2025 has already proved to be a landmark year for UK charities, not only in regulation and governance, but also in expectations around transparency and accountability. With new guidance, refreshed codes, and the introduction of criminal liability for failure to prevent fraud, trustees can no longer afford to take a passive approach.
We’ve summarised the key updates that every charity board should be across this year, so pull up a chair, pour yourself a drink, and read on!
8 Key 2025 Trustee Updates
1. Trustee Recruitment and Board Skills
The Charity Commission updated its guidance in May 2025 to strengthen the expectations around trustee recruitment and skills planning. Boards are now expected to demonstrate a deliberate approach to diversity, skills mix, and succession planning.
2. Payments to Trustees and Connected Persons
April 2025 saw refreshed guidance (CC11) clarifying the narrow circumstances under which a trustee or connected person can be paid. The underlying principle remains the same. Trustees must act in the charity's best interests, and any payment must be clearly authorised and transparent.
3. Annual Returns and Reporting
The 2025 Annual Return introduces additional questions for charities with financial years ending in 2025. Larger charities, with income over £25,000, must upload trustees’ reports, accounts and audit or examination statements.
Check that your internal systems capture all of the required data and integrate serious incident reporting before submission.
4. Charity Governance Code Refresh
A new version of the Charity Governance Code is expected towards the end of 2025. While the fundamental principles are unchanged, updates will reflect modern challenges such as digital risk, environmental impact, and public transparency.
Don’t wait, assess your compliance with the current Code now and be ready to transition once the revised version is published.
5. Fundraising Regulation Update
From the 1st November 2025, a new Code of Fundraising Practice will come into force. It is more concise and principle-led, aiming to simplify compliance while placing greater emphasis on ethical fundraising.
6. “Failure to Prevent Fraud” Offence
From September 2025, larger charities could face criminal liability if they fail to prevent fraud by staff or associates. The new offence aims to strengthen organisational accountability and improve internal controls.
Review your charity's fraud risk assessment, internal control framework, and staff training programmes. Smaller charities should also adopt the same proactive approach.
7. Investment Governance Principles
In January 2025, the Charity Investment Governance Principles were launched to help trustees oversee investment responsibilities. They focus on delegation, decision-making, and reporting. Use the new principles to benchmark your investment policy, delegation arrangements, and risk oversight.
8. Scottish Charities: Trustee Data Reporting
From the 30th June 2025, Scottish charities now have to submit trustee data through OSCR Online, with more detailed information required from 2026. Ensure trustee records are accurate, up to date and compliant with GDPR rules before the new requirements take effect.
So, what are the common themes for 2025?
Across all of these changes, the message is clear:
- Governance maturity is no longer optional.
- Transparency and accountability are under sharper regulatory focus.
- Prevention and preparedness, particularly around fraud, are now central to compliance.
What should Trustees do now?
We’ve compiled a detailed checklist for your next Trustee board meeting:
- Conduct a governance and skills gap analysis,
- Update the key policies (fraud, fundraising, trustee payments and investments),
- Review internal controls and risk management frameworks,
- Ensure trustee training is current and recorded,
- Prepare for new annual return and data reporting requirements,
- Monitor for publication of the updated Charity Governance Code.
How Haines Watts can help
Our specialist Charity & Not-for-Profit teams support boards and leadership teams across the country with:
- Governance reviews and trustee training.
- Annual return and reporting support.
- Internal control and fraud risk assessments.
- Charity investment and reserves strategy reviews.
- Strategic planning and financial sustainability advice.
