By Andrew Holt

In their response to the Charity Commission’s information strategy consultation, CFG have called on the Commission to abolish unnecessary and onerous reporting requirements, most notably the ‘summary information return’ (SIR).

Any charity with an income over £1m is required to submit the SIR as part of their Annual Return.

Jane Tully, head of policy and public affairs at CFG, said: “The SIR represents a clear example of unnecessary duplication of reporting –with the information in the SIR already available through the charity’s annual report.

"We don’t believe that it is used to the extent that justifies the time it takes for finance teams to complete it accurately. Its purpose has long been questioned, most recently in Lord Hodgson’s comprehensive review of the Charities Act, and the current consultation offers a timely opportunity to abolish it.”

CFG recognised that being able to extract data on charities quickly and easily is important.

Tully continued: “As an alternative, we believe the Commission should place more emphasis on encouraging charities to set out information in their reports that is clear, simple, easy to understand and that explores the charity’s impact. Technology also presents possibilities for opening up information that is submitted electronically; this would bring huge benefits without placing the burden on charities.”

“The consultation also puts forward the proposition that late filers should be immediately suspended from accessing Gift Aid, something we strongly oppose. This would be a very strong punishment if put into effect automatically after one instance of late filing and would disproportionately affect small organisations or those struggling for resources.”

CFG also recommend that the Commission should:

Explore developments such as iXBRL through discussion with the sector as well as Companies House and HMRC. Compute–readable data formats have the potential to streamline the reporting and regulatory processes, support development of a single point of filing, as well as to open up better quality information and basic analyses to a wider audience;

Include on the register some historic information that gives wider context around individual charities and the sector as a whole. For example, whether an organisation exists as a result of merger or conversion from another legal structure;

Further research the reasons for late filing and fully consult on the proposals for related fines;

Work with HMRC to develop systems of joint registration. In all cases, charities registered with HMRC should be required to register and file accounts with the Charity Commission;

Retain thresholds relating to requirements for registration and submission of accounts, Annual Returns and audit, but allow easier access to voluntary registration for organisations with an income of below £5000 that wish to register with the Charity Commission.

The CFG response can be read here.

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