Register of interests for a charity

What the register is, and which rule asks for one

A register of interests is a standing list of the personal, financial and loyalty interests of the people who take decisions for the charity, principally its trustees. It is not the Charity Commission's public register of charities, which is a different thing entirely, and it is not the conflict of interest policy, which sets out the rules. Our guide to a conflict of interest policy covers what the policy must include; this one covers the register the policy refers to.

The authority for charities in England and Wales is the Commission's guidance Identifying and managing conflicts of interest in a charity (CC29). It starts from the trustees' legal duty: "As a trustee you must make decisions based only on what is in your charity's best interests." It then treats the register as a practical safeguard rather than a formality: "Keeping a register of conflicts can also help you identify conflicts early. Have one at your charity and make sure it is regularly updated." And it says a conflict of interest policy "should" refer to the register and include "a list of the information you will collect when new trustees join the charity, and annually, to keep your register updated".

For most charities that is guidance rather than statute, but three things can turn it into a firmer requirement:

• The governing document. Many constitutions and articles of association contain conflicts clauses, and some require a register expressly. CC29 tells trustees to check theirs first and to change it if it has no adequate rules.
• Company law. Trustees of a charitable company are also directors, with statutory duties under the Companies Act 2006 to avoid conflicts (section 175) and to declare an interest in a proposed transaction or arrangement (section 177). A register is the usual way to show those declarations were made.
• Sector rules. Academy trusts, which are charitable companies, must keep a register under the Academy Trust Handbook. The 2026 edition, effective from 1 October 2026, says a trust "must keep a register of any relevant business and financial interests, for (as a minimum) members, trustees, local governors and senior employees, serving at any point over the past 12 months", and must publish the register for members, trustees, local governors and the accounting officer on its website.

Why bother, if nothing improper is going on? Because the register protects the trustees as much as the charity. CC29 notes that charity trustees "often have a number of different personal and professional interests", and that most of them bring advantages. What causes damage is an interest nobody knew about, or one that looks worse than it is: "Even the appearance of a conflict could damage your charity and wider public trust and confidence in charities." A perceived conflict that was registered, declared and managed is a non-story. The same personal interest, discovered afterwards, is a question about the charity's reputation and about whether the trustees were acting in the best interests of the charity when making a decision.

Funders and auditors also routinely ask to see the register, because it is the quickest evidence that a board takes its duties seriously.

What goes in the register

CC29 describes two kinds of conflict, and the register has to capture the interests behind both. A financial conflict (older policies and local government call these pecuniary interests) arises when a trustee, or a person or organisation connected to them, could receive money or something else of value from a trustee decision; the Commission is clear that "It doesn't matter if the value of the benefit is small". A loyalty conflict, or conflict of loyalty, arises when a decision involves a person or organisation to whom the trustee owes a loyalty that could influence their decision making.

A workable register records, for each trustee (and for any senior staff or committee members the policy includes):

1. Name, role and date of appointment, and the date they stepped down once they leave.
2. Employment and business interests: employer, self-employment, directorships, partnerships, and any business in which they have an interest through ownership or influence, including a shareholding or other beneficial interest above whatever threshold the policy sets.
3. Other trusteeships and governorships, including of charities with the same or similar purposes, which CC29 names as a loyalty conflict in its own right.
4. Memberships and appointments: the organisation that appointed them as a trustee, and any body that funds, supplies, contracts with or campaigns alongside the charity.
5. Connected persons: CC29 lists a trustee's spouse or civil partner, immediate family, business partner and businesses in which they have an interest, and for loyalty conflicts the trustee's employer, wider relatives and friends. The register needs the relationship and the organisation where it matters to the charity, not a family tree.
6. Land and property the charity uses, leases or might buy, and any service the trustee or a connected person uses as a beneficiary, which is the user trustee position CC29 treats separately.
7. Gifts and hospitality above the policy's threshold, if the charity records them here rather than in a separate log.
8. The date each entry was declared and last confirmed, and a nil return where a trustee has nothing to declare, so a blank line cannot be mistaken for a missing one.

The declaration of interests form that feeds the register asks the same questions, in the same order, with a signature and date. Keep it short enough that a trustee completes it honestly in ten minutes; a form that asks for everything collects guesses. The Chartered Governance Institute publishes a specimen policy, declaration form and register of interests, which CC29 itself mentions as a starting point to adapt.

The register holds personal data about trustees and, through the connected persons entries, about people who are not trustees at all. Record what the policy needs and no more, tell trustees how it will be used, and restrict who can see it.

Keeping it current: appointment, annual review and every change

A register is only as good as its last update, and it goes stale in three predictable ways: a trustee's circumstances change and nobody tells the secretary; the annual refresh slips; and a leaving trustee's entry is deleted rather than closed. The fix is a simple cycle:

• Before appointment. CC29 says "Ask about potential conflicts of interest before you appoint trustees", and adds that in some cases "it will be appropriate not to appoint a person likely to be affected by frequent or serious conflicts". The completed declaration form is part of the appointment paperwork, alongside the trustee eligibility declaration.
• Annually. Every trustee confirms or updates their entry, usually before the meeting that approves the annual report. A trustee who has nothing new still signs a nil return.
• On any change. A new job, a new directorship, a family member applying for a post, a partner's business bidding for a contract. The policy should say the trustee tells the secretary or chair as soon as the change arises, not at the next annual review.
• On leaving. Close the entry with the leaving date rather than deleting it. A question about a decision taken while the trustee served will need to know what they had declared at the time.

The policy, and the trustees' code of conduct, should say what happens when someone fails to declare interests they knew about; a deliberate omission is a different matter from an honest oversight corrected at the next review.

