risk; whether it obtained the required level of DBS check for every eligible role; whether it reported every serious incident it became aware of in the period; and, only “in exceptional circumstances where an event has significantly impacted the charitable sector”, such as the COVID-19 pandemic, the estimated impact of that event.

Question 7 asks: “Which of the following policies and procedures did your charity have in place at the end of the financial period of this annual return?” The 13 options are internal financial controls (see the financial controls checklist), safeguarding (the safeguarding policy guide), financial reserves (the reserves policy guide), complaints (the complaints procedure guide), serious incident reporting, internal risk management, trustee expenses, trustee conflicts of interest (the conflict of interest policy guide), investing charity funds, campaigns and political activity, bullying and harassment, social media (the social media policy guide), and engaging external speakers at charity events.

The return does not require all 13. The question guide says: “The policies and procedures appropriate for your charity will vary depending on the size, nature and activities of your charity. The Charity Commission expects most charities to have policies and procedures on: internal charity financial controls; financial reserves; risk management; trustee expenses; trustee conflicts of interest; serious incident reporting policy”. It adds that investing charity funds, political activity, and bullying and harassment policies “may also be appropriate”. The guide to the policies a charity needs sets out which are legal requirements and which are expectations.

The DBS question is precise: “Excluding Basic DBS Checks, has your charity obtained the required level of DBS Checks for all roles which are eligible for them in the financial period of this return?” The options are standard, enhanced, and enhanced with barred list checks “for all eligible roles”, and the guide tells charities to use the DBS eligibility tool to find whether a role needs a check and at what level. Ticking an option means the charity knows the level each eligible role needs and can show it obtained that level for everyone in the role.

Gathering the answers during the year

Most answers are financial information about the whole period; some describe a single date. Staff numbers and policies are counted at the end of the period, and trustees who are subsidiary directors “at the date of this return”. A return signed in month nine on figures nobody kept in month two is where wrong answers come from. A short year-end evidence pack, with a named trustee or officer owning each part, keeps the answers checkable:

• Public money. Every contract and grant received from central government, the NHS or a local authority, with the value received in the period; for a multi-year award, only the portion received in the period counts.
• Donations and related parties. The largest single donation from a company, from an individual and from a related party, which needs a current register of interests to identify related parties at all.
• Grants made by recipient type, flagged where the recipient is a related party.
• Trustee payments of any kind other than out-of-pocket expenses, and any trustee who resigned to take a job with the charity. The trustee payment guide covers when such payments are allowed.
• Money crossing borders. Each transfer in or out of the UK by country and by method, with anything outside the regulated banking system recorded as such, and the written agreement for each partner delivering work abroad on the charity's behalf.
• Payroll. Headcount at the year end by employment status, total payroll, the number of employees at £60,000 or more in benefits, and the highest paid employee's total.
• Volunteers. An estimate, from your own records, of the volunteers, excluding trustees, who carried out charitable activities for the charity in the UK during the period. The guide is explicit: “Do not include volunteers who the charity may call on from time to time but have not worked on behalf of the charity during this period.” The volunteer records guide sets out what to keep.
• Policies. A list of the policies in force at the year end, each with the date and minute of the meeting that adopted or last reviewed it.
• DBS. For each eligible role, the level of check it needs and confirmation that everyone in the role had that check, kept in line with the DBS record keeping rules.
• Serious incidents. Every incident the trustees considered in the year, whether it was reported and when, and the reasons recorded for any judged not reportable.

Agree the answers at the board meeting that approves the trustees' annual report and accounts, so the figures in the return and the figures in the accounts are approved together. The treasurer usually owns the financial sections, the charity secretary the governance answers (see the charity secretary guide) and the safeguarding lead trustee section 8. The trustees' annual report guide covers the report that goes with the return above £25,000.

How to submit a charity annual return, correct it, and the cost of missing it

Charities submit their annual return online through the Commission's Send a charity's annual return service. Taken together, the Commission's guidance sets this order:

1. Set up your own account. “You need to have set up your own My Charity Commission Account, using an individual email address and password, to access services on behalf of a charity.”
2. Clear any earlier years. “You must submit any annual returns from previous years before you can submit your latest one.”
3. Check the financial period the service shows, and update the charity's records first if the year end has changed.
4. Prepare the trustees' annual report and accounts first, where your tier sends them, and upload them while completing the return.
5. Report any outstanding serious incident before submitting, if the charity's income is over £25,000.
6. Answer the questions and submit before the 10-month deadline.

The Commission will not complete or change a return for you. Under 'Amending an annual return' the guidance says: “The annual return must be completed by the charity itself, and the Charity Commission cannot make amendments on your behalf.” An accountant or independent examiner can help prepare the figures, but the duty and the offence for missing it stay with the trustees.

Correcting a submitted return takes a written request. “If you need to change any information that was submitted as part of the annual return, you must apply in writing to request a full reset.” Accounts are different: “If you need to update or replace your accounts, you can do this by re-uploading the documents through your My Charity Commission Account. A reset is not required.” A reset has a visible cost: “When an annual return is resubmitted, the new submission date will appear on the public register. If the date is after the end of the charity's financial year, the submission will show as late.”

