Who can carry out an independent examination of charity accounts?

The Charities Act 2011 sets a two-tier eligibility framework for independent examiners. The tier that applies to your charity is determined by one figure: gross income in the financial year being examined. Get the tier wrong and the examination is invalid, which can put your annual return filing at risk and draw Charity Commission attention.

The basic rule: independent and capable

For a charity with gross income below £250,000 (£500,000 for financial years ending on or after 30 September 2026), the statutory requirement is that the examiner is independent of the charity and has the relevant capability to carry out the examination. The Charity Commission's guidance (CC32) defines independence as having no financial interest in or close personal connection to the charity. Capability means understanding the examination process, the applicable SORP, and the accounting records well enough to spot material errors or issues.

In practice this means a suitably experienced individual who is not a trustee, not a member of staff, and not a close relative of anyone in those roles. A retired accountant, an experienced treasurer from another charity, or a qualified bookkeeper with charity sector knowledge can all qualify at this level, provided they are genuinely independent.

The professional-body requirement above £250,000

Once gross income reaches £250,000 or above (£500,000 for financial years ending on or after 30 September 2026), the rules tighten. The examiner must be a member of one of the professional bodies listed by the Charity Commission under section 145 of the Charities Act 2011. A capable but unqualified individual is no longer eligible, regardless of experience.

The listed bodies currently recognised by the Charity Commission for this purpose include:

• The Institute of Chartered Accountants in England and Wales (ICAEW)
• The Institute of Chartered Accountants of Scotland (ICAS)
• The Institute of Chartered Accountants in Ireland (ICAI)
• The Association of Chartered Certified Accountants (ACCA)
• The Association of Authorised Public Accountants (AAPA)
• The Chartered Institute of Public Finance and Accountancy (CIPFA)
• The Association of Accounting Technicians (AAT)
• The Association of International Accountants (AIA)
• The Chartered Institute of Management Accountants (CIMA)
• The Chartered Governance Institute UK and Ireland
• The Association of Charity Independent Examiners (ACIE)
• The Institute of Financial Accountants (IFA)
• The Certified Public Accountants Association (CPAA)

These are the thirteen bodies listed under section 145 of the Charities Act 2011. The Charity Commission publishes the definitive current list in its guidance CC32, so check there before appointing an examiner. Membership of the body is the requirement, not simply holding a qualification previously awarded by it. An examiner who has let their membership lapse does not satisfy the condition even if they are technically qualified.

Why the £250,000 threshold matters

The threshold applies to the gross income figure in the accounts being examined, not to the prior year or a rolling average. If your charity's income crosses the threshold for the first time in a given year, you need a listed-body member to examine those accounts even if you used an unqualified examiner the year before. Note the threshold itself changes with your year end: £250,000 for financial years ending before 30 September 2026, £500,000 for years ending on or after that date.

The distinction is not administrative box-ticking. At higher income levels the accounts cover more complex transactions, more grant income, and often more restricted funds. The professional-body requirement reflects the greater technical demands on the examiner.

When a full audit is required instead

An independent examination becomes unavailable entirely once gross income exceeds £1 million, or where income exceeds £250,000 and gross assets exceed £3.26 million (£1.5 million, £500,000 and £5 million for financial years ending on or after 30 September 2026), or where the governing document requires a statutory audit. In those cases a registered auditor must be appointed. If your charity is approaching any of these thresholds it is worth planning ahead, since auditors typically need more lead time than independent examiners.

The examiner's independence requirement

At both income tiers the independence requirement is non-negotiable. The examiner cannot be:

• A trustee or officer of the charity
• An employee of the charity
• A business partner or close relative of any of the above
• Anyone with a financial interest in the charity's affairs

Charities sometimes assume that having their bookkeeper carry out the examination is acceptable because the bookkeeper is not a trustee. It is not. A bookkeeper who prepared the records being examined cannot be considered independent of those records.

CICs and other non-charitable organisations

Community interest companies (CICs) are regulated by Companies House rather than the Charity Commission and are subject to the Companies Act audit regime rather than the Charities Act independent examination framework. Small CICs below the Companies Act audit threshold can take advantage of the small company audit exemption, but this is a different mechanism. The Charity Commission's listed-body requirement applies only to registered charities.

Appointing an examiner: practical steps for trustees

Trustees are responsible for ensuring the charity's accounts receive the appropriate form of external scrutiny each year. Before appointing an examiner, confirm:

1. Your charity's gross income for the year being examined
2. Whether that figure is above or below the qualified-examiner threshold (£250,000, or £500,000 for financial years ending on or after 30 September 2026)
3. If above, that the proposed examiner holds current membership of a Charity Commission listed body
4. That the proposed examiner has no connection to the charity that would undermine their independence
5. That the governing document does not require anything more than an independent examination

A brief written confirmation from the examiner setting out their qualifications and confirming independence is good practice and useful to have on file if the Charity Commission ever raises a query.

Need an independent examination arranged?

If your charity's gross income means you need a member of a listed professional body to carry out the examination, or if you simply want to be sure the appointment is compliant, our independent examination service covers charities at all income levels. Get in touch via our contact page.