Give the register a named owner, usually the company secretary, clerk or chair, and review it as a board once a year, including a check that every trustee has a current entry. CC29 also allows the policy and "some or all of your register of interests" to be made public, with the warning "Make sure you comply with data protection rules if you decide to do this." Publishing the trustees' own business interests and other trusteeships is increasingly common; publishing the names of their relatives rarely is.

Declarations at trustee meetings

The register is the standing picture. A declaration at a meeting is item-specific: it applies the standing picture to the decision in front of the board, and it catches the conflicts the register could not have predicted. CC29 asks for both. Declaring conflicts should be "an agenda item at each trustee meeting", and a trustee must tell the others about a conflict "early, before you have any discussions about the matter or make decisions about it."

In practice, the chair or secretary reads the agenda against the register before the papers go out, and flags any item where a registered interest is likely to matter. At the meeting, declarations are taken at the start, and the board decides how each one is managed before the item is reached. For a financial conflict, CC29 sets a minimum: the trustee should declare it, leave the relevant discussion, not take part in the decision and not be counted in the quorum. For a loyalty conflict the options vary with the risk, from leaving the discussion and decision for high-risk items to allowing the trustee to remain in the meeting without taking part in the decision or voting, which CC29 reserves for low risk loyalty conflicts.

Two practical checks save most of the trouble. First, confirm before the meeting that there will be enough unconflicted trustees to make the decision; CC29 says "You must have enough unconflicted trustees in the meeting when a conflicted trustee withdraws". Second, update the register after the meeting if a declaration revealed a standing interest it did not hold.

What the minutes must show

CC29 is specific about the record. The minutes should show "the trustees who declared a conflict of interest and why", and the charity should "Keep a written record of how you have managed conflicts of interest", adding "You will usually record these in the minutes of your meetings." It lists what that record should contain:

• what the conflict was
• who or what it affected
• when it was declared
• how you managed it, for example asking the conflicted trustee to leave the relevant discussions and not take part in the decision
• which rules you followed, for example the governing document, the law or the steps in the guidance
• that you obtained legal advice, if you did

A good minute is short and complete: "Trustee A declared a financial conflict in item 6 as her husband's firm had submitted a quote for the roof repairs. The trustees agreed, under the conflicts clause in the articles, that she would leave the meeting for the item and not be counted in the quorum. She left at 7.40pm and returned at 7.55pm. The remaining four trustees were quorate." Our minute taking guide covers the rest of the minute.

Once a year, compare the minutes with the register. Every declaration minuted during the year should either match an existing entry or have prompted a new one, and every trustee with a registered interest in a supplier, funder or partner should appear somewhere in the minutes where that organisation was discussed. The gaps between the two documents are where a question from the Commission, an auditor or a journalist will start.

The declaration that never reaches the register

Our guide to a conflict of interest policy describes the declaration made in passing: a message to the chair or a remark in the trustees' group chat, made promptly and correctly and never written up. This section is about what that does to the register, because the register, not the chat, is the document other people read.

When the Commission asks about a decision, when an auditor or a funder asks to see the register, or when anyone reads an academy trust's published register, what they have in front of them is the entries and their dates. They see an interest first recorded at the annual update in June and a decision involving that organisation minuted in March, and the natural question is whether the board knew in March. If the trustee in fact declared it in a message to the chair in February, the register does not say so, and neither do the minutes, because there was no meeting at which it was declared. The trustee behaved properly; the register says otherwise.

So the register needs a way in that does not depend on a meeting. The policy can say it in two lines: whoever receives a declaration by message, usually the chair or the secretary, passes it to the register's owner within the week; the owner enters it with the date it was made and how ("by message to the chair"), and reports it at the next meeting so the minutes record it too. The entry carries the date of the declaration, not the date someone got round to it, and a register that shows where each entry came from is one an auditor can test against the minutes. If the decision the interest relates to is also taken between meetings, our guide to trustee decisions between meetings covers how that decision is recorded.

ComplyChat provides channels for trustee conversations, on the record from the first message, with every trustee told so and free to object or leave, and a mobile number verified by SMS as the identity, so trustees with no account on the charity's systems can take part. Messages are recorded on the server as they are sent, so the register's owner can find a declaration made in a channel, enter it with its date and point to the message behind the entry. On paid plans, once the charity's Microsoft 365 tenant is connected, the lasting record files there under the charity's own retention rules. It is not a register of interests, it does not manage conflicts and it does not replace the minute; the board does those things. ComplyChat Free is personal messaging with one private group, direct messages and three calendar months of recent history, with no Microsoft 365 archive, so it is not a place to keep governance records.

A question for the next board meeting: for each entry on our register, can we say when and how it was declared, and is any interest a trustee mentioned by message this year still missing from it?

Official guidance and your next step

The Charity Commission's Identifying and managing conflicts of interest in a charity (CC29) is the authority for charities in England and Wales, and its examples are worth reading as a board. The Chartered Governance Institute's specimen conflict of interest policy, declaration form and register of interests is the template CC29 mentions. Academy trusts should read the register of interests section of the Academy Trust Handbook. Scottish charities should follow OSCR's guidance and Northern Ireland charities the Charity Commission for Northern Ireland's. Quotations are from those documents as published on 25 September 2026.

This guide is a practical summary, not legal advice. Where a conflict is serious or complex, involves a payment or benefit to a trustee or a connected person, or cannot be managed within the board, CC29 says to get professional advice and, in some cases, the Commission's authority.

Then do one thing: send every trustee their current register entry with a one-line request to confirm or correct it, and record a nil return for anyone with nothing to declare. The replies are the register's annual update, and the trustees who do not reply are the first agenda item for the next meeting.