Missing the deadline is a criminal offence by the trustees, not an administrative fee. Section 173(1) of the Charities Act 2011 provides that if the section 169(3) requirement is not met, “each person who immediately before the specified date for compliance was a charity trustee of the charity is guilty of an offence.” Section 173(3) gives a defence where the person “took all reasonable steps for securing that the requirement in question would be complied with in time”, and section 173(4) sets the penalty on summary conviction as a fine not exceeding level 4 on the standard scale and, for continued contravention, a daily default fine of up to 10% of level 4 for as long as the person remains a trustee.

The Commission also acts as regulator. In a case the Commission announced in May 2025, a charity was placed in the Commission's “'double defaulter' class inquiry for charities that have failed to file their annual documents for two or more years in the last five years”, and the Commission then opened a statutory inquiry into it under section 46 of the Act.

A wrong answer carries its own risk. Section 60(1) makes it an offence “knowingly or recklessly to provide the Commission with information which is false or misleading in a material particular”, and the Commission's serious incident guidance says this “includes through the annual return.” The safeguard is the evidence pack: an answer the board can trace to a record is an answer it can stand behind.

The decisions behind the answers

The annual return asks the trustees to declare, as at the year end, that a policy was in place, that every eligible role had the right DBS check, and that every serious incident was reported. Each of those rests on a decision, and in a small charity many such decisions are not made in a meeting. The chair agrees by text that the updated safeguarding policy can be used before the next board. Two trustees settle in a group chat on a Sunday that the new youth role needs an enhanced check with the barred list. The treasurer messages the chair that an incident is not reportable, and gives the reasons.

Those messages are the record behind the tick. If they sit in a consumer app on trustees' personal phones, the charity may not be able to produce them when its own answers are questioned, and they can leave with the trustee who stands down. The trustees WhatsApp group guide sets out what such a group can and cannot be used for.

ComplyChat provides channels for a board and its staff and volunteers, with everyone added told that the channel is on the record, and a mobile number verified by SMS as the identity, so volunteers and trustees with no work account can join. Messages are recorded on the server as they are sent, and on paid plans, once the charity's Microsoft 365 tenant is connected, conversations are kept there, under the retention schedules the charity already runs. ComplyChat is not accounting software, does not prepare or file the annual return and does not replace minutes; the return is still answered by the trustees through the Commission's service.

A question for the next board meeting: for each policy you will tick in question 7, could you show the minute, or the message, in which the trustees adopted it?

Questions people ask

What is required for a charity on annual return?

It depends on income and legal form. A charity that is not a CIO with income of £10,000 or less reports only its income and spending; between £10,000 and £25,000 it answers the annual return questions and sends no documents; over £25,000 it also uploads its trustees' annual report, accounts and any examiner's or auditor's report, and declares that no serious incident has gone unreported. Every CIO answers the questions and uploads its report and accounts whatever its income.

How do I do annual returns?

The person filing signs in to their own My Charity Commission Account, set up with an individual email address and password, and submits the charity's annual return from the charity's available services. Prepare the trustees' annual report and accounts first, then upload them when you complete the return; any returns for earlier years must be submitted before the latest one.

Can I file an annual return myself?

Yes. The Charity Commission's guidance says the annual return “must be completed by the charity itself, and the Charity Commission cannot make amendments on your behalf”. An accountant can help prepare the figures, but the trustees remain the people who commit an offence under section 173 of the Charities Act 2011 if it is not sent on time.

When is the charity annual return deadline?

The charity annual return is due within 10 months of the end of the charity's financial year, so a year ending 31 December must be filed by 31 October the following year. The deadline comes from section 169(3) with section 163(1) of the Charities Act 2011, which also lets the Commission allow a longer period for a special reason.

What happens if a charity does not file its annual return?

Failing to send the return on time is an offence by each person who was a trustee immediately before the deadline, unless they took all reasonable steps, under section 173 of the Charities Act 2011. The Commission has placed charities that missed two or more years in five in its “double defaulter” class inquiry, and in one 2025 case went on to open a statutory inquiry under section 46.

What is the charity audit threshold for 2026?

For financial years ending on or after 30 September 2026, a charity in England and Wales needs an audit if its income is over £1.5 million, or over £500,000 with assets over £5 million, and an independent examination above £40,000. The annual return threshold stays at £10,000 and sending the report and accounts at £25,000. The charity audit threshold guide has the detail.

Official guidance and your next step

The law is in sections 169, 163, 173 and 60 of the Charities Act 2011. The Charity Commission's Prepare a charity annual return (updated 16 September 2026) and 2025 and 2026 question guide are the working documents, with the Send a charity's annual return service page and Threshold changes at a glance. Scottish charities should read OSCR's annual reporting guidance, and Northern Irish charities CCNI's annual reporting guidance. Quotations are from those pages as published on 29 and 30 October 2026.

This guide is a summary of the law and guidance in England and Wales, with notes for Scotland and Northern Ireland, not legal or accounting advice about a particular charity's return.

Then do one thing: sign in to your own My Charity Commission Account, note the deadline and financial period it shows for this year's return, and put the question 7 policies and the question 8 DBS and serious incident answers on the agenda of the meeting that approves the accounts.