Author Archives: Martin Bailey - Partner

About Martin Bailey - Partner

T +44 (0)20 7874 8877

I have particular expertise in the charity and the social business sector, working with organisations in 'The Third Sector' since joining the profession and developing vast knowledge and extensive experience in this time.

Charities are unique and have specialised reporting, compliance, and governance requirements. They require someone with specialist skills and knowledge to support them, allowing them to focus on their important work.

I work with organisations rather than for them, providing support and advice to issues as they arise - whether that be core accounts and audit compliance, VAT and taxation planning, governance issues, risk management, strategic reviews and advice, or designing accounting systems.

And it’s here!

Following the consultation over summer 2025, the new Charities SORP has now been released. SORP 2026 takes effect for accounting periods beginning on or after 1 January 2026.

The new SORP reflects two major changes to UK accounting standards, lease accounting and revenue recognition, as well as other changes in legislation and sector specific stakeholder feedback.

Key changes include:

  • A new three-tier reporting regime based on income, each accompanied by differing levels of disclosure requirements:
    • Tier 1: Charities with income up to £500,000
    • Tier 2: Income between £500,000 and £15 million
    • Tier 3: Income over £15 million
  • Enhanced Trustees’ Annual Report disclosures including:
    • Charities in all tiers must include impact reporting.
    • There is a new sustainability section, with charities in tier 3 now required to report on environmental, governance, and social matters. Those charities in tiers 1 and 2 may choose to do so and are encouraged to consider their stakeholders when deciding whether or not to include such disclosures.
    • Tiers 2 and 3 charities should include an explanation of material legacy income that has been recognised in the accounts but not received.
    • Future plans becomes a requirement for all charities.
    • Any charity that is not holding reserves or has a negative net assets on its balance sheet must explain why it is still operating as a going concern.
  • Additional guidance on income recognition, with the module now split into two separate sections on exchange transactions (e.g. contract income – including the new 5-step revenue recognition model for income from exchange transactions) and non-exchange transactions (e.g. donations and grants). The performance model remains mandatory for grant income recognition.
  • A new module covering provisions, contingent liabilities and assets, including accounting for funding commitments.
  • A new module on lease accounting following the significant changes within FRS10. This new module provides guidance on identifying leases, identifying short-term or low-value leases that may qualify for simplification, and guidance on nominal or peppercorn arrangements.
  • Cash flow statements will no longer be required for charities with income under £15 million, i.e. those in tiers 1 and 3, unless a cash flow statement is still required under FRS102.
  • Clarified guidance on measuring the value of donated heritage assets.
  • Simplification of social investments into one new category where previously such investments were split between programme related investments and mixed motive investments.The SORP also includes an appendix on charity law thresholds (including the audit threshold), and an appendix summarising the changes in the new SORP on a module-by-module basis.

It’s important that all charities review the new SORP carefully as there are some significant changes and the effective implementation date is close.

If you’d like any support in understanding the changes and how they may impact your charity, then please do get in touch.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

If you would like to discuss how this applies to you, we would be delighted to talk to you. Please make contact with the author on the details shown below.

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Transcript

Martin Bailey

[00.00.00]

Hello and welcome. My name is Martin Bailey. I’m a Partner and charity specialist at Goodman Jones LLP, and I’m joined today by Jamie Allen at 4PointZero, Jamie, do you want to introduce 4PointZero?

Jamie Allen

[00.00.10]

Yes. Thanks, Martin. So yes, my name is Jamie. I’m the CEO of 4PointZero. We’re a digital transformation specialist company. We’ve existed for for ten years. Um, set that up as founder, and we’ve grown quite steadily. Um, a little bit more recently, as technology has evolved and it’s become more prevalent, it’s become a little bit easier. Um, but we’re certainly on a good track and really enjoying our journey.

Martin Bailey

[00.00.34]

We’re here today discussing how organisations can plan and implement successful digital transformation projects. And that’s become particularly relevant in recent times. And I know from my own work with working with charities of various sectors and various sizes and income levels over the last few years that the sector has been through some enormous challenges. There was the Covid and the impact on fundraising and operations, and trying to carry out their charitable activities remotely. We’ve been through Cost of Living, which has also added increased pressure onto the services that charities are required to deliver. So it’s become really important recently, while charities are carrying out their fundraising activities that they are aware of their own costs and financial position that can help with their fundraising activities, but also make sure they have a clear, clear understanding of where of the resources that they need. And this is really important that they have an up to date finance system with live data that allows them to understand their current position and make decisions. So, Jamie, in terms of having an accounting and finance system that’s up to date and providing the information needed, it might be that a transformation and process has to be gone through. So what are the benefits of change?

Jamie Allen

[00.01.48]

Yeah. So from a benefits perspective is going to be related to your specific organisation and the challenges that you’re facing. Typically from making any change within a business, you’re going to consider it from the fact it’s going to provide an extra added value, and that you’re going to be paying an appropriate amount that you value that change against. Right. So depending on your organisation and the challenges, it might be that you want to increase fundraising and the ability to be able to report to your fundraisers in a timely manner with accurate data, with appropriate backing is exceptionally important. It might be important from a cost control perspective if you want to implement stricter or more regimented cost controls into your business, or even just nurturing more modern technology techniques that currently don’t exist in your business. So if you really live in a world where people are more mobile, if you need people to be out spending money in a more controlled way, but that facilitates that mobility, there are new techniques such as, you know, prepaid cards that enable you to put in funding limits on people to go out and spend. So. Typically when I will go and meet a customer, a lot of the focus will be on what are your challenges? You tell like, I’m not here to tell you what your problems are. You will you, you will probably feel and know what your problems are, right? And my job is then to facilitate or provide the technology or the processes, or work with the people to to make sure that we’re all engaged in solving the problems that matter to you as a business. Otherwise, you’re not going to obtain the value. And ultimately we’re not going to have a happy ending.

Martin Bailey

[00.03.22]

Absolutely. And do you find that that’s often an easier to solve all problems at once, or can you do things piecemeal?

Jamie Allen

[00.03.30]

Um, it will. There will always be a level which is a minimum viable product, which is you can’t go in and implement something that isn’t going to deliver business as usual activities. That’s the bar. You can’t go below that and you have to have an appropriate project plan and timing and milestones agreed by everyone and also engaged with everyone. Um, from a people perspective, that’s critical, um, to ensure a successful delivery. Um, and that’s typically what we will do when we engage on a project and everyone agrees to it. And we also agree that there is participation at each level of the business.

Martin Bailey

[00.04.06]

You mentioned about about planning and having a timeline and engaging everyone. That’s really important. I think some people see it as well. We get a new piece of kit, we install it, we do the training, that’s it. But that’s not the case. Is it that that involving everybody and planning realistic timelines is key? Yeah.

Jamie Allen

[00.04.23]

I mean, you’ve got to always imagine this from a human perspective, because the biggest variable in any project is not the technology. The technology does what it does. You’ve got to be able to get humans to use the technology or set the technology up to succeed. So the biggest variable in all of this is the people and a common, um, common area that can fall down in this is actually making sure that the people that are going to have the responsibility of using this on an ongoing basis feel supported. You know, it can can often be a one dimensional perspective if if senior leadership are the drivers of change, they’re saying, we want this change. We’re imparting this change on you for that person, the incumbent of that finance system, to feel, you know, that they’ve they’ve been handed a problem that they didn’t ask for. Um, that can be very 50 over 50 in terms of whether that incumbent of the finance system, that head of finance, that finance controller wants to change or they can be quite resistant. Um, so making sure and that’s not just necessarily the financial controller that could be the bookkeeper. That could be at any various levels. So making sure that you’ve got the appropriate touchpoints with the various people with senior leadership involvement is really important to make sure that you’ve that that person feels supported in the fact that they’re going to engage in what is a reasonably seismic change within their within their department.

Martin Bailey

[00.05.51]

Absolutely. The old adage of you only get out of it, what we kind of put in a project is going to be successful. If you have that engagement across the board, and you might find that there’s one small area of somebody inputting a tiny bit of data into a system, and if they haven’t bought in, it can just that ripple effect throughout the year.

Jamie Allen

[00.06.08]

And it’s just also feeling supported. Right. So, you know, if say, something unforeseen happens, something goes wrong in the scoping. You know, not every project goes perfectly. Um, that financial controller doesn’t want to feel that they’re in a position where, let’s say the provider who who is going to be, um, interested in their own perspectives, you know, this didn’t happen or that didn’t happen or we didn’t know about this. What that financial controller, who is now who is going to be ultimately responsible for delivery internally within the organisation, doesn’t want to feel is that they’re going to receive the blame for something that ultimately they probably don’t have a lot of experience of doing. They’re. They’ve never done. They like. Like they’re not qualified to do it. Like it’s the first time for them. Um, and ultimately, you know. They’re getting held responsible for for those, for those for this, even though that they, they don’t have those two items. So it’s very important that, that even through perceived issues, which can often be rather quickly fixed, there can be often a desire to overreact if something doesn’t quite go to plan these these often can be addressed in a short period of time. It’s about everyone working together like it’s a team effort, whether that’s with an external consultant, whether that’s just doing it internally or working with a third party. It’s approaching it, you know, with a good plan, with a little bit of slack, so that if things go wrong, everyone’s still on board. No one’s pointing fingers. And there’s an appropriate support network for the people that are physically doing the project because they’re the most important people.

Martin Bailey

[00.07.52]

Absolutely. That’s key in saying having that, having that support there for the people is key. Um. Generalizing slightly. Accountants don’t necessarily like change, though. Perhaps more. More reserved individuals and the change in technology even over the last 510 years. Accounting packages you could probably count on one hand the number that they were the. Kind of fixed, you know, installed on fixed desktop computers. Now there’s so much cloud based. Packages all interlinking with other systems. It’s rapidly different to systems that they would. Have trained and grown up with.

Jamie Allen

[00.08.23]

Absolutely. I mean I wouldn’t I tried not to put too much. You’re absolutely right. But from a from a bringing people on the journey perspective, it can be a fear. And obviously my goal in this is to reduce fears. So ultimately at the end of all of this we all produce balance sheets. We all do produce panels. They all do debits and credits, right? If an accounting system can’t do that, it isn’t going to be in the market, right. So yes, there are largely I mean, there might be new processes that you want to introduce, like maybe you didn’t do purchase ordering before and that’s new and that needs to be learnt and understood. So yes, if you’re adding something new, but otherwise if you’re just maintaining a status quo, they’re just different buttons. They’re probably a different color. They might be called something slightly different, but ultimately they’re all going to be performing the same tasks because the end goal stays largely the same. It’s then just a case of systematically adding layers. So going back to your question earlier, you don’t have to do everything in one go. You can deploy these things, and in certain circumstances it is sensible to deploy things at certain times. And that’s where you do come up with the minimum viable product, which is you have to be able to facilitate the core operations of a business. Sales, purchases, bank, journals, fats. If you’re VAT registered, those are like your staples, everything else. You don’t try to start from the basis of workarounds. You try to optimize from the beginning, but you have to be realistic in your approach.

Martin Bailey

[00.09.58]

Yeah, and I think for charities, resources can be scarce and the idea of changing everything in one go can be scary, but it also might be cost prohibitive. So understanding at that planning stage, whether you do something piecemeal all in one is key and it comes back to you. I know one of the things you talk about and with clients in the first period in that planning stage is why you’re doing this. What kind of approach do you take in that space?

Jamie Allen

[00.10.25]

Yeah, I mean, ultimately some of that is a sales message, because if we’re not solving a problem, no one’s going to no one’s going to want to pay me any money. But, um, but of course, you’re trying to extract a level of value. Um, and you’re also trying to help people to understand why they’re making the decisions that they’re making. Going back to what you’re talking about for about the number of applications on the market, there are a lot more applications available on the market. They’re all quite good at marketing, and they’re all very sophisticated in their sales methodology as well. Methodology. If I can get my teeth. So. You’ve. You’ve got to find the time to do the R&D on this, but also take it with a little bit of a pinch of salt in terms of they’re all going to do basic accounting. So as far as possible, you want to be looking for an application that does have some level of specialism in your industry. Right. Particularly if you’re slightly bigger, if you’re just, you know, a slightly smaller organisation, then you’ll probably be looking just largely at the market leaders. They won’t have a lot of functionality in there. You can buy apps and add ons now to handle specifics, and that may be cost effective. But if you’re getting to depending on what your strategy is, if your strategy is to grow or you’re quite a big organization, you know, and you’re on that verge where you probably need to be looking at a slightly bigger application, you should consider that, because it might be more cost effective to buy a bigger application than a small one with bolt ons. So there is there is different scenarios depending on the needs to to to find the optimal solution. And that’s that’s all we try to go in and try to talk through with people, to enable them to have the information from someone who is neutral. I don’t have a preference which application you buy or how you do it. I will make it a little bit wary of using the word recommendations, but we will certainly provide opinions on what we know works well and where we’ve seen it work well with other customers, but ultimately. If I put in the wrong application. I have an unhappy customer and that’s the value that I’m providing. So if I’m not providing that value, I’m just there’s no point in me being there. You might as well just go straight to the vendor.

