Charities monthly round-up – July 2026

July marks the peak of summer: Wimbledon, a fleeting spell of sunshine and the countdown to the school holidays. This year, hopes of football finally coming home were once again put on hold, proving that some traditions are harder to break than others. Whatever happened on the pitch, the charity sector remains as busy as ever, with plenty of developments to share and challenges to tackle.

Start preparing for Companies House reforms now

Although major accounts filing changes have been delayed until 2028, charities with corporate structures and trading subsidiaries should begin reviewing their accounting systems, reporting processes and governance arrangements to ensure they are ready for the new requirements.

Don’t leave ID verification until the last minute

The new Companies House identity verification regime is now affecting routine filings. Encourage directors and trustees to complete verification early and check personal details against Companies House records to avoid delays when filing confirmation statements.

Revisit the governance basics

Recent Charity Commission regulatory action and changes to organisational criminal liability both reinforce the importance of strong governance. Trustees should ensure governing documents are being followed, financial oversight is robust, roles and responsibilities are clear and senior leaders understand their compliance obligations.

Now let’s take a closer look at this month’s developments.

Less paper, more data: Companies House reforms delayed until 2028

Companies House has confirmed that a package of accounts filing reforms introduced under the Economic Crime and Corporate Transparency Act 2023 will now come into force from April 2028, rather than as originally planned in April 2027. The changes are designed to improve the transparency, accuracy and reliability of information held on the Companies House register, while also helping to tackle economic crime. You can read the guidance on this in full here.

The reforms include requiring all companies to file annual accounts using commercial software in iXBRL format, removing the option to file abridged accounts, strengthening audit exemption statements and requiring all components of accounts and reports to be filed together. Small companies and micro-entities will also be required to file a profit and loss account with Companies House, although they will be able to opt out of having that information published on the public register.

For charitable companies and charities with trading subsidiaries, this means those entities will need to ensure they can file accounts using compliant software and meet the enhanced reporting requirements. While 2028 may still feel a long way off, now is a good time to start thinking about whether your current systems and processes are fit for what’s coming next.

Charities with corporate structures may wish to use the additional preparation time to:

• Review how accounts are currently prepared and filed;
• Consider whether existing accounting software can produce accounts in the required iXBRL format;
• Discuss the upcoming changes with auditors and accountants;
• Ensure directors understand their responsibilities under the new filing requirements;
• Review whether current group reporting arrangements are still working effectively.

Although implementation is still some time away, charities that start planning now are likely to find the transition much smoother. For organisations that are considering setting up a trading subsidiary or other corporate structure, the reforms are also a useful reminder that governance, reporting processes and company constitutions should be designed with future compliance requirements in mind.

Back to basics: governance matters

Strong governance is often about getting the basics right, including:

• Trustees should make sure their charity is operating in line with its governing document, including maintaining the required number of trustees and ensuring that decisions are taken properly and with the necessary quorum.
• Trustees should be able to demonstrate that charitable funds are being used to further the charity’s purposes and that there is clear evidence to support how those funds have been spent.
• Good record keeping, appropriate financial controls and effective oversight of income and expenditure are all key to protecting charitable assets and maintaining public trust.
• Trustees should also carry out appropriate due diligence when appointing professional advisers and when managing projects, grants or activities involving the transfer of funds.

It is worth remembering that, even where a charity relies on accountants, advisers or volunteers, ultimate responsibility for compliance remains with the trustees. Accurate and timely accounts, compliance with reporting requirements and the ability to evidence significant transactions are all fundamental trustee responsibilities. Charities should also think carefully about how they monitor the use of funds, particularly where money is being paid to third parties or used overseas. Having robust procedures in place from the outset can help avoid governance and compliance issues further down the line.

These themes were recently highlighted in the Charity Commission’s inquiry into Jesus Power House Ministries Ltd. The inquiry identified a range of governance and financial management failings, including the charity operating for lengthy periods with fewer trustees than required by its governing document, weaknesses in financial record keeping, unsupported expenditure and ongoing accounting and reporting issues. The Commission concluded that there had been serious and sustained misconduct and/or mismanagement in the administration of the charity and ultimately removed the sole trustee. While the facts of the case were unusual, the inquiry is a useful reminder that governance, financial oversight and trustee accountability remain key areas of regulatory focus for the Charity Commission.

