A new statutory instrument will raise a series of financial thresholds across charity law in England and Wales from 30 September 2026. The Charities Acts 1992 and 2011 (Substitution of Sums) Order 2026 was made on 17 April 2026, laid before Parliament on 20 April 2026, and signed by Stephanie Peacock, Parliamentary Under-Secretary of State at the Department for Culture, Media and Sport. The legislation is technical, but the practical effect is straightforward. According to the Order and its explanatory note, higher cash limits will now determine when certain fundraising rules apply, when simpler accounts may be used, when independent examination is required, when a statutory audit is triggered, and when the Charity Commission may act under a specific concurrent jurisdiction route.
The first set of changes sits in Part 2 of the Charities Act 1992 and affects fundraising regulation. The Order raises remuneration thresholds used in the definition of a professional fund-raiser from £10 to £15 in the daily test and from £1,000 to £1,500 in the higher-value tests. The same monetary changes are made to the lower-paid collector provisions in section 60B. For charities and agencies, that means some activity that was previously caught by these rules will fall below the statutory figures after 30 September 2026. The Order also lifts the section 60 payment threshold from £100 to £150, which affects disclosure requirements tied to payments made in response to fundraising appeals. In section 61, the minimum donation linked to cancellation rights for certain payments and agreements also rises from £100 to £150 for future appeals.
The Charities Act 2011 changes are more significant for trustees and finance teams. In section 70, the gross income threshold connected to restrictions on the Charity Commission's concurrent jurisdiction rises from £500 to £1,000. In practice, that changes the income ceiling for applications made under that part of the Act, while leaving the wider legal structure in place. The Order also doubles the section 133 threshold for simpler receipts and payments accounting from £250,000 to £500,000. For smaller charities, that is likely to be the most noticeable shift. Charities that fall within the revised limit will have a broader option to prepare a receipts and payments account and a statement of assets and liabilities, rather than full accrual-style accounts, where the Act allows that route.
Audit and examination rules are also adjusted upwards. In section 144 of the 2011 Act, the audit threshold in one limb rises from £1 million to £1.5 million, while the higher assets figure in another limb rises from £3.26 million to £5 million. The drafting matters because the audit test does not turn on a single figure alone; the statutory conditions still need to be read together. Section 145 is amended in two places. The lower threshold for when an independent examination or audit becomes necessary rises from £25,000 to £40,000, and the higher income threshold in that section rises from £250,000 to £500,000. The immediate effect is that some charities now sitting between the old and new limits may move into a lighter-touch reporting position, although governing documents, funder conditions and lender requirements may still point to audit even where the statute does not.
The Order also amends the Charities Act 2011 (Group Accounts) Regulations 2015. The gross income threshold used for the exception to preparing group accounts is increased from £1 million to £1.5 million, and the threshold for audit of accounts of larger groups is raised by the same amount. For charities operating through subsidiary structures, that is a material compliance change. Group reporting duties can be costly and time-consuming, so the revised figures may reduce the reporting burden for some organisations beneath the new threshold. Regulation 6 of the 2015 Regulations, which contained a transitional provision, is removed because the new Order supplies its own transitional rule.
The transitional provisions are unusually important and should stop organisations applying the new figures too early. The Order states that the fundraising amendments in the 1992 Act do not disturb the old rules for solicitations made before 30 September 2026. Payments of £100 or more made before that date remain subject to the earlier section 60 position, and the previous £100 cancellation threshold continues for payments and agreements tied to appeals or representations made before commencement. There is a similar rule for the Charity Commission threshold in section 70: the new £1,000 figure does not apply to applications made before 30 September 2026. On the accounting side, the revised thresholds in sections 133, 144 and 145, together with the group accounts changes, do not apply to any financial year ending before 30 September 2026. For trustees, the operative date is therefore not only 30 September itself, but also the charity's year-end and the date on which a fundraising approach or application was made.
Taken together, the changes do not alter the architecture of charity regulation. They reset the sums that decide when existing duties are engaged. That is likely to be welcomed by charities that have argued that older figures no longer reflected current operating costs, particularly in audit, examination and lower-value fundraising activity. The immediate task for trustees, finance leads and advisers is to check which side of each revised threshold the charity will sit on after 30 September 2026, and whether internal policies still match the law. Fundraising scripts and donor communications should be checked against the new £150 figures, while finance teams should revisit accounting and assurance plans for the first financial year ending after commencement. The explanatory note states that a full impact assessment is available from the Department for Culture, Media and Sport and is annexed to the Explanatory Memorandum published alongside the Order.