The Certification Officer’s annual report, laid before Parliament on 2 July 2026, gives a combined account of the regulator’s work in 2025/26 and the annual return data submitted by trade unions and employers’ associations for 2024/25. The GOV.UK announcement presents the document as both a regulatory update and a record of the statutory changes that took effect during the year. For policy readers, the report matters for two reasons. It provides the latest official figures on union membership, assets, funds and complaints, and it records the reporting year in which the Employment Rights Act 2025 reversed parts of the post-2016 regime. The announcement also states that all headline figures are drawn from annual returns received during the reporting year.
According to the report, three organisations were added to the statutory list of trade unions, taking the total to 131. The number of listed employers’ associations was unchanged at 36. That points to continuity in the formal register even as the wider legal position has shifted. In regulatory terms, inclusion on those lists remains the starting point for which organisations fall within the Certification Officer’s reporting and oversight remit.
Headline membership data showed a reported fall of 19.4%, from 6.7 million in 2023/24 to 5.4 million in 2024/25. The report itself cautions against reading that as a clean year-on-year contraction, stating that Unite the Union supplied membership figures for 2023/24 but did not provide its annual return of membership and financial information for 2024/25. The financial picture was more mixed. Reported total assets of trade unions edged down by 1.3%, from £2.30 billion to £2.27 billion, while reported total funds rose by 4.76%, from £1.89 billion to £1.98 billion. Read together, those figures suggest that union finances remained sizeable even though the membership series is affected by an incomplete return.
Political fund reporting also requires careful reading. Of the 21 trade unions with political funds, 19 submitted annual returns with financial information. Across those returns, total holdings in political funds were £29.4 million, down 17.88% on the previous year, when 20 unions provided the relevant data. The Employment Rights Act 2025 also changes the operating position for those funds. As the GOV.UK announcement explains, the law restores the pre-2016 arrangement under which new members may be treated as contributing to a political fund unless and until they submit an opt-out notice. For unions, that places renewed weight on member notices, subscription processes and internal record-keeping.
The report records a sharp increase in formal complaints by members against their unions. The Certification Officer dealt with 46 complaints, up from 13 in the previous year. Two were withdrawn and four were struck out. Of the 40 that went to a hearing, seven were upheld and 33 were dismissed. Two enforcement orders were made in the upheld cases. Separately, the Certification Officer made one financial penalty order in a case where a union member was not given access to the union’s accounting records. In practical terms, the data indicate that complaint-based enforcement remained active even as some of the broader post-2016 powers fell away.
The most consequential policy change in the report concerns the Employment Rights Act 2025. The amendments that came into force during the reporting year restored the Certification Officer’s powers to those that applied before the Trade Union Act 2016. According to the GOV.UK notice, that removed the requirement for trade unions to include industrial action information and more detailed political spending information in annual returns. It also removed the additional power to determine certain breaches and to investigate non-compliance without first receiving a member complaint, and ended the power to raise an annual levy from listed trade unions and employers’ associations. The officeholder context is also set out in the announcement. The Certification Officer is described as the independent regulator for trade unions, appointed by the Secretary of State for Business and Trade. Stephen Hardy, appointed on 1 October 2025, is the current holder of the office. He succeeded Sarah Bedwell, who left the post on 31 May 2025 after serving since 2017, with Michael Kidd acting on an interim basis from 1 June 2025 to 30 September 2025. Taken together, the report points to a deliberate return to a narrower, member-complaint-led model of oversight.