If you want to discuss your current governance arrangements please contact Edwina Turner or your usual Anthony Collins contact.

A new liability risk for incorporated charities

A recent change in the law may be relevant for some charities, in particular, those with an incorporated legal structure. Under s250(1) of the Crime and Policing Act 2026, where a senior manager commits a criminal offence while acting within the actual or apparent scope of their authority, the organisation itself may also be deemed to have committed that offence. This change significantly widens the circumstances in which an organisation can be held criminally liable for the actions of its senior people.

The new provision will not affect every charity. Whether it applies depends on the charity’s legal structure. Charitable companies, CIOs and charitable community benefit societies are all corporate entities and can fall within the scope of the new rules. In contrast, charities that are established as trusts or unincorporated associations are not bodies corporate and are therefore outside the scope of section 250(1).

For charities that are within scope, this is really just another prompt to revisit the governance basics (which seems to be a recurring theme in this month’s newsletter!). Trustees may want to think about who in the organisation could be considered a ‘senior manager’, whether roles and responsibilities are clearly defined, and whether there is appropriate oversight of key decisions and risks.

For most charities, this isn’t about introducing lots of new policies or procedures. Instead, it’s a good opportunity to sense-check that reporting lines are clear, senior leaders understand their responsibilities and existing governance and compliance arrangements are working as intended.

My colleagues Lorna Kenyon-Pain and Tim Coolican in our regulatory team, along with my governance colleague Catherine Simpson, have written a great blog post on this topic which you can read here.

Don’t underestimate the new ID verification requirements at Companies House

Many will already be aware of the new identity verification requirements introduced by the Economic Crime and Corporate Transparency Act 2023. These changes are being phased in, but in practice they are now beginning to have a real impact on routine filings – particularly confirmation statements for companies.

For current directors, the requirement comes into play when the company files its first confirmation statement after 18 November 2025. In other words, this is often the point at which existing companies encounter the practical challenges for the first time.

We have recently been supporting clients through their first confirmation statements under the new regime, and what would ordinarily have been a straightforward ten-minute filing became a much more time-intensive exercise. The key learning is that most issues only come to light once the filing process has started. Common problems included mismatches between a director’s legal name and what is recorded at Companies House (for example, missing middle names or abbreviated names), incorrect dates of birth, and simple errors in the personal ID codes provided.

To help avoid delays, we strongly recommend:

• asking directors/trustees to complete their ID verification well in advance of any filing deadline, rather than waiting for prompts from Companies House;
• requesting and checking personal codes as soon as they are provided (rather than waiting until you have received them from all your directors); and
• starting your confirmation statement earlier than you might expect, so that any issues can be identified and resolved in good time.

Looking ahead, we are also advising clients to embed this into their governance processes. In particular, companies should look to obtain ID verification and personal codes as part of their standard trustee/director recruitment and onboarding processes. Taking this proactive approach can help avoid last‑minute complications and ensure filings are completed efficiently.

While these requirements apply to all companies (including charitable companies), they do not apply to other entity types such as CIOs or charitable community benefit societies. However, they will still be relevant for any group structure which includes a company (e.g. a charity’s trading subsidiary).

The Charity Commission wants your feedback

If you regularly deal with the Charity Commission – whether as a trustee, charity employee, adviser or professional user – this may be of interest. The Commission is currently looking for people to take part in its user research programme, giving participants the opportunity to share feedback on its services, systems and guidance.

Whether you’ve found a particular process frustrating, have suggestions for improving guidance, or simply want to share what works well (and what doesn’t!), this is a chance to help the Commission better understand the user experience and shape future improvements. The feedback gathered will be used to help make the Commission’s services more user-friendly and reduce burdens on those who use them.

Further information on how to take part can be found here.

More information?

For more information or advice on the topics covered in this month’s newsletter, please get in touch with your usual AC contact or Edwina Turner.

For those of you who may not know me, I am an executive in the governance, funding and corporate team, where I advise charities on registration, incorporation and governance matters. Over the past 15 years, I have supported both new and established charities through restructures, incorporations and conversions to CIO status.