Charity Commission changes to Annual returns

The Charity Commission for England and Wales have made some changes to the questions asked as part of a charity’s annual return. These apply for annual returns being completed where the financial year end is 1 January 2023 or later. 

There are some new questions around finances and structure – which will mean groups need to provide extra information compared to the previous year, but we don’t think this will be problematic for most groups.

For more information about what you’ll need to prepare, read the Charity Annual Return 2023: question guide

Policies  

An area that might cause concern is the governance question, which has a checklist of policies and asks you to confirm what policies your charity has in place.  

It is important to note that there is no requirement that you have all these policies in place. If you don’t, there are no marks against your charity.  

That said, policies are a useful way to focus your thinking and make sure you are acting in your charity’s best interest as well as protecting individuals connected to your charity. The new annual return question is not designed to catch you out – it is about encouraging charities to think about how they operate and what policies might benefit them. If you don’t have these policies, that’s fine, but it may be worthwhile to consider if it is something you should work towards.  

When thinking about what policies you need and what they should say, think about the nature and size of your charity and your activities.  

Policies should establish rules and ways of operating and provide a framework for decision making. All charities deal with money, and having some rules about how that works is sensible. But the considerations for a community orchestra will be different to those of Making Music, and different still for large international charities. For the policy to be useful it has to be relevant, proportionate and realistic for your group.  

Social media is another good example here. The Charity Commission is talking about this quite a lot. Undoubtedly, a tool as powerful as that comes with some risks. But what Green Peace needs to put into a policy is a long way from the light touch approach trustees of a leisure-time music group might take, where understanding responsibilities and what to prepare for in case there are any issues would suffice. 

What policies will we be asked about?

The full list on the annual return is below – along with links to guidance for more info.  

The Charity Commission expects most charities to have policies and procedures in place for those marked bold in the list below. Again, this does not mean that you are required to have them in place – but that the regulator sees having them as best practice to help protect your charity and its interests.  

They also suggest the policies marked with an * below are ones groups might consider. This will depend on the nature of your activities. If you don’t invest money or engage in political activity, you don’t need a policy. But do bear in mind that if you are going to start doing any of these things, you should think about a policy before you do.  

Full list of policies on annual return:  

1) Internal charity financial controls policy and procedures 

2) Trustee expenses policy and procedures 

3) Trustee conflicts of interest policy and procedures 

4) Serious incident reporting policy and procedures 

5) Internal risk management policy and procedures 

6) Safeguarding policy and procedures 

7) Financial reserves policy and procedures 

8) Complaints policy and procedures 

  • Making Music guidance to follow  

9) Investing charity funds policy and procedures* 

10) Campaigns and political activity policy and procedures* 

11) Bullying and harassment policy and procedures* 

12) Social media policy and procedures 

13) Engaging external speakers at charity events policy and procedures

Safeguarding: There is also a new question about safeguarding and obtaining relevant DBS checks. Read Making Music’s guidance, which can help you understand when DBS checks are required.  

If you have any questions about the new Charity Annual Return, get in touch at info@makingmusic.org.uk