Martin Bailey

[00.12.37]

I’d like to pick up on a point you mentioned about, um, understanding or using systems that are experienced in that sector or are used within, within a sector. Um, and I think in the charity space that’s important. Charities are have the need to split by restricted and unrestricted funds. They’re often reporting back to in particular grant funders, um, so needed to track their income and costs on particular projects, activities, grant funding agreements, etc.. So having that level of analysis in the system is key. The other one, other systems that are for more commercial organisations may not have that level of reporting, even for larger, more sophisticated businesses. So I think that sector sector knowledge within a system, as it is with an advisor as well and human is, is is important.

Jamie Allen

[00.13.20]

Yeah. And it’s also on top of that. You’re absolutely right. It’s only getting more complicated. Right. Whether we like it or not. Finances getting more complicated. So whether it’s, you know, you need to do source and you want something that’s going to do your sort of reporting straight off the bat that is available out there. Um, it might be that you’re looking down the road. And part of your strategy is to look more environmental reporting and ESG stuff that’s coming. So. All of this again, going back to what I was talking about is attributing a value to the items within your strategy, and then how that aligns with what you’re looking to, to do to to buy. Right. Um, based on the journey that you’re looking to go, whether it be a growth or a compliance change or whatever it might be, right. So you can always find workarounds to these kind of things. Like, we’ve all been accountants. We’ve all lived in Excel. There’s often ways to do things. But my experience is there’s often only one right way to do things. And if you’re taking data out of accounting systems, or pulling in data from various data sources to manufacture reporting in Excel, if you’re good at Excel, it may work, but you are taking a risk because you are manufacturing data. You are not working within a process. You are creating your own process. It

Martin Bailey

[00.14.50]

always raises a flag with my audit hat on. When you see people exporting the data into Excel and manipulating it, as is often the phrase used. Um, but in order to get to get, you know, such disclosures or anything else, but it’s data that’s been handled outside of an accounting system. So it just adds that additional level of risk and additional level of input by somebody that may not need to be

Jamie Allen

[00.15.10]

done. Yeah. And this is where it comes becomes even more important to make sure that you factor time elements into your return on investment when you’re also considering things and attributing a value to them. Right. So it’s not just a pure cost exercise. And this is where I think historically the perception around accounting potentially needs adjusting within your organization. And I would actually start there. If you’re looking at making change within a business, what is our perception of finance from the top to the bottom. Because what you’re doing with modern accounting system is you’re actually integrating wider operational pieces of your business. Right. Whether that’s budget holders who have to look after specific areas of the business and maintain their budgets and look at actuals, or whether it’s people who just need to do expenses in a different way, or if it’s senior members, you want to be able to go into the system, interrogate the data. Right. We have more transparent accounting systems, so it touches everyone. So before you start, what is your actual perception of finance at the top of the business? And if you just look at it as a cost. That’s a danger. Because the point of doing this is that you want to extract more value, and you have to be able to attribute a number to that and a return on investment. And that means valuing it like we are giving it value. So you have to value it. Right. If you’re just looking at this in terms of, well, I’m paying this now and I’m going to be paying this more than this because and I’m, you know, but I’m just getting a better finance department. I would say that’s not accurate. If you get the correct finance system and the correct processes and the best way of working, it will make you money, it is actually a profit generating activity. Whether that’s getting better data to make better decisions, whether that’s saving your finance, people’s time like attribute a cost to someone’s time. Like if you’re a finance professional, even if you just do, you know, back of a piece of paper mathematics. Like, what does this person cost me an hour And how much time are we looking to save from them? Performing certain activities, manual activities, normally just from an outlet. What are we going to say in doing that? That’s a tribute of value to that. If we’re saving three hours, a £40, whatever it is, right? That all has to go in. Because if you do this right, it will help you make money.

Martin Bailey

[00.17.45]

Absolutely. And I think the finance team, they partner with everybody else. They, they, they link in with the budget holders, the fundraising team, the people delivering activities because everybody has has those different skills and that different knowledge of different areas. But the finance team can help bring it together. And you’re absolutely right. If they if they have that data and can produce the information in the reports, that can help generate, you know, funding applications and generate income that can help save in costs or deliver things in a different way. So it’s a very good point that it’s often overlooked as being an income generating cost centre.

Jamie Allen

[00.18.21]

Exactly. And if you don’t have that perspective when you’re going into this. You’re not clear on your strategy. So therefore how? When you’re like delegating these activities or getting people to engage on this project and asking people to buy into what is quite a lot of change, if you’re not clear on that as your strategy and how much you value that and how it’s a good thing for a business. Why would anyone else believe in it? Indeed.

Martin Bailey

[00.18.49]

So, you know, kind of getting people to buy into change. We spoke at the beginning about, you know, the benefits of going through the change and the why you do it. But, you know, there are challenges in going through transformation program. So all common challenges do you see?

Jamie Allen

[00.19.04]

Um, engagement, which we’ve talked a lot about that is that is a typical one. Um, as I said before, the biggest variable in all of this is people. Um, and that can be from certainly a change management, which we’ve already talked about, but equally, um, from, from the perspective of learning new skills, um, and trusting the people that you’re going to work with. Like, you know, if I can meet someone tomorrow, I’ve never met me. They’re like, they’re not qualified. They potentially haven’t done this before. You know, they haven’t seen and seen the intricacies of it. It’s it’s what they do day in, day out. They’re placing a fair amount of trust in me. And also you’ve got to be able to help people to understand that their role is being redefined and not being replaced. Right. Because a typical trepidation that we will see from finance systems is, you know, we’re getting this system in a computer, doesn’t care if it’s doing 10 million transactions or one. It’s a machine. It just chugs through it. Right. So we’re going to save all this time. What am I going to do? And I think it’s a key part of this to understand that the role of the finance person doesn’t go away. Quite the opposite. It is just a redeployment or a change of role. And what we see is the change of role becomes more closely linked to an internal audit. That is effectively what you are becoming. You are becoming the owner of the company’s financial data rather than the creator of it. You are the financial control. You are the person that is now in charge of making sure that data is correct, and then someone shows up and wants to understand something, wants to know something. It’s there, you can give it and it’s done. And you’re you’re flexible and you have the ability to, to to work in an agile way, which. You know, being a finance person going back in time. Being an accountant for I don’t know, how long have I been a counselor? For 20 years now. Um, I started. Yeah. So the big changes that someone shows up under, I want this information now. And you’re like, when’s that supposed to happen? You know, like, you’re there because you’re doing a job. You have business as usual activity. Someone comes in when, like, you’re not there to sit and do nothing. If someone comes in with an extra activity, it happens in extra time. Yeah. Like so the perspective of this is that no longer has to go into extra time. You have more transparency, you have more agility, you have more ability to deliver to people the things that they actually want, which is the things that they don’t know. Yeah, right. I would say it’s quite rare that you give a business owner a balance sheet and a PNL and they go, wow, there’s something in there that I didn’t know. Yeah, like there may be bits and pieces, but they’re not going to ever go, okay, wow, that’s hit me. You know, they’re going to have a rough idea. Like most business owners will run their business by their bank account. Not the right way to do it, of course, but by and large, keep it simple. Running a big business or running a business, lots of things to think about. They will run it by their bank account. How much am I going to spend? How much have I got coming in?

Martin Bailey

[00.22.18]

And that’s often similar in the charity space because, you know, often they, you know, they there’s all the talk about reserves, but you know, often, you know, the trustees and the management team are thinking in terms of cash is, well, what cash have we got to fund our activities going through? Um, and I think maybe in the charity space you might find that, that the knowledge at board level around the balance sheets and maybe you do get more surprised within the charity space because you have people on the board from, from various different sectors.

Jamie Allen

[00.22.47]

Yeah, exactly. And they’re not qualified. They’re not finance professionals and nor, you know, it’s not a reasonable expectation for them to understand all the intricacies of it. Right.

Martin Bailey

[00.22.56]

It’s all on the ground day to day. Whereas a business owner is involved in the business. They may have found that they’re involved day to day. Your charity trustees aren’t involved on the day to day basis.

Jamie Allen

[00.23.06]

Exactly. Exactly. So certainly the goal of this is to to be able to to provide value to ultimately the people who are appraising you, you know, in the in the reality of this, at the end of the year, when you sit down and have your appraisal, you’re going to sit down with these people. They want to be able to have that exchange with you as the head of finance and say, you’re giving me everything that I hope for. And that is often actually the tricky stage of going back to what we’re talking about before. Like, what are the the, you know, some of the risks and what are some of the difficulties that we face in this is that. The understanding that. That it’s not. It’s not a personal thing. This it’s a business strategy thing and it’s and it’s a development thing. And typically where it can be difficult for a finance controller as they say. You know, this is a reflection that I’m not doing well enough. It’s not. It’s not a reflection of you as an individual. It’s just the case that there is a change that potentially needs to happen in the business to to enable it to move in a new strategic direction. That will be for the benefit of everyone. And I think that’s that’s the mentality. And going back to engaging with the senior leadership team and the messaging and and all these things is to make sure that there is calm and understanding and a vision of where we’re going in this and an understanding of the people who are doing it, what their role is going to be, and that they’re comfortable with that. Yeah.

Martin Bailey

[00.24.39]

And I think often charities are to an extent maybe a better place than that. The churches are really quite resilient and have to be very adaptable to change. You know, we mentioned at the beginning with Covid, you know, activities all of a sudden being done remotely or fundraising in-person fundraising events, stopping overnight and having to look at new ways to fundraise, new ways to carry out activities. I think the charity sector’s quite used to having to be flexible and adapt to change. But that can feed, you know. That’s absolutely right that that needs to flow down into the into the finance team as well.

 Jamie Allen

[00.25.10]

It’s the setting up for success. I mean, even in the example you’re talking about, all of those things are human things. They’re not like technology as a tool. It is there to facilitate you to be able to do the things that you want to do. Right. Whether whether you’re using a, you know, an accounting piece of software or a car to get you to work quicker, it’s the same analogy, right? You’re just using a piece of technology, whether it’s a car or a finance team, to facilitate the best journey. Right. So. All of these things. These decisions are made by humans, like someone who’s giving you funding. They are making a decision that they trust you to give you that money. Right. And in the same way as a as a person who maybe is running that charity and saying, well, I want this funding, they are trusting you as the incumbent of their finance team to facilitate them to look good in front of this person and say, right, you want that information? We’ve got it bang done. We’re a proper professional outfit. We’ve nailed this. Here it is. Go. Now, isn’t that going to create a much more positive experience for everyone? Absolutely. Then, then oh, let me come back to you and let’s have timely information? Okay. Well, yeah. You know, give me a couple of weeks to go in and, you know, get the spreadsheets out and work it out. It’s, it’s having that that data there. And then it just demonstrates that you understand your organisation, what you’re doing, how you’re funded, how you’re working. It just shows that depth of knowledge there. It’s just making the journey more enjoyable for every single stakeholder. And as I said, going back to before that can only make your business more profitable, particularly in the charity sector when you’re going after funding.

Martin Bailey

[00.26.50]

So, Jamie, we’ve spoken about the people’s side of of transformation projects so far, but there’s also the system side of things and the process side of things as well. So maybe you could just touch on that element.

Jamie Allen

[00.27.02]

Yeah of course. I’m here to talk about digital transformation. So it probably makes a bit of sense to talk specifically about the technology perspective. So um, we’ve spoken a little bit about new entrants to the markets. And there are a few. What I would say is that if you’re looking at the the industry make up, like how it’s structured at the moment, you have SME products, you have this new area which is called the mid-market. They’re all fairly, fairly new in the last few years. And then you have, um, the slightly larger ERP, um, the Oracle’s of this world and SAP’s and so on and so forth. So you have very much a three tiered, um, uh. Set up at the moment in the accounting technology section. So there will be a lot of different theories on this, and it is largely opinion based, but this is from my experience. You can achieve a lot with SME products at the moment, and you use Boltons and apps to be able to achieve those to handle specific problems. And it’s a very, very good way of approaching it depending on your organisation, because what it enables you to do is not buy a product which comes at a particular price, normally quite a high one for a number of modules that you’re not going to use, right? So it gives you a little bit more of this pick and mix, plug and play perspective. Almost like imagine on your mobile phone. Like don’t download every app in the app store. You pick the ones that you want and you you use. You probably have about 50 and use about five of them, but that shouldn’t be the way you don’t need them on your phone. You could be deleting them, right? And it doesn’t often cost you anything, right? But if you are buying a bigger application, you are going to have modules and paying for things potentially that you’re not going to use, right? However, if you are buying five applications, potentially to do one thing, each of those applications is going to have their own margin involved in them. It is potentially going to cost you more money depending on which applications you buy and their pricing mechanism. And you are a lot like if an integration between each of those applications doesn’t work, that’s your problem. Like, you are never going to get two vendors to to to particularly engage with you if there’s an integration issue, because ultimately they’re doing it for free and they’re going to look at it from a commercial perspective. How many users are using this integration? Is it 100 or 100,000? If it’s 100, you’re going to go into a queue and you’re that’s your problem, right? So, you know, that’s just down to the vendors that you’re working with. Working with market leaders. Does that work from a pricing perspective. But if you’re just working with market, it might be that you’re going to spend more money than just going a step up into the mid market applications.

