Trustee Compliance
Trustees' Annual Report: What It Must Contain and Who Has to File One
A plain-English walkthrough of who must produce a trustees' annual report, when it is due to the Charity Commission, and exactly what it must contain.
Every registered charity in England and Wales must file an annual return with the Charity Commission. Once your charity's gross income exceeds £25,000, that filing must include the trustees' annual report and your accounts. This guide walks through what the report must cover, how the content requirements scale with your charity's size, and how to draft each section.
The short answer: who must produce a trustees' annual report
All registered charities in England and Wales must submit an annual return. The filing is tiered by income: charities with gross income under £10,000 report income and spending only; those between £10,000 and £25,000 answer the annual return questions; those with gross income over £25,000 must also attach the trustees' annual report and their accounts. The key point is that every registered charity files something: the £10,000 and £25,000 thresholds change what is filed, not whether you file at all.
Charities not yet registered because their income is below the registration threshold (currently £5,000, or any income for a charitable incorporated organisation) do not file with the Commission. They should still prepare a report as a matter of good governance.
Scotland operates a separate regime under OSCR. This guide covers England and Wales only. If your charity is registered in Scotland, consult OSCR's accounts guidance directly as the reporting requirements differ.
When the report must be filed
The annual return, along with the trustees' annual report and accounts where required, must be submitted within 10 months of the end of your financial year. A charity with a 31 March year end therefore has until 31 January the following year. The Commission can and does publish late filers publicly, which is a reputational risk most trustees want to avoid.
For charitable companies, you have a parallel obligation to file accounts at Companies House. The Companies House filing deadline is not the same as the Commission's 10-month window. If your charity is a charitable company, check your Companies House deadline separately: this guide does not cover it and the two deadlines should not be conflated.
To keep track of both the report preparation and the filing deadline, many charity finance teams build a year-end timetable that works backwards from the 10-month cut-off. See our guide to the charity commission annual return for the step-by-step filing process.
What the trustees' annual report must contain
The Charity Commission's guidance (CC15b, which sits alongside the detailed CC15d reporting and accounting guide) sets out the statutory content requirements. At a minimum, every trustees' annual report must cover the following.
Reference and administrative information
The opening section identifies the charity: its legal name, registered number, registered address, names of all trustees who served during the year (including anyone who resigned or was appointed mid-year), and the name and address of any advisers (bank, auditor or independent examiner, solicitor). This section is largely mechanical but must be accurate: a Commission reviewer will check trustees listed against the register.
Structure, governance and management
This section explains how your charity is constituted and how it is run. Cover the legal structure (unincorporated association, charitable company, CIO and so on), the governing document, how trustees are recruited and inducted, any related parties or connected organisations, and how day-to-day management is delegated. Larger charities are expected to describe their risk management framework here.
Objectives and activities
Set out your charity's purposes as stated in its governing document, then explain what activities were carried out during the year to advance those purposes. The Commission expects this section to be specific: not "we run community programmes" but what programmes, who they served, and how many.
Achievements and performance
This is the results section. What did your charity achieve against its aims? Include outputs (what you delivered), outcomes (what changed for beneficiaries) where you can evidence them, and any significant challenges. Funders and the public read this section; it should be honest about what worked and what did not.
Financial review
Summarise the financial position: income and expenditure for the year, any surplus or deficit, the level and purpose of reserves, and whether the charity has any material financial commitments or uncertainties. Where reserves have been restricted by donors, explain this. The reserves policy is a specific item the Commission expects to see: trustees should be able to explain why the level of free reserves is appropriate for the charity's needs.
Plans for future periods
A brief forward-looking statement of the charity's objectives and plans for the next year. This does not need to be detailed but it should connect to the activities described and should be realistic given the charity's resources.
Public benefit statement
Trustees must confirm that they have had regard to the Charity Commission's public benefit guidance and explain how the charity's activities have delivered public benefit. This is a legal requirement, not optional narrative. See the dedicated section below.
How the report links to your accounts
The trustees' annual report is filed alongside the accounts, and the two documents need to be consistent: figures in the report must match the accounts, and the narrative in the report should explain what the numbers show.
