Charity Commission proposes changes to Annual Return

The Charity Commission for England and Wales is consulting on changes to the annual return for charities.

One of the main proposed changes is that the number of core baseline questions being asked is doubling, from 16 to 32, and some charities may now need to answer 52 questions in total.

At the same time – and particularly relevant to ACO members – there is also a proposed new question for charities which are principally grant-makers on what percentage of grants were made to individuals and to other charities. The Commission will also ask whether any of those grants were to connected parties.

Another area of potential concern is that some benevolents/grant-makers may also appear as a risk category, as the Commission is seeking to identify which charities are reliant on a single income stream, and ACO members with a single endowment could be included in this.

In addition, there are a number of questions ACO members will now have to answer questions on, from employment, salaries, premises and other aspects of their operation.

In conjunction with ACF (Association of Charitable Foundations) we will be following up with the Commission on some of these issues and will report back further. The changes will come into effect in 2023.

You can access the consultation at: Charity Commission: revisions to the Annual Return 2023-25 – GOV.UK (

If you have any comments/queries please contact