Martin Bailey

[00.29.48]

So a pro of that kind of plug and play approach though is that you said, you know, you might have five things at five different apps that go into it. Four might work really well that you want to keep longer term. Something might happen down the road. You maybe don’t need number five. You need to change it. It’s often a bit simpler than to swap out that one, rather than if you’ve got one system that’s doing everything. It’s harder than to…

Jamie Allen

[00.30.09]

Yeah, I mean, a system is only as good as its weakest part. And I mean, that’s not necessarily true,  but if you’ve got it’s it’s never going to go away. And ultimately if you’re buying a bigger application, you’re doing that because you want the integration problem to go away because they they have to make it work because it’s all under one brand and it’s all one system. So, you know, there is a cost impact to it. But there’s also an ownership of of, of, of issues that goes away, you know. Um, so yes, it’s more interchangeable. Yes, it’s more flexible. It can be more expensive. Um, and it will be down to the individual scenario, whether that is the right way to go or the wrong way to go. What you do find with people, and this is where what I would say, not just from the technology perspective, but from a consultancy perspective, and you will see a lot of people on social media who say you can use zero for any size of customer. Not not a message I would totally agree with. You can get good companies on zero. Often it’s down to transaction volumes. Not not the size of the transaction. Like if you’ve got one transaction that’s like £20 million, that’s not creating a load on your accounting system. It’s like high, high volumes, right of of individual transactions. Can those be batched together to reduce the stress on your accounting system? Possibly as long as it doesn’t damage your reporting perspective. Right. You’ve always got to think of this. What is going to be the next question? If you’re batching transactions together and making your accounting system leaner, you are losing that granularity of information. So if someone comes in and says, don’t like that number, you’ve then got to go somewhere else to find that that out. And that is time and that is cost. So so you’ve got to take an objective perspective to this. Yes, you can go and get a simpler accounting system that may be potentially what a head of finance wants. They like. Not everyone loves complicated. Yeah. All right. So you’ve got to balance out all these different factors and and and approach these things pragmatically from a cost perspective, from an ownership of integration perspectives, which you are going to want if you’re going for an SME product. And even in a mid-market product, if you’re using funding platforms like you might be using some of the donation platforms out there, right? No accounting system is going to do donations. So, you know, always look at what you’re using in your business already operationally and what cannot change. What are the limiting factors in approaching this. And then look for the accounting systems, the niche in your sector preferably, and that have existed as a result of niching in your sector and having a bigger client base in that sector, they should be more willing to build integrations into donation platforms or whatever you’re using to facilitate future success in that sector. Because they are they are more inclined to do something. So it’s about positioning yourself. Um, it’s also about getting the right consultants with experience of putting that product in. Right. You can get generic consultants, but. Why would you? If you can go out and you can find someone who’s put that product in before, and the vendors should help you as well. But I wouldn’t underestimate the value of having someone approaching it from your organization’s perspective with experience, rather than just relying on a vendor, because a vendor will want to approach it from a more off the shelf perspective in terms of they want to have a project plan, which is repetitive across all of their customers because it’s more efficient for them to do so. So as a result of that, they’re going to look for things that are repetitive. So anything that is individual to you from a sales perspective, they will of course say, yes, we will do that to get you to sign a contract. Salespeople will do that. Hopefully they have the integrity to to to communicate that. It’s not as easy as sometimes that they can make out to be. But why? Why? Like always, I would always encourage you to have someone within your organization on a part time basis, potentially, who has experience of putting that product in and can maybe see through some of the sales messages and actually highlight potentially where the complexities are going to be so that those get front-loaded. Because otherwise all that’s going to happen is you’re going to get knee deep into a project and then they’re going to go, we can do it as we said, we can do it. But actually doing it is maybe not so straightforward.

Martin Bailey

[00.35.08]

I think having that independent pair of eyes across it is useful, as you say, a vendor, it might be more likely to say, well, we can make our product work for you in this way, whereas is that actually… 100% right for the organisation in the first place. There might be different solutions, and I think that’s where where you and your team come in. And having that that wider viewpoint across different platforms, different systems, different organisations, you can just draw on that experience from different different areas.

Jamie Allen

[00.35.37]

Exactly. And and it’s you know, the temptation with a lot of vendors can be it’s in the development plan. It’s like, okay, you’re very rarely pinned them to a date. Um, and things may or may not happen. So I would always probably steer away from anything that says it’s part of a development plan. If it’s not there, it’s not there. You can’t. I’ve seen too many promises of functionality over the years to, to to to hold too much weight on that. Right. So if it’s not there, take care that it’s not going to be there for a little while. Right. Um, because these things can change, right? And once you’ve signed, you’ve signed. Right. So. Going back to what we were talking about and where where you’re where your point is. Absolutely, yes. Look at the experience. But what you’ll also find with certainly consultants where we feel that we’re a little bit different. Not not to talk too much about us, but we do multiple vendors. Often you will find that someone just does zero or just does a sage product. They might do two sage products okay, but they are a sage reseller, or they’re a NetSuite reseller or a Microsoft Business Central. So they will do one thing. So it’s a bit like going to buy a car, right? If you’re going into a Honda garage, would you ask them to provide an opinion on every single car that’s on the market? And theirs is definitely the best compared to every other car on the market? Yeah, no, I don’t think they would be able to give an objective opinion, right. So yes, I mean we can’t do every application. And do I know everything about every single application out there? No, it’s impossible. But a lot of the challenges in finance repeats. So procurement is largely the same in one application that does it. That or another. We’re not we’re not completely reinventing the wheel. Right. If you’re posting a journal, it’s largely the same in one accounting application to another. Same with the purchase invoice. Same with scanning. Same with all these things. It’s more about functions than it is about specific ways of doing things. It’s what are the tick box functions that we need and what have we got already in the business that we cannot change, whether it’s funding platform or we collect things via direct debit and we work with PayPal or stripe or whatever it might be, that ain’t going to change because it’s just not on the table. It has too much of an impact on our business. So. Make sure that you’ve got those limiting factors. Make sure you understand the volumes that you’re looking to to go at. Make sure the entire financial system ecosystem is made up, but it is made out and drawn out for you, and you understand it and then present yourself with, I would say, three options, or someone else someone can do it for you. We do it for people. There are other people out there that also do that kind of digital advisory piece. Make an informed decision. Pick the platform that’s right for you. Make sure that you’ve resourced it internally correctly with someone, hopefully with a bit of experience. Make sure you’ve got a good project plan that has a certain amount of slack. Don’t make sure people are going on holiday. You know when the sun’s out or it’s a Christmas. Do it at a sensible time. Don’t necessarily focus on year end, although it can help. Um, but modern one file systems can work around year ends. Um, you know, is January necessarily the right time to be doing a finance transformation project or, I mean, with some of the charities they have year ends in like April or August with an education centre? Yeah. Are people going to want to do it in September when they come straight back? Ask yourself those questions maybe. Right. Um. But certainly. Getting the technology right. Make sure you’ve taken those three options. Consider it from a human perspective as well. So some products completely configurable. Turn on turn off. Don’t need a lot of sophistication to run those. Just need to make sure the integrations work. Mid-market you’ll have less integrations, bigger systems, a lot more configurable. You will need someone with a decent level of technology skill to maintain those applications. Um, they’re not so straightforward. There’s a lot of buttons you need to understand them. There is what I would say half way to being what we’ve historically, historically called a systems accountant. You’re about halfway. So you’ve got to have someone in your business who can manage that. If you’re going full ERP, if you need to. And and I would say with the mid-market applications, there is less need to because those mid-market ones weren’t around. So accounts like you illicit x ledger sage intact. They are the new cloud mid-market offerings. They’ve all sort of appeared in the last five, ten years I would say. So. Pick which one you like. Make. Make sure you get what you want. Above that, you may go and get Microsoft Business Central or Oracle NetSuite in particular for a similar price point to the mid-market ones. But what they won’t tell you is if they do updates because you can code in it, you are responsible for those updates. So if they do an update and it messes around with some of your coding, is your problem. Okay. Which is where the cost comes in with the LP is you often need a full time systems accountant, and that it’s not actually the technology that costs you with a big ERP, it’s the sophisticated humans to manage it for you. So just understand the decision that you’re making from a technology perspective. Okay.

Martin Bailey

[00.41.31]

Fascinating stuff. I think the the key bits for me of all of this is make sure you have that project plan. So make sure you understand what you want. Want to get out of out of it. Make sure you’re engaging with everybody in the business, making sure you’ve got somebody kind of overseeing the project that hopefully has some knowledge internally of implementation. But getting that buy in from the different, the different people within it. And I think the third thing is just making sure that you’ve got that system and you pick the right system there to do it.

So thank you very much, Jamie. That was a fascinating discussion around digital transformation projects. I hope you found that useful. And if you are thinking of undertaking a digital transformation project yourself, and please do get in touch. Thank you very much.

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SORP 2026 webinar slides

Transcript

So let’s start with the background to why we’re here on this webinar today. So as a reminder, charities must adopt FRS 102, so the financial reporting standard one zero two, which is the prevailing accounting framework within The UK. And the FRS 102 is subject to periodic review by the Financial Reporting Council. And the Charity SORP takes FRS 102 and then applies that specifically for charities. So whenever FRS 102 is updated, the Charity SORP then also must be updated. And charities that prepare accounts on an accruals basis must follow UK GAAP.The micro entity regime and IFRS are not available for charities, and so all charities must follow FRS 102 and the charity SORP. And in terms of timeline, so we’re a couple of years later than initially planned. So the the SORP was due to come out back in 2024. It was the consultation version was published at the March 2025, and the consultation is open until the June 20. The SORP will then be reviewed and revised if needed over the summer.
And in the autumn, October, November time, we are expecting the final version of SORP 2026 to be published following its approval by the FRC. And it will be effective for accounting periods beginning on or after the 01/01/2026. Now early adoption is permitted. I’m not sure how many will early adopt given how close we will get the final version to the effective date, but early adoption is permitted. If you do wish to early adopt the new SORP, then you must also early adopt the new FRS 102.
There are three possible outcomes. The thresholds will remain at their current levels. They will rise in line with the consumer price index with housing, or there’ll be a partial increase. Every financial threshold is being considered as listed here. However, the thresholds that we’ll be focusing on are the ability to prepare receipts and payment accounts, independent examinations, audit, and large charities.
We have a table that shows the three consultations in separate columns. So the first column shows the current up the current thresholds, the second column shows us the inflation increase, and option c shows us the partial increase. The figures in the table show income with the exception of large charities, which relates to total assets. These thresholds are for entities within England and Wales, and it’s important to note that Scottish charities are required to have an order at £500,000 It was announced that the Scottish government were committed to raising the threshold to 1,000,000 to align with England and Wales. However, this was before this consultation all started, so we’re unsure where the the outcome will end up.
There’ll be three separate tiers for the reporting requirements based on the turnover of the charity. Tier one being up to £500,000, tier two being between £500,000 and 15,000,000, and tier three being over 15,000,000. The £15,000,000 threshold aligns with the new small company turnover threshold. However, it’s important to note the difference between within the company size thresholds you have to meet two requirements. Here, it’s just the one.
The tiered system will mean that the concept of large charities will effectively disappear. Tier one charities will be able to use natural classification basis, whereas all other tiers must report on an on an activity basis. The disclosure requirements will be that all tiers must disclose what was required in the lower tiers plus any additional items. Just a reminder that within the SORP there are must, should, and may phrasing within the SORP. Must is mandatory, should is recommended but not required, and may are optional.
There is a balance to be struck between including the appropriate amount of information around material balances and not including additional unnecessary information around non material transactions. The SORP can be quite specific about which items are considered to be material. And that’s really it for tiered reporting. Thank you, Emma. So we’re going to move on to one of the next key updates, within the SORP.

