Preparing for updated guidance and regulation in the charity sector.
A new academic year often means plenty of new material to understand. The 2025-2026 academic year is going to be no exception, with sector wide covenants, updated guidance and new regulation. For academy trusts - who balance education responsibilities with both charity and company regulation - now is the time to get to grips with the changes.
Changes in Companies House Regulation
The Economic and Corporate Crime Act 2023 introduced significant changes to Companies House regulation, particularly around the efficiency, transparency and accuracy of data filed with the regulator. Some of the key changes are being brought into force from Autumn 2025:
- directors and people with significant control (PSC) in relation to academy trusts will need to complete digital identity checks;
- there are new criminal offences for giving false information to Companies House, and bigger penalties for missing filing deadlines;
- introducing a new 'failure to prevent fraud' offence, which will apply to larger academy trusts (For our earlier article on this, please see here).
Companies House has also recently confirmed that, on and after 1 April 2027, it will not be possible to file annual accounts via the web or on paper. Accounts must be filed using commercial software. For many academy trusts, this will apply to their accounts for the financial year ended 31 August 2026, given that there is a nine month period to file the accounts. Either the accounts for that financial year will need to be filed in good time, or academy trusts should start making sure that the person responsible for the filing of their annual accounts has access to relevant software.
Code of Fundraising Practice
The Fundraising Regulator has announced that the updated Code of Fundraising Practice will take effect from 1 November 2025. There is currently a transition period up to this date, but afterwards the Fundraising Regulator will hold organisations to the updated standards.
Of particular interest to academy trusts (and 'Friends of..." or Parent/Teacher Associations) may be:
- a stronger focus on being open with donors and stakeholders about how you use funds, and on having clear complaints processes;
- stringent requirements around fundraising involving children
- ethical use of digital platforms, data protection, and keeping online payments safe;
- risk assessments for event fundraising, and ensuring clear communication about the expectations on and from participants in event fundraising; and
- procedures for prize competitions or draws.
Charity Governance Code
The Charity Governance Code, which sets out best practice for charity governance, is currently under review with an updated version anticipated before the end of 2025. Although not a legal requirement, the Code is widely used as a benchmark by regulators, funders, and others, and could help academy trust trustees identify their own areas for improvement, as well as confirming areas of good practice.
It is anticipated the Code will be strengthened in various areas:
- an increased focus on board diversity, equity and inclusion, and making sure a wide range of voices are included and valued;
- additional guidance on considering the environmental and social impact of board decisions, as well as strong governance;
- openness and accountability with stakeholders – which for academy trusts could mean pupils, parents, staff and the local community.
A Civil Society Covenant?
The proposed Civil Society Covenant is a government initiative to improve relationships between charities, public bodies, and local communities. The consultation closed late last year, and the final version of the Covenant is expected to be published over the summer. It is intended to operate as a voluntary framework based on shared values.
There are clear benefits to an academy trust in engaging with any eventual Covenant, and being able to pool knowledge and experience with other local organisations to ensure the impact for the academy trust's charitable beneficiaries (i.e. its pupils) is as great as it can be. This is not to say that the Covenant is expected to be easy – for it to truly work it will require open and honest conversations between all parties.
Wrigleys hosted a series of forums on the Covenant earlier this year. You can read about our findings here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