The type of accounts your charity prepares affects how much the SORP shapes your report. Under Commission guidance, non-company charities with gross income of £250,000 or less (£500,000 or less for financial years ending on or after 30 September 2026) may prepare receipts and payments (R&P) accounts. Charitable companies, and all charities with gross income over that threshold, must prepare accruals accounts.
| Accounts basis | Who it applies to | SORP requirement |
|---|---|---|
| Receipts and payments | Non-company charities, gross income £250,000 or less (£500,000 for years ending on or after 30 Sep 2026) | Not required to follow SORP; simpler report format applies |
| Accruals | All charitable companies; all charities with gross income over £250,000 (£500,000 for years ending on or after 30 Sep 2026) | Must follow the Charities SORP (FRS 102) |
For charities preparing accruals accounts, the Charities SORP (FRS 102) sets out additional disclosure requirements for the annual report that go beyond the statutory minimum. The current SORP 2026 applies to accounting periods starting on or after 1 January 2026. Because the site launches during the transition, date every SORP-related statement in your report to the accounting period it covers rather than describing it as "new" or "old" rules.
Once your charity's gross income exceeds £25,000 (£40,000 for financial years ending on or after 30 September 2026), an independent examination or audit of the accounts is required. The level of external scrutiny accompanies the report when you file. Our IE vs audit threshold checker will tell you which level applies to your charity.
Small charity vs larger charity reporting expectations
The Charity Commission applies a proportionality principle: the level of detail expected in the report scales with the charity's size, complexity and resources. A very small charity operating from volunteers is not expected to produce a report structured like a large national charity's document. The statutory requirements are the same regardless of size, but the depth of treatment differs.
| Charity income | Annual return filing | Report and accounts required | External scrutiny required |
|---|---|---|---|
| Under £10,000 | Income and spending only | Not required to be filed; good practice to prepare | None (unless governing document requires it) |
| £10,000 to £25,000 | Annual return questions | Not required to be filed; good practice to prepare | None (unless governing document requires it) |
| Over £25,000 | Full annual return | Trustees' annual report and accounts must be attached | Independent examination or audit required |
Even where the Commission does not require a report to be filed, trustees of smaller charities should prepare one. It is the record of stewardship for donors, funders and beneficiaries, and is the first document a funder will ask for if you apply for a grant.
Public benefit reporting
All registered charities in England and Wales must report on public benefit. Trustees are required to confirm that they have had regard to the Charity Commission's guidance on public benefit, and to explain how the charity's activities during the year have advanced its purposes for the public benefit.
The report should be specific rather than generic. Stating that the charity "helps people in need" without explaining who was helped, what was done and what changed does not meet the requirement. The Commission's guidance suggests covering: who benefited, how they benefited, how many people benefited, and any barriers to access that the charity worked to address.
Larger charities (those preparing accruals accounts and following the SORP) have additional narrative requirements under the SORP's public benefit reporting module. These go beyond the statutory minimum and cover the relationship between activities and purposes in greater detail.
A weak public benefit statement is one of the most common reasons the Commission requests supplementary information from a charity after it files. Getting this right is worth the time.
Common weaknesses the Commission flags
The Commission publishes findings from its monitoring work. The weaknesses it most consistently identifies in trustees' annual reports are:
- Vague public benefit reporting. Trustees say they have delivered public benefit but give no specific evidence. The Commission expects outputs and outcomes, not assertions.
- Missing or inadequate reserves policy. The report should explain what level of free reserves the charity holds, why that level is appropriate, and what the charity would do if reserves fell below it.
- Incomplete trustee information. All trustees who served during the year must be listed, including those who resigned. Mid-year changes are often omitted.
- No risk management disclosure. Larger charities are expected to describe their principal risks and the controls in place. This section is often too brief or entirely absent.
- Inconsistency with the accounts. Narrative in the report and figures in the accounts must agree. Where the accounts show a deficit, the report should address it.
- Boilerplate plans for the future. A one-sentence placeholder does not meet the requirement. Plans should connect to the charity's purposes and its financial position.
Drafting walkthrough: a section-by-section skeleton
Below is a practical starting point for drafting each section. Adapt the language to your charity's structure and activities.
Section 1: Reference and administrative information
Open with a table or bullet list: charity name, registered number, registered address, names and addresses of trustees (list all who served in the year, noting appointment and resignation dates), name and address of the bank, and name and address of the independent examiner or auditor. Add solicitors or other professional advisers if applicable.