I always think that’s because it’s possibly the most important part of the final financial statements. It’s an opportunity for a charity to tell the story and to explain what’s happened in the financial year, not just the numbers, perhaps putting some meat on the bone. And, where the numbers have the framework, but the report, gives the full story. Now the purpose of the trustees report is to ensure that the charity is accountable to its stakeholders and to communicate in the most helpful way. And the exposure draft or the proposed, changes does this, by using a series of prompt questions such as who are the users of the account, what are the information needs of those users of the report.
And as I say, the trustees, report is one area, of the exposure draft that has seen significant change from the existing, SORP. It’s an area where what we have and it’s interesting because it’s an area where what we’ve seen, under the current SORP that’s required, of larger charities is now being proposed, to apply to all charities, and they all we will see this a fair bit throughout, and not just the trustees report, but the rest of the, the rest of the changes. So the significant changes, as I put up there, the the five main ones are impact reporting, sustainability reporting, use of volunteers, our friends reserves, and plans for the future. So impact reporting. Now this was, discussed when, for inclusion in the current SORP, but was ultimately not made compulsory there.
But there is now much greater emphasis on charities reporting on the differences that they are making. And, the new SORP proposes that charities in all tiers must explain how their work has benefited society as as a whole. So that’s not just larger charities that, that we’ve seen at present. So how have how have, the char how’s the charity made a difference to the circumstances of its beneficiaries, and has the charity’s work provided any wider benefit, as I say, to society as a whole? The larger charities in tiers two and three have to provide a summary of the measures, or indicators used to assess their performance, and explanations required of the outputs achieved by the charities’ activities, especially when numerical targets have been set.
So, for example, the number of beneficiaries reached or, perhaps a number of events that have taken place. Information on activities, outputs, and outcomes, and how they’ve been, contributed to the achievements of the, charity’s aims and objectives needs to be disclosed. And you need to report on the positive and negative factors, as we do at the moment, that have affected the achievement of the objectives and how this might a few, affect future plans. As I say, this is very familiar to, larger charities, but it’s it’s proposed that this, applies to all. So, tier tier three then have to go on to talk about the performance of material fundraising activities set against, fundraising objectives.
And if the material, if there is a material expenditure incurred to raise that income to explain, how it, how its effect will impact not just this year’s, but also future, future years reporting. Sustainability reporting. I mean, we this reflects society’s increasing awareness of an interest in environmental governance and social issues. And the SORP proposes that, charities in tiers one and two are encouraged to explain how they’re responding to and managing environmental governance and social matters. For example, it might do it by using, KPIs to assess progress against targets, used to manage climate related risks or something like that, and details on how they calculate it.
And in governance, for example, it might include details of social opportunity or or diversity, privacy policies perhaps, or business ethics. And this becomes a must for tier three. Now this is a must for the very, very large charities, but as we’ve seen in, this council, what has been applied to large charities in the past often filters down to the smaller ones. And indeed tier one and two, charities are encouraged to make this disclosure. Volunteers.
Now recurrent SORP requires all charities to disclose a description of the role played by volant volunteers in module six. But the new SORP moves some of this disclosure to the trustees report itself. So that’s all charities disclosing the role played by, volunteers. Tiers two and three, it suggests, should, provide a little bit more detail by providing the number of charities and where practicable, their contribution expressed in terms of full time equivalent hours. Just to note the, existing requirements as set out in module six are still required in the notes.
Reserves. This is an area of interest to many stakeholders and is but is often misunderstood or complicated by the various terms used. Therefore, the news source has updated their glossary in appendix one. And now, as as we’ve seen before, requires all charities to include a reconciliation from the reserves shown in the trustee’s report to those in the accounts. And if there are no reserves held, you need to explain how the charity is still a going concern.
All charities are now required to compare reserves with the reserves policy and explain what steps the charity is taking to bring the amount of reserves into line with the level of reserves identified by the trustees as appropriate given their plans for the future. All charities are also required to identify and explain and, any designated or committed funds and indicate the likely timing of that expenditure. And finally, plans for the future. All charities must now provide a summary of their plans for the future. This has been extended to all charities, whereas it currently is just the larger ones.

So the column split by fund and should include total, subtotals, and reconciliations. Please note that natural classification basis does not remove the disclosure requirements in other module such as trustees remuneration, related party transactions, and key management remunerations. These disclosures are still required. There are some changes to income presentation as well due to the changes in leases, which will be covered in module 10 a little later on. Income from donations and legacies now include grants and donations implicit in the lease arrangement where the charity, a lessee, benefits from a lease term where the lessor made the lease at significantly below market value rates.
Investment income now includes finance income on the net investment in a lease and income from operating leases. Any variable lease payments which are not included in the measurement of the net investments in the finance lease are now included as investment income as well. Other income now includes income from subleasing, right of use assets, and now excludes gains on disposal of programme related investments covered in module 21 a little later on. This is an example per the SORP of the expenditure on tractable activities note layout. As you can see, it now has the activities on a row on rows in on the left and along the top.
Columns are direct are split by direct support and grant funding. This is an alternate suggestion as well, the diagram on the slide currently. And this details where accounting policies can now be put into a column at the end if you choose to do so. This concludes changes to the sofa. Lovely.
And there are the SORP has done this by splitting module five into two sections. Section one looks at exchange transactions, which is, basically contract income, and section two looks at nonexchange transactions, where there haven’t been very many changes, but there is enhanced guidance and explanatory notes within the SORP to help people with their decision making and recognition. So we’re going to focus on looking at the changes brought in, by FRS 102, section 23 on revenue, which establishes a five step revenue recognition model for accounting for contract income. And this very much aligns FRS 102 with IFRS. So the current SORP deals with contract income in just over a page.
The new SORP deals with accounting for contract income in 10 pages. I don’t actually expect that we’ll see too too, many changes in terms of the outcome. I don’t think we’ll see a radically different, figures of with respect to contract income recognition. But the method and the way that we get there and how what we need to demonstrate to show how those amounts have been recognised in accounts has changed. So as mentioned, we now have a five step model.
Step one is to identify the presence of a contract with a third party. Step two is to identify the performance obligations in the contract. Step three is to determine the transaction price. Step four is to allocate the transaction price to the performance obligations in the contract. And step five is to recognise income when or as the charity satisfies the performance obligation.
So in terms of step one, identifying the presence of a contract. So a contract is an exchange transaction. It’s an it’s an exchange arrangement with enforceable rights and obligations on the part of the third part party and on the part of the charity to provide certain goods and or services. And the contract is an agreement between two parties that creates those enforceable rights and obligations. And it’s important to note that a contract can take many forms.
It can be a a full written document. It may be verbal, or it may be in another form such as the listed terms of agreed terms of sale in a shop. So what do we have to look for? So a charity must apply the revenue recognition model to account for contract income when a contract, with a third party and when all of the following criteria met. So the parties to the contract have approved it and are committed to performing their respective obligations.
So the charity will be providing the goods and service, and the third party will be, providing the giving the charity consideration in return. That the charity can identify each party’s rights regarding the goods or services to be transferred, the payment terms for the goods or services, can be identified, that the contract has commercial substance, so I. E. The risk, the timing, the amount of the charity’s future consideration, and future cash flows as a result of entering into the contract, are expected to change. And finally, it’s probable that the third party will have the ability and the intention to pay the consideration to which the charity bill will be entitled when it’s due.
Now it is possible that during the life of a contract, there may be scope to the price or to the nature of the goods or services to be provided. And so then it’s important to review whether that’s a modification to the contract or whether it is a new contract altogether. If it’s a modification, then charity should refer to section 22 reference one zero two for those, for the guidance on that. If it’s a new contract, then you apply the full five step process to that new contract. For it to be a modification, then the increased scope or change of the price of the contract can’t be too too significant.
If they are significant, then it would be considered to be more of a new contract than a modification. The second step is to identify the the performance obligations within a contract. Now for charities that receive performance grants, this is probably not too dissimilar here. And so a charity must identify as a performance obligation each promise to transfer to the customer either a distinct good or service or a distinct bundle of goods or services or a series of goods and services that are substantially the same and that they have the same pattern of transfer to the third party. And it talks there in the in the step about a charity must identify as a performance obligation each promise.
And the SORP patch goes into detail about what is meant by a promise. So it might seem a bit strange to define a promise. But if we remember, a contract may be verbal, so there may not be written down terms and conditions, etcetera, if we have a verbal contract. So in terms of we need to make sure that we’re happy, that there is a promise on both sides around transferring the goods or services and the consideration. And the SORP talks about the promise being a valid expectation that the third party, of the third party that the charity will transfer the goods or services.
Now those promises may be implied. It may be just the charity’s customary practice, or the charity may have published policies or procedures or published terms of sale, etcetera, on its website, to its shop, and its premises, etcetera, that will provide some written backup and allow verification of that promise. Step three is to determine the transaction price. So the transaction price is the amount of consideration to which the charity expects to be entitled in exchange for transferring the goods or services consideration promised in a contract mainly the variable amount, and that variable amount will be the one that’s most likely to be received, and that assessment needs to be made at the beginning of the contract. So if the contract includes any penalties, any performance bonuses, any retrospective rebates, etcetera, perhaps rare for a charity, but not on not impossible, then consideration of the likelihood of those should be done at the beginning of the contract and then throughout the contract period as well.
And if a charity offers payment terms to a third party that defers payment beyond normal business terms or it’s financed by the charity at a rate of interest that’s not market rate, then that arrangement may constitute a financing transaction as well. And so the charity must account for the time value of money and discount the consideration and the amount that of consideration that the charity would expect to receive from the third party. And it’s important to note that if the the charity does have those arrangements, then that interest income that comes on accounting of the time value of money must be shown separately from the value of contract income in the sofa. They can’t be combined together. And a charity doesn’t need to adjust the amount of consideration and reflect the time value of money if it’s expected when the contract begins that the third party will pay for those goods or services within twelve months.
Step four is to allocate the transaction price to the performance obligations in the contract, and the charity must allocate the transaction price to each performance obligation identified in the contract on a stand alone selling price basis unless the contract either only contains one performance obligation, in which case the full transaction price price is allocated to that, or if all the performance obligations in the contract are satisfied at the same point in time. Now if there are no observable stand alone prices, then these must be estimated using a suitable estimation to make, and the SORP then provides three options here. The first one is an adjusted market assessment approach. And this is where the charity evaluates the market in which it sells the goods or the services, and it estimates the price that the third party would pay in that market for those goods or services. Another option is the expected cost plus margin approach.
So a charity would forecast its expected costs of transferring the goods or services to the third party and then add an appropriate margin for doing so. And the final option is the residual approach, and this is only available if the standalone selling price of a good or service is highly variable or uncertain. And then the charity may estimate the selling price by reference to the total transaction price less the sum of any observable or estimated stand alone prices promises promised in the contract. Now the residual approach is is going to be, is considered to be very rare. It’s unlikely to be appropriate.
But if either of the other two, the adjusted market assessment or the expected cost plus, approach didn’t work, then the residual approach would be the one to use. And that would look at something like so for example, if a contract had five performance obligations and you could attribute a standalone selling price to three of them but not the other two, you would take the total transaction price on the contract. You would remove the three standalone prices that you can do, and then you’d use a residual approach to allocate the rest across the two remaining performance obligations. And any discounts in a contract are applied proportionately across all performance obligations unless any of them relate to a performance obligation or if it’s felt that there’s a fairer, method that would provide a fairer presentation of the amounts the charity is recognising in terms of discounts. But, generally, discounts will be recognised proportionately.
And step five is to recognise income when or as the charity has satisfied the performance obligations. So you must recognise income when or as the charity satisfies the performance obligation by transferring the promised goods or services to the third party. And they are transferred when the third party obtains control of those goods or services. And control refers to the ability to direct the use of or obtain substantially all the remaining economic benefits that may flow from that asset. And for each performance obligation identified, a charity must determine at the beginning of the contract whether the performance obligation is satisfied over time or satisfied at a point in time.
So there’s no real change here in step five. It’s looking at recognising and think about the point where substantially all the economic benefits have transferred. So no real change. So those are the the new five steps, within the new revenue recognition model. As I say, I don’t actually expect there to be a radical change in terms of the level of income that charities will record and recognise for their contracts, but the method of getting there and the assessment to get there, is different.
And there’s quite a lot of technical language within there. As I think you’ll have seen, it’s not always the most straightforward language to read and follow and understand. But once you get your head around it and work through, I think we’ll see that there’s no no major changes. One other point just to be aware in terms of exchange transactions is around membership subscriptions. So membership sub subscriptions can be in two two types.
They can be exchange transactions, or they can be nonexchange transactions. A nonexchange transaction being effectively a donation or a gift. But in terms of membership subscriptions that might might be considered an exchange transaction, then the charity needs to identify how it fulfils its performance obligations to the member and how that is linked to the member benefits that are drawn down. So where a charity has membership subs, it needs to look at what benefits or what rights does having that membership give to the member. And then then if that’s considered to be an exchange transaction, then it must follow the five step process that we’ve just been through.
And so it must select, a method that best reflects the situation. And the SORP suggests that one option could be recognising income on a straight line basis. Now recognising income evenly over a period is not, something that’s that the SORP and previous versions of the SORP have have generally allowed previously. And the SORP gives an example here of a membership subscription that allows the holder to visit historic gardens or properties. Now it doesn’t know how often that individual is going to visit, the the sites.
It doesn’t know how many times. And so because all of that is unknown and with the numerous number of members as well, it’s almost impossible for the charity to make that assessment. And so a a fair mechanism here might be to recognise income in a straight line basis over the membership period. Now if those gardens were perhaps only open March until September, it might be that the income is recognised within those periods and not outside of those periods. In terms of the transition arrangements, there are two options here when applying the five step model, in term because that model is applied retrospectively.
So what we have to do is we have to apply it to the previous accounting period, as well so that the comparative figures are present presented, on a fair and consistent basis. But the SORP gives us two options here in f r s one. No. Two gives us two options as well here. So the first one is that the cumulative effect at transition is recognised by adjusting opening reserves.
So in this case, you wouldn’t restate your comparatives. Reserves. So in this case, you wouldn’t restate your comparatives. You would apply the five step model to contracts that have not been completed at the date of transition. And there’s also the option to take advantage of what FRS 102 calls various practical expedients.
And so what does that mean? So it gives you the option to for completed contracts, you don’t need to restate those contracts. For contracts that begin and end within the same annual reporting period, you don’t need to restate those. And any contracts that were completed at the beginning of the earliest period presented don’t need to be restated. So any contracts that were completed before the beginning of the comparative year don’t need to be considered.
For completed contracts that have variable consideration, then the SORP allows you to use the final known transaction price rather than applying judgments at the beginning and trying to use estimates of what you think the transaction price will be when you already know that because the contract is finished. So it allows you to use that completed transaction price. And for contracts that were modified before the date of initial application, but not complete by that date, then an entity need not retrospectively restate the contract for those contract modifications. You can just apply apply the end point as though those modifications all occurred at the beginning. So that’s option one.
We do the restatements, but we just amend opening reserves. Option two is that we restate comparatives as though that policy and that accounting model has always been in place. And we disclose where practicable the amount of adjustment to revenue and to profit and loss for the effect of applying the model. And we give an an explanation of the reasons for any significant changes, or we need to disclose why those that explanation cannot be disclosed, and that’ll be perhaps because it’s not been practical to quantify it. So that wraps up the the slides looking at the change to exchange transactions and contract income.
So grant income must be recognised as follows. So transactions that don’t impose any specified future performance related conditions are recognised in income when the amount is received or receivable. And transactions that do impose future performance related conditions are recognised when those performance conditions have been met. So any resources that are received or receivable before the performance conditions are met, then the liability is recognised, I e, the income is deferred and held in deferred income on the balance sheet. Just so just for clarity.
So for a grant without any performance conditions, it’s likely that when a formal offer of funding has been communicated in writing to the charity, there is then a valid expectation that payment will be made and the income is receivable. So that should be recognised in full at that point even if it is paid in instalments. And the SORP has provided some additional guidance around what are performance conditions and what are not performance conditions or what are conditions that don’t impact recognition. So performance conditions are those conditions that closely specify a level of output or service that is to be performed by a charity. And it’s really important to note that a restriction on the use of a grant or donation to a particular purpose or project does not create a performance related condition.
It makes it restricted funding, but it doesn’t necessarily prevent recognition of the income under the performance related conditions. But there may be some conditions that do prevent recognition. And it may be that the condition that the grant funding is conditional upon receiving planning permission or match funding or some other form of consent from a third party before a charity can receive and and accept that funding. And then we may also see that the donor imposes some times, time periods. So the donor is imposing some time conditions as to when the charity can spend the funds.
Now this can be a very grey area in determining whether these are donor imposed time conditions or just a payment plan of a grant. So let’s say a a third party awards you a hundred thousand pounds a year for three years. We need to assess whether that hundred thousand pounds a year for three years is just a payment plan. If it’s a payment plan, you would recognise all £300,000 upfront with years two and three being in accrued income. Or is the donor specifying that those years two and three payments relate to activities to be done in years two and three, in which case there may be implied time conditions and the charity is not entitled to recognise the funds all upfront and instead recognises on an annual basis.
Now often, the wording in the grant agreements can be quite grey in that area. So it’s worth it’s really worth talking to the donor, just getting clarity in in the documentation to specify that or even asking them to confirm in an email just that that is their intention, that funds relate to future years. Often, what we’ll see is that a charity has submitted an application form that specifies activities to be done in each year for for, say, for three years with a budget allocated and cost allocated across the those activities in the future years. The donor will then say, we’re giving you a grant based on your application. In that case, then the donor is effectively saying, yep.
You applied for money to do these activities in these years. We’re awarding it on that basis, I. E. We are aligning our funding to those future years and imposing time conditions. So it may be there.
It may not be. It is quite a gray area, so it’s worth just making sure that the wording and the agreements, is clear. And the SORP pin, has now provided some enhanced guidance around conditions that do not limit recognition. And in particular, it states that conditions such as submission of accounts, progress reports, or certification of expenditure are considered admin requirements and do not prevent recognition of income. And the sorts really made this clear because most grant, funding agreements will require progress report or update reports to be provided back to the donor.
But often, that’s just that. It’s just a progress report on how you have spent the funds. But the tie so the timing of the related expenditure remains under your control. And so just because the chair the funder has asked for a report on how you spent the funds in year one, doesn’t necessarily mean that you you aren’t entitled to years two and three as well. So for progress report to prevent recognition, it would need to be very clear in the documentation that the future donor would need to confirm in writing that that years two and three have then been released.
And I think if you’ve had if you’ve been paid the second year, beef while you’ve or even before you’ve submitted the report for first year, if you’ve been paid the second year tranche without having that confirmation from the donor, I think that’s highly likely to indicate that there is no substance there behind the donor’s review, that it is just a progress report, and that they are not controlling the timing of the expenditure. So I I think some charities may find that the wording of the agreements here in Fergus reports mean that they are recognising grant income sooner. And finally, just because there’s a repayment condition for any unspent funds, again, that doesn’t prevent recognition. So if you if you apply for funding and you’re expecting to spend the full amount, that full amount should be recognised. You only recognise the liability, for any unspent funds at the point that repayment is is likely to the donor.
But unless there are restrictions attached to that asset, the asset is unrestricted, meaning that the related x the the related depreciation charge is unrestricted. So what the new SORP says is that when you use your capital grant income to acquire an asset, at the point you acquire that asset, the full amount is then transferred out of restricted funds and into unrestricted funds. If you haven’t purchased the asset at the balance sheet date, those funds remain in restricted funds until you purchase the asset. And the swap also states that if you get grant income that is unrestricted, you may wish to set up a designated fund for the asset and charge the depreciation as an expense to the fund rather than doing a transfer. So at the moment, what often happens is a charity receives restricted grant income.
That income sits in restricted funds. And then a tran because the asset is unrestricted, the depreciation goes through as an unrestricted expense, and a transfer happens each year for the amount of the depreciation charge. So that will that will change going forward. And so we’ll just have that full movement into unrestricted funds at the point the asset is purchased. In terms of Gift Aid payments from a a a subsidiary or subsidiaries to the parent charity, and the source just provided some additional guidance here, and it states that income is accrued when a Gift Aid payment is payable to the parent under a legal obligation.
So either being a deed of covenant in place, and a board decision to make a gift date payment to a parent charity that has not been taken before the balance sheet date is not sufficient to create a legal obligation. So if the board decide after the balance sheet date when it knows what the profits and the subsidiary are to make to pay the profits up and there’s no due to covenant in place, you would not recognise that in the accounts. If the board had decided to pay something up before the balance sheet date, then that would be a, transaction that would need to be accrued within the accounts. And then just moving on to legacy income. So there’s no major changes here, but the SORP has provided some verification around certain areas.
And it’s now provided enhanced guidance around receipt of legacy income when it’s considered probable, and it’s considered probable when there has been a grant of probate or a grant of confirmation in Scotland. When the executives have established there are sufficient assets within the estate to pay the legacy, and any conditions attached to the legacy have either been met or within the control of the charity. And the legacy legacy income must only be recognised when it can be measured reliably. And the SOAR pack knowledge is that the value of legacy income may be impacted by various events such as valuations or disputes. And, therefore, those matters need to be considered when determining whether to recognise or disclose as a contingent asset.
So if a charity knew it was to receive a residual legacy that was based on the value of, selling a property, it may not have a value of the property, at the balance sheet date, although there may be no offers on that property. So it may not consider that it can reliably measure the amount, and so it may disclose as a contingent asset. If a charity is made aware of a legacy but has also been made aware that there have been three or four challenges on that on that legacy, on that will, then it may consider that there’s just too much uncertainty at that point in time as to whether they will actually receive anything or not. And so they may not have anything to recognize or potentially even bring in as a contingent asset note. They could, of course, still bring in a disclosure to say they’ve been made aware of a legacy, but that there are challenges on the will, and it’s not possible to quantify anything at this stage.

