Making sense of the Charity Commission’s serious incident reporting updates

The Charity Commission’s guidance on reporting serious incidents remained unchanged for more than six years, from June 2019 until two updates in quick succession in December 2025 and January 2026.

The update notes on GOV.UK are brief, referring to “unacceptable experiences” and “changes as part of Charities Act 2022.”

Given the lack of detail, many in the sector will be wondering what has actually changed. Having compared the 2019 and 2026 versions, we can report that the amendments are modest – and trustees familiar with the existing guidance will be relieved to see their core obligations remain the same.

What is the serious incident reporting regime?

The Charity Commission requires charities to report serious incidents promptly. A serious incident is an adverse event, actual or alleged, which results in or risks:

• Significant harm to beneficiaries, staff, volunteers or others
• Loss of money or assets
• Damage to property
• Harm to the charity’s work or reputation.

The responsibility for reporting rests with trustees. The Commission uses these reports to check that trustees are handling incidents appropriately, to offer regulatory guidance where needed and to identify risks affecting the wider sector.

What has actually changed?

After comparing the June 2019 and January 2026 guidance, we can confirm that the amendments fall into a small number of categories – none of which alter the fundamental reporting obligations.

Charities Act 2022: trustee disqualification language

There has been a minor, administrative amendment to reflect the provisions in the Charities Act 2022 relating to trustee disqualification.

The 2019 guidance said trustees should report if someone is disqualified because, among other things, “they are on the sex offenders register.” The 2026 guidance now refers to the correct statutory reference – Part 2 of the Sexual Offences Act 2003 – following clarification of the automatic disqualification criteria for charity trustees.

Action Fraud becomes Report Fraud

The national fraud and cyber crime reporting service has rebranded from ‘Action Fraud’ to ‘Report Fraud’. Again, this is administrative only; trustees should simply note the new name when reporting fraud or cyber crime.

Cyber Essentials Scheme reference removed

The 2019 guidance included a specific reference to the government’s ‘Cyber Essentials Scheme’ for accreditation. The 2026 version replaces this with a more general reference to “guidance about protecting your charity from cyber crime”. This reflects the broader range of cyber security resources now available, rather than any change in the Commission’s expectations.

Further minor updates

The remaining changes represent housekeeping only. References to supplementary documents, including the Examples Table and the Risk Framework, have been updated to reflect current terminology.

What about “unacceptable experiences”?

The December 2025 update includes examples that should be reported to the Commission where a charity is facing “unacceptable experiences such as harm to their charity or people associated with it.” This prompted speculation that the Commission might be introducing new categories of reportable incident.

However, provisions regarding harm to trustees, staff and volunteers already existed in the 2019 version. The guidance has long made clear that workplace incidents resulting in or risking significant harm to trustees, staff or volunteers may be reportable, particularly “where the level of harm to the victims and/or the likely damage to the reputation of or public trust in the charity is particularly high.”

The December 2025 update added examples to the supplementary “Examples Table: deciding what to report”, rather than the main guidance text. The Table now includes references to scenarios involving a risk of harm to charities, their property or their trustees, staff, beneficiaries or volunteers – and an indication of what could be a serious incident requiring reporting and what doesn’t meet the threshold.

Other amendments to the Examples Table

Additional scenarios have been added, including under the headings “Protecting people and safeguarding incidents” and “Other [serious incidents], including criminality”.

Trustees may find it useful to review the updated Examples Table but can be reassured that the underlying principles remain unchanged.

What hasn’t changed?

Between 2019 and 2026, the following remain the same:

• The definition of a serious incident
• The main categories of reportable incident
• Safeguarding reporting requirements
• Financial thresholds (£25,000 for unverified donations; £25,000 or 20% of income for financial losses)
• Guidance on terrorism and extremism
• Data protection and confidentiality provisions.

Practical steps for trustees

The recent updates don’t require trustees to change their approach to serious incident reporting. However, the publication of revised guidance provides a useful opportunity to refresh your understanding.

In particular:

• Review your existing serious incident reporting policy: this should include a clear definition of what constitutes a serious incident for your charity’s size, operations and activities, how incidents will be handled in practice and who is authorised to report on behalf of the trustees as a collective
• Record keeping: keep a clear and detailed paper trail when deciding whether to report a serious incident, particularly when dealing with borderline incidents. Trustees may need to explain their reasoning if they decide not to report an incident and the Commission later becomes involved. Clear records also help identify actions needed to mitigate the risk of incidents of a similar nature recurring
• Reporting: the Commission expects disclosure of serious incidents as soon as is reasonably possible after an incident occurs or is discovered. Reports should be updated if circumstances change or new information comes to light.
• Trustee training: your charity may benefit from focused training sessions on trustees’ core obligations when reporting serious incidents. We can produce bespoke training sessions based on the needs and relative scale of your charity, from basic duties and guidance to interactive sessions with real-world case studies.