Section 2: Structure, governance and management
State the legal form of the charity and the governing document (its name and date). Explain how new trustees are recruited (nominations, election, co-option), any induction or training provided, and how the board delegates to staff or volunteers. If the charity is part of a group, or has related organisations, describe the relationships. Include the charity's risk management approach: what the principal risks are and how trustees monitor and mitigate them.
Section 3: Objectives and activities
Quote or paraphrase the charitable purposes from your governing document. Then list the main activities carried out during the year, grouped by purpose if helpful. Be specific: "We delivered 48 weekly advice sessions attended by 312 individuals" is more useful than "we provided advice".
Section 4: Achievements and performance
Describe what your charity achieved. Where possible, give numbers: people reached, services delivered, funds raised, projects completed. Acknowledge what did not go to plan and what you learned from it. Funders in particular look for honest performance reporting.
Section 5: Financial review
Summarise income and expenditure for the year. State the level of free reserves at year end and your reserves policy (target level, rationale, and what you would do if reserves fell below target). Note any restricted funds and what they are held for. Flag any material financial risks or uncertainties. The financial review should read alongside the accounts, not duplicate them.
Section 6: Public benefit statement
Confirm that trustees have had regard to the Charity Commission's guidance on public benefit. Then explain, specifically, how the charity's activities advanced its purposes for the public benefit. Include who benefited and how.
Section 7: Plans for future periods
State the key objectives for the next financial year and any significant planned activities. Keep this grounded in your charity's actual capacity and resources. One focused paragraph is enough for most smaller charities.
Approval and signature
The report must record the date it was approved by the trustees and be signed by one trustee on behalf of the board, with the trustee's name printed below the signature.
Getting the report and accounts done together
The trustees' annual report and the accounts are two parts of the same filing. Preparing them together is more efficient than drafting the report and then finding it does not match the accounts. Most charity finance teams run the accounts preparation and the report drafting in parallel, with a final reconciliation before the board approves both.
For charities that need accruals accounts and SORP compliance, the accounts preparation is the more technically demanding task. The annual report cannot be finalised until the accounts are signed off, because the financial review section must reflect the final figures.
If your charity needs help preparing both the accounts and the trustees' annual report, our charity accounts service covers the full year-end package. For charities that also need an independent examination arranged, see our independent examination service. For a deeper look at the SORP requirements that apply to accruals accounts charities, see our guide to Charity SORP 2026.
Frequently asked questions
- Do all charities have to write a trustees' annual report?
- All registered charities in England and Wales must submit an annual return. The trustees' annual report itself must be attached only by charities with gross income over £25,000. Smaller charities should still prepare one as a governance record even if they do not file it.
- When is the trustees' annual report due?
- The annual return, including the trustees' annual report where required, must be submitted within 10 months of the end of your financial year.
- What must a trustees' annual report include?
- The report must cover your charity's purposes and activities, its achievements and performance during the year, its financial position, its plans for the future, and its governance and management arrangements. The Charity Commission's guidance (CC15b) sets out the full statutory requirements.
- Do small charities have to file their report with the Commission?
- Charities with gross income of £25,000 or less do not have to attach their report to the annual return, but all registered charities must submit an annual return. The report is still a useful internal governance document for smaller charities.
- What is public benefit reporting?
- Public benefit reporting is a legal requirement for all registered charities. Trustees must explain in the annual report how their charity's activities have delivered public benefit in line with its stated purposes.
- Does the report have to follow the SORP?
- Charities preparing accruals accounts must follow the Charities SORP (FRS 102). The SORP sets out additional disclosure requirements for the trustees' annual report that go beyond the minimum statutory content. The current SORP 2026 applies to accounting periods starting on or after 1 January 2026.
- Who signs the trustees' annual report?
- The trustees' annual report must be approved by the trustees and signed by one trustee on behalf of the board, naming the date of approval.
- Is the trustees' annual report public?
- Yes. Once filed with the Charity Commission, the trustees' annual report is publicly accessible through the Commission's register. Charity details, finances and the report itself are available to anyone who searches the register.
- What is the difference between the annual report and the annual return?
- The annual return is the Charity Commission's online filing form. The trustees' annual report is a narrative document you prepare alongside your accounts. For charities with income over £25,000, both the report and the accounts are attached to the annual return when you file it.
Need help with your charity's accounts?
Tell us about your charity, CIC or social enterprise and we will arrange a short introductory call.
Get in touch