A related party is a person or entity that is related to the charity, And appendix one gives a full definition, but commonly, it’s referred to a trustee or other person with significant influence and their close family members and those entities which they control. And there was a new requirement to disclose transactions with former related parties if that transaction relates to a time when they were a related party. So an example of this is where a settlement’s made, to a related party after that related party has ceased to be related. And there is one other small change relating to transactions to be disclosed within, related parties. All charities must dis, disclose the total amount of any employee benefits received by trustees and its, key management personnel.
And when calculating it, it must include employers and ice and that’s insurance contributions. That’s not a change. I hear you cry. We’ve been doing that already. In which case, that’s excellent.
So the next is a new module, module 10 a, which looks at provisions, contingent liabilities, and contingent assets. And as I just mentioned, there’s no there’s no major changes here. It’s a new module because all of the content has been taken out of module seven on expenditure and put into a new module. And it was felt it was more appropriate here. One is to group the material into its own module so that module seven doesn’t become too long and unwieldy.
But, also, because it might sit better within the balance each section. So module 10, of the SORP looks at the balance sheet, and it was felt that this might sit, better within that balance sheet section. Again, enhanced guidance, and disclosure help within the SORP around accounting for provisions and funding commitments here. So as I mentioned, no major changes, but there is some guidance around the fact that funding commitments are not recognised as provisions or liabilities. If it’s clear that an offer has been made, but the recipient charity is unlikely to proceed with the project, in which case we would disclose as a contingent liability.
So no change there. But just draw an attention to paragraph 10 a point two three that says, it is important that charities disclose the existence of unrecognised commitments and explain how these will be funded. So that is a that is a must requirement, and it’s just then explaining how those commitments will be funded. And module 10 a also provides some further help around onerous contracts. So if a charity does have a have a contract that is onerous, then it measures and recognises the present obligation, under the contract as a provision.
If the contract is considered to be onerous, I. E. You will cost more than the consideration you will receive in return. And the SORP gives the guidance that the that the amount to be recognised is the lower the cost of fulfilling it, or any compensation or penalties arising from the failure to fulfil it. And then we’re next going to move on to lease accounting, and this is probably the biggest change that’s likely to impact charities.
Again, it’s a new module, and, again, it sits within, a sub module of module 10 on the balance sheet. So this is module 10 b on lease accounting. So where we had some changes in terms of the tiered reporting, we had some changes to the trustees report disclosures, and we had the the contract income change. While some of those may may be new to charities, some may not be an actually the the contract income one. Whilst it feels like there might be significant changes, we’re not expecting there to be.
So lease accounting is going to be a big change for charities. The consultation doesn’t, can’t consult on whether or not to bring in these changes because FRS 102 has brought them in. So the SORP doesn’t have any choice in whether whether to adopt these changes or not. It is required to do so because these changes have been brought into FRS 102. And the changes are a bit like the contract income five step model.
It’s more to align FRS 102 with IFRS going forward. So this module applies to all charities, and it covers accounting treatment and the disclosure requirements, as well. And I’m going to talk about it from the lessee point of view rather than from the lessor point of view. So it’s likely most likely that charities will be lessees. They will be leasing assets.
It’s perhaps less likely they will be lessors, although they may sublet parts property. But we’re going to focus the the attention in this webinar on the treatment for lessees. And the main point to note or one of the main points to note is that there’s no longer a distinction between finance leases and operating leases. The lessees, there is for lessors, but not for lessees. So under this new approach, the lessee recognises at the beginning of a lease an asset and a liability with part of the consideration being paid to the to the lessor being treated as a cost of financing the arrangement.
So let’s say you have a you lease a property on a ten year lease. At the moment, you have an annual rent charge. Going forward, you won’t have an annual rent charge. You’ll have an annual depreciation or amortisation charge and an interest cost of the finance element. You’ll have an asset on your balance sheet, and you’ll have a corresponding liability on your balance sheet as well.
So we’re going to see some quite big change. You’ll potentially see some quite big changes of increases in asset values. And if we think back to the slides that Emma talked about earlier in terms of the size limits for charities, those size limits are based on balance sheet totals based on gross assets. So if you’re bringing an asset onto the balance sheet for a leased asset, that will be adding to your balance sheet total. You don’t make any allowance for the for the related liability, so we could have higher balance sheet totals.
And as Emma mentioned, it’s perhaps not unreasonable that a charity might have, with these enhanced rules, more than 7 and a half million of of assets, more than 50 employees, and therefore not be a small entity for for company law and become a medium sized company and all the additional disclosures that that may bring around strategic reports, cash flow statements, etcetera. So what do we do first? Well, perhaps, the first thing that we do is try and find a way out of doing lease accounting. And so, helpfully, there are two exemptions that are available for us. The first one is looking for any short term leases.
So these are leases that are twelve months or less. And then we look for low value assets, and the FRS gives examples of personal computers, tablet devices, telephones, and other small items of office furniture. It’s important to note that neither FRS 102 nor the SORP gives a monetary value here. So it doesn’t give a diminimus level, in terms of what is considered to be a low value asset. It gives examples of the types of things that would be considered.
I think one of the most common ones here might be printers and things like that, photocopies that that charities lease. They are probably considered to be fairly low value, but it’s where it doesn’t have a de minimus, so you need to assess the value of the item, and the nature of the item as well. So if you are able to take advantage of those exemptions and in and indeed do do so, then you need to disclose the fact that those exemptions or one either of those exemptions has been taken. And then you must also separately disclose the amount of lease commitments for short term assets and low value assets at the balance sheet date analysed between commitments due within one year And then for low value assets, I’d amounts due between one and five years and then over five years. So that’s very similar to the current operating lease commitment note.
So if you do have low value assets that don’t fall under the lease accounting rules, you still need the disclosure that’s very similar to the operating lease disclosure currently. So if we’ve ruled out whether anything counts as a short term, asset or a low value asset, we then need to determine whether or not it is a lease. So if the exemptions aren’t available, we need to look at whether the agreement for the use of that asset will qualify as a lease. So a lease is a contract or part of a contract. And for a contract to be a lease, then the bullet points on the slide must apply.
So there needs to be identified asset. The contract, must specifically identify the assets or the asset must be implicit when it’s made available for use by the by the lessor. The agreement gives the lessee the right to control the use of the asset, and the agreement does this when the lessee has both the right to direct the use of the asset and obtain substantially all of the economic benefit from the use of the asset. There’ll be a commencement date. There’ll be a period over which the lessee has the right to control and use the assets.
And the SORP does say that that can be viewed in terms of time. So it could be you you know, you’d lease a or commonly, you would lease a an asset for a period of time. Or it may be in terms of the amount of use. So if you lease a a machine that can produce a certain number of units, then it may be that that’s the that’s the basis on which you determine the term of a lease. And there must also be payments due by the lessee to the lessor for the right of control of the asset.
So none of that is perhaps different to what we’re used to. The the language may seem quite formal and legal and technical, but it’s no different. So at the moment, really, to looking at whether there is agreement in place, there is an asset, there are payments going around, in return for the use of the asset, etcetera. Now the SORP goes into quite a lot of guidance on each of those bullet points. And there’s actually there’s there’s a lot of guidance within the SORP of lease accounting, and I think that’s because it is new.
And the SORP is trying to provide as much help as possible. For me, I think one of the issues is that the language is not the most user friendly. It’s not the most accessible of language, and there could perhaps be a few more examples within the SWAP, to help charities and. There are some that could perhaps be a few more. But it does go into quite a lot of information and guidance to try and help charities when they’re carrying out their reviews of assets and leases and whether they fall under, lease accounting.
So the SORP has quite a lot of guidance within there. Just to pick up on a couple of bits. So in terms of being able to identify an asset, so an an asset can be separately identified and that the supplier doesn’t have a substantive right to substitute the asset during the lease term. And in terms of having control of the asset, the SORP again gives quite a lot of detail and also gives a few examples in terms of having a right to use a vehicle when leased or to use a building to carry out its activities or to rent out to other parties to generate a economic benefit. Again, they seem fairly fairly common sense, and standard examples that we’re used to.
In terms of commencement date and lease periods, we need to consider any rent free periods and any noncancelable periods as well when looking at what the commencement date is and what the lease term is. And in respect to the lease term, we need to consider, excuse me, if there are any break clauses. And we also need to make a judgment as to whether it’s reasonably certain or not that those break clauses will or will not be exercised. So as an example, let’s say that the charity leases a building for twenty five years and there are break break clauses at ten years and twenty years. So at the point of inception when recognising this for the first time, you need to make an assessment as to whether it’s likely you’ll break it to ten years or break it to twenty or neither.
Just run the full lease term. So if if it’s considered that the charity won’t break the lease clause at ten years, but may is likely to break the lease clause at twenty years, then the lease term becomes twenty years for accounting purposes even though you’ve signed up to a twenty five year lease. If, however, it was only the landlord that could break, had had the right to exercise the break clauses, then the charity would need to exercise, a lease term of the full twenty five years. And finally, you also need to consider whether there are any non-lease elements. If if you sign the lease that comes with an additional service charge element or there are some other other components that form part of this, then they need to be split out between the lease and the non lease elements.
So if we’ve been through all of those, bullet points and we’ve determined that the short value the short term asset exemption doesn’t apply and the low value asset exemption doesn’t apply. We’ve been through those bullet points, and we’ve considered that that out of that, we don’t have a lease. Then it’s considered that the payments are treated as an expense over an appropriate basis over the terms of the arrangements, I. E. You have an annual or monthly rental charge that goes through your accounts.
But only if those bullet points on the slide don’t exist and therefore you don’t have a lease, which I think is unlikely. So then we move on to the initial recognition. So firstly, we have to measure the the right of use asset at cost. And the SORP uses the term right of use assets, excuse me, kind of throughout the module. And, again, it it’s it doesn’t mean that it’s, overcomplicating anything.
All it means is that in terms of having a lease, the charity must have the right to use that asset and gain the economic benefit from it. So it uses the the phrase right of use asset, but but I think we can just refer to it as being the the leased asset or the or the asset. So it has to measure that that asset at cost, has to measure the lease liability, and also identify the interest element of the lease. And when you calculate the cost, you need to make that initial measurement of the lease liability when entering the lease. You adjust it for any lease payments made or before the commencement date less any lease incentives received.
And those lease incentives may include cost of agreed enhancements or improvements that are undertaken by the charity as lessee where those costs are assumed by the lessor. You deduct any initial you need to consider any initial direct costs that are incurred by the lessee in taking up the lease, so you may have some legal charges or something like that, and make an allowance for any expected dilapidation or other similar costs of making good, the asset to return it in an agreed condition at the end of the lease term. And finally, you would just for for any nonexchange transaction component that sits within the lease, and we’ll talk about that in a bit more detail shortly. Now when we’re calculating the initial lease liability, what we don’t do is add up the total amount payable to the lessor over the lease term, and that becomes the lease liability. Instead, what we need to do is we need to take account of the time value of money and discount the total amount payable to the lessor over the lease term, and we need to do that using an interest rate.
Now the default position is to use the rate that’s implicit in the lease. And it may be that the lessor is willing to disclose the discount rate, that’s using or the interest rate that’s being charged. Otherwise, if we can’t calculate the rate that’s implicit within the lease, then we would use the charity’s incremental borrowing rate, which is the rates to of interest a lessee would have to pay to borrow over a similar term and with similar security, the funds necessary to obtain an asset of a similar value to the right of use asset in a similar economic environment. So that’s option one. If that doesn’t work, then you move on to the charity’s obtainable borrowing rate, and that is the rate of interest that the charity would have to borrow over a similar term to the total undiscounted value of the lease payments that are included in the measurements of the lease liability.
And if the obtainable borrowing rate can’t be determined, then the last resort option effectively is that you use the rate of interest that you, the charity, would get if you had funds held on deposits. So, effectively, your your income interest rate. Now it’s considered that being able to calculate the rate implicit in the lease is probably going to be most common and should be able to be used in the vast majority of lease cases. And there is an IRR function within Excel, to enable a charity to calculate the value of the the rate that’s implicit within the lease. You can easily quite straightforwardly build a model within Excel that looks at the timing of the payments, the initial cost of the asset, the annual, monthly, quarterly payments, and then use those total payments to calculate the the rate of return.
And lease liabilities must be shown as a separate line on the balance sheet going forward. So they will be held separately on the balance sheet. Now one thing that’s very common for charities or quite common for charities is where there are leases be held below market rate or for nominal amounts. Now those leases are not viewed as having commercial substance or the lease is not intended to generate an a commercial return to the lessor. Instead, those lease arrangements are serving a social purpose.
They’re allowing the charity to further its charitable aims. So if there are nominal or what’s commonly known as peppercorn arrangements, then it may have the legal form of a lease. But if there’s very small or no payment due, it’s unlikely to be a lease in accordance with FRS 102. So you won’t bring that in onto the balance sheet as a leased asset or with a lease liability if you have nominal or Peppercorn arrangements. Instead, those payments of the Peppercorn will be treated as an operating expense.
But what you then need to do is consider whether that the fact that you are paying a, use of an asset at a nominal rate, so below market rate or not at all, is does that count as a donated asset, service, or facility? And that’s where we would need to consider module six, which looks at donated goods or services, and whether we need to bring in to the accounts an amount that reflects the the gift effectively, of being able to use an asset, free of charge or at a nominal below market rate. So if there’s a market a market value of the, lease and we pay the charity is paying not paying anything towards it or paying much less than that, then that potentially is a donated good or service that should be recognised with an income and expenditure within that. And the swap also talks here about being mindful to consider whether any restrictions imposed on the use of an asset, may and that may result in payments being below, market rates or payments are low on nominal amounts actually mean that those low payments are in effect market rate. And the SORP gives, an example of restricting the use of space to a particular faith group where the restrictions mean that only a nominal amount is paid.
And in effect, that is the market rate because no other faith groups or other groups could use that space. And leading on from that, the the SORP talks about social donation leases. So a social donation lease is an arrangement where the payments are below market rate but higher than a nominal rate. So we’ve got somewhere in between our normal rate and our nominal peppercorn rates, And this is what’s known as a social donation lease. And this is as a result of the lessor deciding to accept lower rent and returning for providing the asset to the charity so that it can use it for its charitable purposes.
So the lessor is is, providing some philanthropic benefits as well as the use of an asset. And so as such, those leases will often contain a nonexchange component, and that nonexchange component is recognised as part of the cost of the asset and then also in income. So, for example, let’s say that a lessor offers a charity a discount on rent as part of its social responsibility activities. So the normal market rent, is £72,000 a year, but the charity is only paying £60,000. And the £12,000 difference is then the nonexchange element, and that is usually recognised in income at the commencement of the lease.
And there are quite a lot of disclosures that need to be brought into accounts as a result of the lease accounting changes. So firstly, all charities must disclose a general description of their significant leasing arrangements, needs to disclose information about future cash outflows to which the lessee is potentially exposed that are not reflected in the measurement of the lease liabilities, and that includes any variable lease payments, any extension options, any termination options, any residual value guarantees, or leases not yet commenced to which the lessee is committed. It needs to provide information about any restrictions or covenants that are imposed by leases. It needs to give information about the types of discount rate. So the rate in interest rate that’s implicit in the lease or whether it’s used the incremental borrowing or the obtainable borrowing rate or whether none of those have been determined, the rate of interest that it would have held on deposits.
So, effectively, it needs to disclose the interest rate it’s used in discounting the present value of the lease commitments. And if there are any sale and leaseback transactions, then they need to be included, in the usual disclosures that are required, with respect to those transactions. All charities must also disclose the interest expense on lease liabilities. It must disclose expense relating to short term leases if it’s if you are able to apply that relevant exemption. With the, except for any expense relating to leases with a term of one month or less, Sure.
If you’d take a lease out for a month or less, but, you do get exempt from disclosing that if so. You need to disclose the expense relating to leases of low value assets if you’re applying the relevant recognition exemption for low value assets. You need to disclose expense relating to any variable lease payments that are not included in the lease in calculating the value of the lease liability. Any income from subletting the right of use asset. So if you lease a building and you sublet part of it, you would need to disclose the income that you have received from that sublet, the total cash outflow for leases, and gains or losses arising from any sale and leaseback transactions.
And the disclosures go on. So the charity must also then disclose by underlying class of asset, the carrying value and depreciation at the beginning and end of the period, and a reconciliation of the carrying amount at the beginning and end of the period with respect to additions, disposals, acquisitions through business combinations, revaluations, impairment losses, depreciation, etcetera. So what that effectively is doing, it’s taking your fixed asset table, stripping out anything that you own, and, effectively, you’ll have a fixed asset table for owned assets and a fit a fixed asset table for leased assets as well. So you need to disclose those, fixed assets held, under leases separately as well. And this is the one area where comparatives are not required for these disclosures.
So FRS 102 requires comparatives for pretty much every figure within a set of financial statements, but it doesn’t require disclosure of prior, fixed asset tables as currently. And if you have any social donation leases or Peppercorn arrangements, then you must disclose the general description of the lease term, the remaining term if it’s not a perpetual lease, any restrictions or conditions in respect to the use of the right of use assets, the presence of any reversion clauses. You also need to make sure you’re covering any don’t any disclosures required under module six if you felt that it’s a donated, asset or good or service. If there’s a nonexchange element of a social donation lease, you need to disclose that amount and also disclose if a lease has been modified, but there’s been no change in the discount rate. So that wraps up the changes in lease accounting from, from the lessee side of things.
It feels like a massive change. I I think for some charities, there will not be a change. For some charities, there will be quite a big change. And and buildings in particular is one where we could see with especially if based in in London, we may see the values of those leases and assets being being quite high. And as we’ve just been through over three or four slides there, there’s a significant number of disclosures around leases.

