Charity Commission deadlines run on a different clock from Companies House, and for charitable companies that means two regulators with two filings. Most missed CC returns are a calendar problem, not an accounting one.
What the Charity Commission annual return covers
The annual return (AR) is the trustees' submission to the Commission covering activities, governance, finance and trustee details. For charities above the threshold it sits alongside the statutory accounts and the Trustees' Annual Report (TAR). The Commission has expanded the questionnaire steadily since 2023, and the 2026 form now includes questions on safeguarding, employee remuneration bands and overseas activity that catch first-time filers off-guard.
The 10-month filing window
The deadline is 10 months after the charity's financial year-end. So a 31 March 2026 year-end means the AR, accounts and TAR are all due by 31 January 2027. Same date for all three. The Commission doesn't stagger them the way HMRC and Companies House do.
How it differs from Companies House
For a charitable company, accounts are due at Companies House 9 months after year-end and at the Commission 10 months after year-end. Same accounts, two filings, one month apart. CIOs (Charitable Incorporated Organisations) file only with the Commission, with no Companies House obligation at all, because they're not Companies Act entities.
This is the single most common trap. A generalist practice picks up a charitable company, treats the CH filing as 'done', and forgets the CC obligation a month later. The trustees commit an offence under s.173 Charities Act 2011 for failure to file accounts, and the Commission's register flags 'overdue' publicly within days of the deadline passing.
Income thresholds and what they trigger
The thresholds determine what level of scrutiny applies. They're due to change from 1 October 2026 under new DCMS regulations.
| Gross income | Until 29 Sep 2026 | From 30 Sep 2026 |
|---|---|---|
| Up to £10,000 (non-CIO) | Update charity details only | Same |
| CIO (any income) | Full annual return required | Same |
| Above £10,000 (or any CIO) | Full AR + accounts + TAR | Same |
| Above £25,000 | Independent examination required | Threshold rises to £40,000 |
| Above £250,000 | Qualified examiner required | Threshold rises to £500,000 |
| Above £1m income (or assets >£3.26m + income >£250k) | Statutory audit | Audit threshold rises to £1.5m |
The 'qualified examiner' point catches more firms than it should. Between £250,000 and £1m of income, the examiner must be a member of one of the listed bodies (ICAEW, ACCA, AAT and others). Defaulting to 'we're below the audit threshold so any IE will do' is wrong above £250,000.
Filing for charitable companies (CIOs vs companies)
A worked example. Charity A is a CIO with £180,000 income, year-end 31 March 2026. One filing: AR + accounts + TAR + independent examination to the Commission by 31 January 2027. No Companies House anything.
Charity B is a charitable company limited by guarantee, same income, same year-end. Two filings: accounts to Companies House by 31 December 2026 and AR + accounts + TAR + IE to the Commission by 31 January 2027. Same accounts go in both places. Miss either and you have a problem.
Consequences of late or missed returns
The Commission doesn't levy automatic financial penalties the way Companies House does, but the public register flags the charity as overdue, which is visible to funders, donors and the media. For grant-funded charities that's often a direct hit on income. Repeated failure triggers regulatory engagement, statutory inquiry powers under Charities Act 2011 Part 6, and in serious cases trustee disqualification under s.181A. Trustees commit an offence under s.173 for failure to file accounts.
Don't forget the separate serious-incident reporting obligation. It isn't part of the AR and it isn't annual. It's event-driven, and the Commission expects timely reporting independently of the filing cycle.
Coordinating both regulators in one workflow
For charitable companies, the cleanest approach is to set the CH 9-month date as the internal deadline and the CC 10-month date as the buffer. If you sign and file at CH by the 9-month date, you have a month of headroom for the CC submission, which is usually where the AR questions take longer than expected. Trying to do both on the same day in late January, with SA returns also landing, is how filings get missed.
For context across the rest of the year, our 2026 deadline calendar shows where the charity dates sit alongside everything else.
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