The Certification Officer’s annual report, laid before Parliament on 2 July 2026, gives a year-end account of the regulator’s work in 2025/26 and compiles annual return data from trade unions and employers’ associations for 2024/25. For policy readers, the report matters less as a political statement than as a record of how the statutory framework is now operating after recent legislative change. Throughout, the report points to a system in transition. The headline data cover membership, assets, funds, political funds and member complaints, but the more consequential point is institutional: during the reporting year, the Employment Rights Act 2025 altered the Certification Officer’s remit and reversed several changes introduced by the Trade Union Act 2016.
The register itself remained broadly stable. According to the Certification Officer, three organisations were added to the list of trade unions, taking the total to 131, while the number of listed employers’ associations stayed at 36 with no additions or removals. That stability matters because listed status sits at the centre of the regulatory model. Inclusion on the register determines which organisations must file annual returns and which bodies fall within the Certification Officer’s supervisory framework. For unions and employers’ associations, the report serves as a reminder that routine filing duties remain in place even as the scope of oversight has changed.
The most eye-catching figure is a reported 19.4% fall in trade union membership, from 6.7 million in 2023/24 to 5.4 million in 2024/25. The report itself cautions against reading that as a simple year-on-year contraction. Unite the Union submitted membership figures for 2023/24, but its annual return containing membership and financial information was not provided for 2024/25, materially affecting the aggregate total. The wider financial picture is mixed rather than uniformly negative. Reported total assets fell by 1.3%, from £2.30 billion to £2.27 billion, while total funds rose by 4.76%, from £1.89 billion to £1.98 billion. As the report notes, all figures are drawn from annual returns received during the reporting year, so comparisons should be treated with care where an individual return is missing.
Political fund reporting also shifted. Of the 21 trade unions with political funds, 19 submitted annual returns with financial information. Those returns showed £29.4 million held across the reported political funds, down 17.88% on the previous year, when 20 unions supplied information. For readers assessing campaigning capacity or party-political activity, that decline requires caution. As with the membership totals, the reporting base changed between years. The figures remain useful as an administrative snapshot, but they do not by themselves establish a like-for-like fall across every union maintaining a political fund.
The complaints data show a sharper operational change. The Certification Officer dealt with 46 complaints from union members against their trade unions, compared with 13 in the previous year. Two applications were withdrawn and four were struck out. Of the 40 complaints that went to a hearing, seven were upheld and 33 were dismissed. The report records two enforcement orders and one financial penalty order. The penalty arose from a case in which a union member was not given access to the union’s accounting records. For unions, this is a clear signal that internal administration, record-keeping and member access rights remain live areas of legal risk even where the regulator’s wider investigatory reach has been reduced.
The principal policy development in the report is the commencement, during the reporting year, of amendments made by the Employment Rights Act 2025. According to the Certification Officer, those amendments restored the office’s powers to the position that applied before the Trade Union Act 2016. In practical terms, this narrows the post-2016 compliance framework rather than expanding it. Three changes are especially significant. Trade unions are no longer required to include information on industrial action, or the more detailed political expenditure data introduced under the 2016 regime, in their annual returns. The Certification Officer also lost the additional powers that allowed breaches of certain statutory duties to be determined, and non-compliance to be investigated, without first receiving a complaint from a member. In addition, the office no longer has the power to raise an annual levy on listed trade unions and employers’ associations to recover the costs of regulation.
The report also confirms a further reversal in political fund rules. For unions with political funds, the Employment Rights Act 2025 restores the pre-2016 position under which new members may be treated as contributing unless and until they submit an opt-out notice. That change is likely to reduce administrative friction for affected unions, while increasing the importance of clear member communications and robust opt-out handling. The annual report notes that Stephen Hardy is the current Certification Officer, having taken office on 1 October 2025. He succeeded Sarah Bedwell after her retirement on 31 May 2025, with Michael Kidd serving on an interim basis from 1 June to 30 September 2025. Taken together, the figures and the legal changes point to a more complaint-led, less interventionist model of regulation, with fewer reporting demands but continued scrutiny where members bring formal cases.