Leases of low value assets and variable lease payments are not included in this measurement of the lease liability. Cash flow from finance activities. Cash payments by a lessee for the principal portion of a lease liability. Previously, this was just finance leases. The other major section is cash flow from investing activities.
There are no big changes to discuss in this section. Moving on to looking at the presentation of exchange rates. There is an increased guidance on including exchange rate movements. This isn’t something new, but it is explicitly stated as a must now. Financial assets and financial liabilities in foreign currencies must be recalculated at the balance sheet date at that rate.
The year end exchange rate movement is what should then be shown separately on the cash flow statement. The note which reconciles net debt now includes obligations under operating leases as well as finance leases. This was previously just finance leases. Supplier finance arrangement. There are some changes in this area, but this isn’t something common.
So we’re not going to dwell on it too much, but it’s something to be aware of if you have supplier finance arrangements. Moving on to heritage assets. This applies to all charities and all tiers. Donated heritage assets to be measured at fair value isn’t something new, but if the fair value cannot be measured reliably at a cost proportionate within the benefits of the user’s financial statements, then the asset should not be recognised on the balance sheet, but it must be disclosed in the notes. In the disclosure, explain why the heritage asset has been recognised on the balance sheet and why the fair value cannot be reliably measured.
Date the significance and the nature of those assets and disclose any information which is helpful in assessing the value of those assets. Ability to not be able to value at fair value is now considered exceptional. The expectation is that the assets will be able to be valued. If heritage assets purchased or acquired by donations are held at valuations, the valuation should be reviewed with sufficient frequency to ensure the valuation is current. Efficient frequency is not defined.
It will depend on the nature of the asset. However, three years is probably a decent period. Disclosures required through heritage assets that are on the balance sheet are as follows. Present heritage assets as a separate class of fixed assets on the balance sheet. Provide an analysis in the notes to the accounts of those classes or groups of heritage assets reported at cost and those reported at valuation, include the valued placed on any heritage assets gifted to the charity in the income from donations and legacies heading in the statement of financial activities and allocate that income to a restricted fund when the use of the asset is restricted.
Recognise any changes in the valuation of heritage assets as a gain or loss on revaluation of fixed assets in the sofa. Recognise any gain on disposal of heritage assets as other income in the sofa, recognise any loss on disposal, depreciation, or impairment of a heritage asset at cost of charitable activities in the sofa, the carrying amount of heritage assets by class or group at the beginning of the reporting period and at the at the reporting date distinguishing between classes or groups of heritage assets recognised at cost and those recognised at valuation at the reporting date. Where assets are recognised at valuation, sufficient information is needed to assist in understanding the valuation being recognised. Information such as date of valuation, method used, whether the method whether they’re carried out by external valuers, and if so, their qualifications and any significance limitations to the valuation. An indication of the nature and scale of heritage assets held, the policy for acquisition, preservation, management, and disposal of heritage assets, including the description of the records maintained by the charity of its collection of heritage assets and information on the extent to which access to assets is permitted, the accounting policies adopted for heritage assets, including details of measurements basis use, disclosure of five year period of transactions covering the cost of acquisition of heritage assets, the value of heritage assets acquired by donation, the carrying amount of heritage assets disposed in the period, and the proceeds received, any impairment recognised in the period, any depreciation or amortisation recognised in the period.
Where heritage assets are held by the charity as lessee as a right of use asset, these must be shown separately within the heritage assets note with the same disclosure as non-leased items. That concludes heritage assets. Thanks, Lauren. Yeah. That’s a that’s a long list of of disclosures that are required around around heritage assets.

Tier one charities are encouraged to do this but there’s no requirement. There is no mention of social investments in FRS one hundred and two and therefore we must rely on the SORP in relation to these. Currently social investments are split between programme related investments and mixed motive investments. The suggested change is to remove the distinction between the two. The SORP 2026 uses the term social investments to describe the class of assets that comprises of investments made for both financial return and to further the investing charities purposes.

Comparatives must be restated on a like for like basis, but, however, there is, a bit of leeway where this is impractical. The definition of a concessionary loan will be aligned with FRS 102 where they are not repayable on demand. A concessionary loan is a loan made to a third party, interest free, or below the prevailing market rate. Charities making or receiving these loans must opt to either initially recognise and measure the loan at the amount received or paid with the carrying amount adjusted in subsequent years to reflect repayments or any accrued interest, or they can apply the charity’s accounting policy for financial instruments. The same accounting policy must be used when measuring these loans for con for once paid and once received.

So, the consultation is valid until the June 20. And if you go to charitysort.org, you’ll find a link on that page that takes you through to the consultation site. That will have the new SORP. It will have the consultation questions. It has a summary documents of the major changes and, obviously, the link there to go and submit your response.

And as we saw earlier, the the tier three fifty million has been aligned with the new income level in the small, company threshold. Whether we agree that the exposure draft sets out the reporting requirements for each tier, whether charities with the largest income threshold should be referred to as tier three charities or tier one charities, and then any additional comments that anyone may have. Section two is on the trustees report, and the trustees report starts with various prompt questions that allows the trustees to develop the annual report. So it’s asking whether those prompt questions are considered helpful. It’s asking whether the requirements for impact reporting for each tier is proportionate, whether the requirements for sustainability reporting for each tier is a port proportionate.

Same for the disclosures of volunteers. Same, same around reserves and whether the explanation of reserves in the glossary is helpful. It also asks whether the requirements for tier one charities to provide a summary of their future plans is considered proportionate. So as Julie mentioned earlier, that that future plans is currently only for large charities, but the the proposes that it will apply to all charities irrespective of size. Whether additional disclosures is in the trustees report on legacies, and treatments of legacies is helpful.

And any other comments on the trustees report? Section three looks at the the sofa and whether the example table is helpful. So as Lara touched on earlier, the slight change looking from activities being in being in the columns now rather than in the rows. Section four is around recognition of income. And does the module explain the five step module in a clear and understandable way?

Not sure. Do you find the module easy to navigate as drafted? And that’s really reflecting the fact that it’s been split into two with exchange and non-exchange transactions. And do you consider the guidance on those transactions to be, appropriate set out in separate module, or should they be in separate sections of the module as it’s currently drafted? Are all the disclosure requirements, listed?

Would it be clearer to set those out within each end of each section rather at the end of the module? So this is more kind of structure of the of the module rather than actually the content there. And then also just some questions around the accounting treatment for legacy income, and whether there’s any further guidance needed and any further questions on, income. Section five looks at looks at lease accounting. So whether the module is considered easy to navigate.

Does the module explain the requirements in a clear and understandable way? Do the does the section, on arrangements that are below market value provide sufficient clarity on how to count for those arrangements, so those nominal or Peppercorn arrangements? Are there any additional disclosure requirements, for charities, that have them, whether those are considered appropriate and any other comments? And I would just add that for question 26, the no response is actually split into four different options here. So the question, is asking whether the module explains the treatment and the requirements in a clear and understandable way.
So you can answer yes. You can answer no opinion. And the no option has been split into, no, you don’t understand the specific section. No. You don’t understand the recognition exemptions.

No. You don’t understand the disclosure requirements. Or no. You don’t understand the time value of money. So it’s just providing some additional breakdown there so it can just gather some further information as to whether any or all of those sections in the in the SORP need to be expanded upon.

Statement section six looks at the statements of cash flows and whether the proposal that only, tier three charities are required to prepare a statement of cash flows, is appropriate. Section seven on total return looks at the, additional disclosures around around the total return, and disclosures are appropriate there in module 20. We didn’t touch on that. That’s, with respect to end total return on on investments. Not there’s no real major changes, in terms of the content there.

Section eight on social investment. So whether it, whether you, the responder, agrees with the with the term the generic term of social investment rather than having programme related to mixed motive investments, Whether the simplification of putting the movements of those gains and losses rather than, as Emma mentioned, within expenditure or or other income is now clearer. And whether there’s any further guidance needed on the treatment of comparative figures and disclosures in that area. Section nine deals with smaller charities, and it’s asking whether, you agree that the drafting structure and proposals in the exposure draft support the needs for smaller charities while also addressing the needs of users of charity reports and accounts. And that’s really getting at where so the SORP takes a think small first approach, and that starts with the tier one charity.

So or disclosure that everybody needs to do, then the additional disclosures that tier two need to do, and then the additional disclosures that tier three charities need to make. So it’s just asking whether that structure, seems the best, structure for the SORP. And, also, whether you agree with the SORP’s decision not to allow the application of section one a of FRS 102. So there are various disclosure exemptions within FRS 102 for small companies. Currently, charities can’t make allowance of those disclosure exemptions.

A common one being at within FRS 102. If you have a parent charity in a subsidiary, in the subsidiary accounts, you can take advantage of of sexual and a disclosures if if you qualify on size not to disclose transactions with, other wholly owned entities within the group. But the parent charity still has to make those disclosures. I don’t see that changing. I I I think that will still be that option to adopt section one a will still be disallowed.

And then finally, section 10 is the capsule question.

I think it’s it’s very important that the SOAP committee, do hear from, charities and from users of accounts. I think, obviously, as, as, charity specialists, auditors, and accountants, we will be, providing our own, feedback and our own opinions. But it’s important that they are informed by, by you, the charities themselves and by users of the accounts, because on a day to day level, you have to provide this information or or use this information. And I think it’s extremely important that those who set the rules do get to hear from you.

So whether you do that yourself, whether you get in contact with us, I would really encourage people to look at those, consultation questions and to to give your own opinions. And, yeah, I just wanted to I just wanted to say I I personally feel that I think it’s really important. Thank definitely, Julian. I I agree with that. It’s, it’s all very well to kinda complain about the rules, but the the the whole purpose of having the consultations is to give people the opportunity to have their have their saying, give their thoughts around it and to and to shape the soap and the disclosures and the treatments there.

So, yeah, really important that everybody, feeds in their response, if they wish to do so. And with that, I’ll say thanks very much to to Julian, to Emma, and to Lara for joining me on today’s webinar. Thank you very much for attending. I hope you found it useful. Thank you very much, and enjoy the rest of your day.

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The long-awaited consultation draft of the new Charities SORP (SORP 2026) has now been released. You can access the full draft here: SORP 2026 Consultation Draft

Some of the key proposed changes include:

  • A new three-tier reporting regime based on income, each accompanied by differing levels of disclosure requirements:
    • Tier 1: Charities with income up to £500,000
    • Tier 2: Income between £500,000 and £15 million
    • Tier 3: Income over £15 million
  • Enhanced Trustees’ Annual Report disclosures, including information on impact, use of volunteers, and sustainability. Charities in tier 3 will be required to report on environmental, governance, and social matters, while those in tiers 1 and 2 are encouraged to do so.
  • Clarified guidance on income, with separate sections on exchange (e.g. contract income – including the new 5-step revenue recognition model for income from exchange transactions) and non-exchange transactions (e.g. donations and grants). The performance model remains mandatory for grant income recognition.
  • New modules covering provisions, contingent liabilities and assets—including accounting for funding commitments—as well as lease accounting.
  • New module on lease accounting following changes within FRS102, including guidance identifying leases, identifying short-term or low-value leases that may qualify for simplification, and guidance on nominal or peppercorn arrangements.
  • Cash flow statements will no longer be required for charities with income under £15 million (unless still required under FRS102).

As always, the detail matters—and with changes of this scale, it’s important for charities to review the proposals carefully.

The consultation remains open until 20 June 2025, providing an opportunity to engage and respond.

If you’d like help understanding how these changes might affect your charity, don’t hesitate to get in touch.

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The financial reporting landscape for charities is undergoing significant changes, with the long awaited new Charities SORP and the updated Financial Reporting Standard (FRS) 102 set to take effect from 1 January 2026. 

These revisions will bring important changes to how charities account for leases, recognise revenue, and report on certain specialised activities. And, as the upcoming Charities SORP will align with these changes, charities need to start preparing now, well ahead of the new SORPs anticipated release in late 2025 (an initial consultation version will be published in early 2025). 

Lease Accounting 

The key change here will be that charities will need to recognise both finance and operating leases on the balance sheet. This means recording both a Right of Use (ROU) asset and a lease liability, eliminating the previous distinction between finance (on-balance sheet) and operating (off-balance sheet) leases. 

 Unfortunately, charities are not eligible for the same exemptions as micro-entities under FRS 105. This means that whilst some short-term leases and leases of low value assets will remain off the balance sheet, charities are likely to see changes to their balance sheets. These changes will be applied by adjusting opening reserves and not by restating comparatives. 

Revenue Recognition 

FRS 102 will also introduce a new five-step model for revenue recognition. Applicable to all contracts with customers, the model outlines the following steps: 

  1. Identifying the contract(s) with a customer. 
  2. Identifying the performance obligations (distinct goods or services) in the contract. 
  3. Determining the transaction price (amount the entity expects to receive). 
  4. Allocating the transaction price to each performance obligation. 
  5. Recognising revenue as the performance obligations are satisfied. 

As a result, charities receiving income under contracts (and possibly under certain grants which have attached performance conditions) may see a shift in when revenue is recognised, potentially altering reported income levels and affecting whether or not the charity is subject to audit. These changes can be applied by restating comparatives or adjusting opening reserves. 

Revisions to Section 34 (Specialised Activities) 

Updates address the recognition and measurement of specific types of income relevant to charities, including: 

  • Heritage assets, such as artworks or historical items. 
  • Non-exchange transactions, including donated goods (e.g., items for charity shops), services, facilities, and legacies. 

The new Charities SORP will provide detailed guidance on how to apply these revisions, offering practical examples and criteria, but if you would like to discuss any of these changes, or have any other questions about financial reporting for charities, please contact Martin Bailey.

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The collapse of several high profile companies, together with an unprecedented series of societal challenges, from the Covid-19 pandemic to the current cost of living crisis, has increased calls for change in the way businesses operate.

From policies aiming to limit carbon emissions to allowing more flexible working, there have been many new initiatives and debates around the way we work and the Better Business Act is one proposal to address some of those issues facing us.

Backed by a coalition of almost 1,200 companies, the Better Business Act is a campaign to amend the Companies Act 2006 to make it a legal obligation for companies to act not only in the interest of shareholders’ profits, but also for their people, the community, and the planet.

“The Better Business Act will transform the way we do business, so that every single company in the UK, whether big or small, takes ownership of its social and environmental impact.”

The coalition argues that section 172 of the Companies Act is unclear as to a business’s responsibility beyond the “Duty to promote the success of the company”. In its current wording it could be interpreted as justifying ruthless profiteering at the expense of the wellbeing of staff, society, and the environment.

Already signed up are companies such as John Lewis, Virgin and Iceland, and with research carried out by the BBA showing that 76% of UK voters and consumers think business should have a legal responsibility for their wider impact, the pressure on more big companies to follow suit looks likely to grow.

This change to the Companies Act would see all companies required to do something that over 700 businesses have already voluntarily done by them becoming B-Corps; certified organisations that ““meet the highest standards of verified social and environment performance, public transparency, and legal accountability to balance profit and purpose”.

 

What would this mean for my business?

The BBA aims to see four key principles reflected in the amended Companies Act.

First, the proposal seeks to align the interests of shareholders with wider society, elevating the cause of societal wellbeing to a legal requirement, alongside company success. To do this requires the second principle: empowered directors with the ability to make holistic assessments and decisions.

Third, the Better Business Act would require this to be a default change that applies to all businesses, large and small and, finally, this must be reflected in reporting.

Therefore, should the Better Business Act be implemented, there would be a noticeable impact on both board-level decision making and strategic reporting. However, despite the act requiring companies to report on “how the company has advanced its stated purpose and in consideration of its key stakeholders, community, and the environment,” established standards of impact assessment do not exist currently.

But having such established standards is not necessarily problematic; after all, assessing impact is something that the charity sector has long been doing, whether through formal impact assessments or via their Annual Report. Perhaps this is an area where the corporate sector can learn from “The Third Sector”.

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The government has issued guidance on the key changes brought about by the Charities Act 2022, that will come into effect in the coming months and years.

Key changes coming up:

Autumn 2022

  • Paying trustees for providing goods to the charity.
  • New powers for trustees regarding moral or ex-gratia payments, or waiving their rights to receive funds (most typically regarding a legacy that may be questionable).
  • Reducing the complexity regarding fundraising appeals that can’t be used for their original purpose.
  • Amending their Royal Charter.
  • Inclusion of charitable companies in the Commission’s scheme-making powers.
  • Automatic corporation trust status for corporate charities where the corporation is a trustee
  • Update the provisions regarding giving public notice to written consents
  • A lighter touch parliamentary process when a charity changes its governing document by parliamentary scheme

Spring 2023:

  • Changes for charities selling, leasing or transferring land.
  • Greater flexibility regarding ‘permanent endowment’ assets .

Autumn 2023

  • Amending governing documents.

SORP

Spring 2023 also sees the beginning of the public consultation on the new SORP which is expected to apply to reporting periods from 1 January 2024.

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One key area that is often overlooked when budgeting and forecasting is scenario planning (or ‘what if?’ analysis) but this has never been more important.

Budgeting is a vital financial management tool: it allows you to track how much has been spent against planned expenditure, it can help to identify potential future issues such as crunch points on cash flow, and it also helps with longer-term planning through forecasting future cash and reserves levels.

The importance of budgeting is heightened in current times, where circumstances are changing on what seems to be a daily basis.

One of the difficulties in making plans, budgets, and strategies at present is the level of change and uncertainty (although after Brexit and now COVID-19, perhaps uncertainty is the ‘new normal’) and so there is a greater need for charities to be nimble and flexible.

Scenario planning example

Scenario planning

Better financial information allows better decision making, and it is therefore important that the decision makers have relevant and accurate information when making those decisions.

Scenario planning allows organisations to make flexible medium and longer-term plans. It allows the Board and senior management to make more informed decisions that are based on an assessment of many and varied situations.

So what is scenario planning? It is making assumptions about the future and seeing what impact these will have on the future of your organisation, what it does, and how it does it.

Tips on the how to do this

If you have never done scenario planning before, this may seem daunting – particularly as it involves making assumptions in a rapidly moving environment. However, the process does not have to be over-complicated:

Firstly, be clear about the uncertainties you are planning for. Start broad (for example income levels or demand for services) and then narrow down (so if we take the income level uncertainty are you considering the loss of a particular funder, a general decrease in public donations, or a fall in commercial trading income?)

It’s important to consider all uncertainties – but assess likelihood and impact of each. I find that this initial stage works well alongside a review of your risk register – you want to make sure that you are factoring in those uncertainties that are most likely and/or carry greater impact. It is these critical uncertainties that you should plan for.

For each critical uncertainty, consider several different scenarios – there’s no right answer for how many to consider, and it will depend on what your charity does and how it is funded. Too many different scenarios for each uncertainty and the analysis may become too unwieldy; too few and you may not be covering every significant possibility.

This stage is where we start to narrow down the uncertainty. Let’s say the critical uncertainty is loss of commercial trading income from a cafe – consider different scenarios such as no trading income for the rest of the current financial year, different levels of capacity, or even wider issues (such as future levels of tourism).

Review and discuss the implications and impact of each scenario. Involve individuals from throughout the organisation – heads of department / project managers or even volunteers may have a clearer idea of different scenarios or impact.

Some final tips

Of course, all of this depends on a strong foundation of accurate and up to date accounting records and financial information. If the accounting records are not maintained regularly, monitoring performance against budget will be less effective and future planning may be impacted as cash and reserve levels are unknown.

Try not to fall into the trap of considering too many uncertainties and too many scenarios for each uncertainty – keep it simple and focused. But remember that there may be various scenarios to model. Scenario planning should not be built around a single factor.

Consider short, medium, and longer-term scenarios – the impact and outcomes may change over time so factor this into your assumptions and into the modelling.

Try to incorporate the scenarios into the modelling so they can be flexed easily – for example, use an Excel model that uses Excel formulae so that as few cells as possible have to be updated.

Photo by Daria Nepriakhina on Unsplash

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Talking to a couple of my charity clients last week highlighted that the impact of the coronavirus (Covid-19) on charities is, as with nearly every individual and every business, ever changing.

Ensuring the health and safety of beneficiaries, volunteers, and staff is of course paramount. But in order to ensure this and ensure that charities can continue to provide their much needed and highly valued services as much as possible, it is essential that organisations continue to operate and be managed efficiently and effectively.

Whilst both charities mentioned above are well run organisations, they have seen an impact on their service delivery (whether through cancellation, postponement, or through changing the way their services are delivered).

Their income is also being affected – especially where income is generated from carrying out its activities, but also from cancellations of fundraising events (as part of social distancing measures) and declines in investment performance.

Income generation is always a key concern for charities – and this is likely to become a greater concern over the coming weeks with bills and wages to pay, and services to provide.

Therefore, here are a few key matters that charities should consider:

Communication – talk to your funders. If you have been awarded funding to carry out a particular project and that project can’t go ahead, or needs to be postponed or changed, speak to the funder about rescheduling or the changes to the project.

The charities that I have advised to do this have found their funders to be very supportive and have confirmed their commitment to the funding even if the activities are delayed.

Speaking to them now, will help to keep them onside and demonstrate that as an organisation you are still focused on what you do, and that you are looking at mid-longer term service delivery, as well as adapting to the current circumstances.

Revisit forecasts and plans – business plans and budgets are not set in stone. They are living documents that should be reviewed and revised as circumstances change.

Review planned activities – can they still go ahead? Are they fully funded? If not, is funding available?

Update forecasts and especially cash flow projections. It may be difficult to predict cash flow over the next few months but doing this as accurately as possible will help to identify pinch points.

Build in ‘what if?’ scenario planning into the revised forecasts – if one project doesn’t go ahead, can the funding be used elsewhere (remember, speak to your funders), or can valuable resources be saved by delaying or cancelling non-essential activities??

Don’t be afraid to say no to income – this may sound strange, but don’t blindly chase and accept income without thoroughly understanding what it is for and where it is coming from. It is essential to stay calm and not make knee-jerk reactions – decisions should be taken after careful and thorough consideration of the circumstances.

Things to consider are:

  • Would accepting this income require us to do new services/activities that we don’t currently provide?
  • If so, are these still in line with our charitable objects?
  • Would we have to adhere to new regulations?
  • Would this require us to incur additional costs?
  • Are there potential reputational risks from working with this funder? Or potential conflicts of interest with other existing funders?

Review your reserves policy – there is both a short and longer-term element to this. In the short-term, reviewing your levels of reserves is an essential part of revising plans and forecasts. Going forward, a full review of the reserves policy is recommended to see whether it is still appropriate, especially if your activities and ways of carrying them out have changed.

Also, don’t be afraid to use reserves in this period – it is why they are held.

One other recommendation is to keep notes of everything that you do differently now for future – this will help with future crisis planning and highlight areas where systems/procedures may need improving. For example, do IT systems need improving to work from home? Would moving to the cloud enable better business continuity? Has this highlighted how reliant an organisation is on particular key members of staff or income streams? Does it show how easily or how difficult it was to change delivery of services and ways of working?

The temptation at present may be to operate on a day-to-day basis, but doing as much planning and preparation as possible, will help you during this time.

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One of the ways in which a company can receive finance is through investment by individuals, frequently through the issue of share capital.

In 2014, the government introduced Social Investment Tax Relief (SITR) with the aim of increasing access for social enterprises to finance by offering tax incentives to individuals who invest in qualifying social enterprises. These are businesses that are run to generate profits but whose missions and objects include social purposes, rather than solely shareholder wealth maximisation.

What is Social Investment Tax Relief?

Individuals can deduct an element of the cost of their investment from their income tax liability in the year in which the investment is made, or carry it back to set against income tax in the previous tax year.

How much is Social Investment Tax Relief?

An individual can claim 30% of the cost of investment against their income tax liability.
An individual can also defer a capital gains tax liability if their chargeable gains are invested in a qualifying social enterprise. The capital gains tax liability then only becomes payable when the social investment is sold or redeemed.

When the social investment is sold, no capital gains tax arises on any gain on the investment itself (but it is worth noting that any dividends or interest received on the investment are subject to income tax).

How long must the investment be held?

The investment must be held for a minimum of 3 years.

Is there a maximum amount of investment?

Individual investors can invest up to £1 million and this can be in more than one social enterprise.

Individual social enterprises can receive €344,827 over 3 years – depending on exchange rates, this is around £300,000. An enterprise can receive a maximum of £1.5m social investment over its lifetime.

What is a qualifying social enterprise?

In order to qualify, there are numerous conditions that an organisation must meet:

1. Use of money

The organisation, or its subsidiary, must use the money for a qualifying trade or for preparing to carry out a qualifying trade (which must start within 2 years of receiving the investment).

A trade must not include such activities as (amongst others): leasing, receiving royalties/licence fees, financial services, dealing in land or financial instruments, agriculture, property development, running a nursing home or residential care, or production of gas/fuel or generation of electricity/heat.

2. Characteristics of organisation

The organisation must not:
• Have more than 250 or more full-time equivalent employees at the time of the investments,
• Be controlled by another company
• Have more than £15million of gross assets immediately prior to the investment
• Have more than £16million of gross assets immediately after the investment

3. After receiving investment

For the 3 years after receiving investment, the organisation cannot:
• Be controlled by another company
• Be quoted on a recognised stock exchange
• Be in a partnership
• Control another company that is not a qualifying subsidiary

How are HMRC notified?

The social enterprise must inform HMRC that the organisation qualifies as a social enterprise, that the investment received is a qualifying investment, and that all necessary conditions have been met.

It is worth noting that the investor is unable to claim the relief until HMRC have received this confirmation from the social enterprise.

Future of SITR

Finally, just a few comments about the future of the scheme. The government has announced a ‘call for evidence’ into the scheme and how it has impacted access to finance for social enterprises. This call for evidence has probably been triggered, at least in part, because take up of SITR has been less than thought.

The latest HMRC statistics show that during 2017/18, 20 social enterprises received £1.4m of investment through SITR. Since its launch in 2014, 80 social enterprises have received investment totalling £6.7m.

As it stands, SITR is due to come to an end on 5 April 2021 – but this may be extended, and/or the rules changed, depending on the outcome of the call for evidence.

Tax Planning

The above comments provide an overview of the key elements of SITR but, as with all things tax, there are likely to be additional conditions or factors to bear in mind.

In addition, this should form part of wider tax planning arrangements to ensure that an individual’s full tax affairs are assessed.

At Goodman Jones, we work closely with organisations and individuals enabling us to understand this from both sides of the fence – so do get in touch with any questions or for advice on claiming SITR.

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The information in this article was correct at the date it was first published.

However it is of a generic nature and cannot constitute advice. Specific advice should be sought before any action taken.

If you would like to discuss how this applies to you, we would be delighted to talk to you. Please make contact with the author on the details shown below.

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