Disclosing trustee payments and expenses

A charity preparing accruals accounts must disclose every payment or benefit given to a trustee, naming the trustee and stating the amount, the reason and the legal authority, together with the total of trustee expenses and how many trustees received them. Transactions with people and businesses connected to trustees are disclosed as related party transactions, with names. Where there is nothing to report under any of these headings, the accounts must say so.

Why are trustee payments disclosed so fully?

Being a trustee is generally a voluntary role, and the Charity Commission’s CC11 guidance series warns that external reaction to paying trustees is often negative. Disclosure is how the public sees that any payment was authorised and reasonable. CC11 reminds charities that they may have to name the trustee or connected person paid and what they were paid, and that the accounts become public information.

The legal hook in England and Wales is Schedule 2 to the Charities (Accounts and Reports) Regulations 2008. Paragraph 1(1)(e) requires the notes to give such particulars of transactions with related parties, including those of any subsidiary undertaking, as the SORP requires, and paragraph 1(1)(p) requires particulars of any ex gratia payment. The detail therefore comes from module 9 of the Charities SORP, which deals with trustee and staff remuneration, related party and other transactions. ICAEW’s summary of SORP 2026 says module 9 applies in full to Tier 2 and Tier 3 charities, and to Tier 1 charities using the natural classification except for the total staff costs disclosure.

What counts as a payment or benefit, and what is only an expense?

CC11 explains that paying a trustee means giving financial rewards, such as money, salary or fees, or giving other benefits, such as free use of equipment or property or free access to services people normally pay for. The rules also apply where a company belonging to the charity pays the trustee, and where the payment goes to a person or organisation connected to the trustee.

Expenses are different. The Commission’s guidance on trustee expenses says charities can meet the costs trustees reasonably incur to perform the role, such as travel to meetings, overnight accommodation, food and drink, and carer or childminder costs, and that paying expenses is not a trustee payment or benefit. No Commission approval is needed to pay them. They are still disclosed, but in a separate note.

What must be shown for trustee remuneration and benefits?

ICAEW material on the SORP lists the information to give for each individual trustee who received remuneration or other benefits in the period:

• the legal authority for the payment, such as a clause in the governing document, a court order or authority from the charity regulator;
• the name of the remunerated trustee;
• why the remuneration or other employment benefits were paid;
• the amount of remuneration;
• any pension contributions paid by the charity for the period; and
• the amount of any other benefit, for example termination benefits, private health cover or a vehicle.

The Commission’s accruals accounts template follows the same pattern. Its trustee note asks for each trustee’s name, the legal authority, and amounts split between remuneration, pension contributions, redundancy or loss of office or ex gratia payments, and other benefits, for this year and last year, covering payments by the charity or any institution or company connected with it. Where no trustee was paid, the template requires a statement that none of the trustees has been paid any remuneration or received any other benefits from an employment with the charity or a related entity.

Separately, FRS 102 paragraph 33.7 requires total key management personnel compensation, and ICAEW notes that all charities must disclose the total employee benefits received by trustees and key management personnel for their services. For when a trustee can lawfully be paid at all, see charity trustees’ duties.

How are trustee expenses disclosed?

The Commission’s expenses guidance says charities preparing accruals accounts must either give details of trustee expenses paid or confirm that none were paid, and that charities preparing receipts and payments accounts should give the same information. The template shows what details means in practice:

• the total reimbursed or paid directly, analysed by type, such as travel, subsistence and accommodation, with the prior year figure; and
• the number of trustees who were reimbursed or had expenses paid by the charity.

Expenses the charity pays directly, such as a train ticket booked for a trustee, are included as well as amounts reimbursed.

Which transactions with connected persons must be disclosed?

Section 188 of the Charities Act 2011 defines a connected person. CC11 summarises it as including a trustee’s child, parent, grandchild, grandparent, brother or sister; the spouse or civil partner of a trustee or of any of those relatives; a business partner of any of them; and organisations in which any of them has a controlling or substantial interest. The SORP’s related party definition, as ICAEW describes it, combines charity law, company law and FRS 102, so it also captures anyone who has given real property to the charity, key management personnel and their close family, and anyone with control or significant influence over the charity.

For each related party transaction, ICAEW’s summary of the SORP requirement lists: a description of the relationship and the related party’s interest in the transaction; a description of the transaction; the amounts; balances outstanding at the year end and any provision for doubtful debts; amounts written off in the period; terms and conditions, including security and the form of settlement; guarantees given or received; and the name of the related party. That name requirement goes further than FRS 102 paragraph 33.9. Paragraph 33.13 also forbids stating that transactions were on arm’s length terms unless that can be substantiated. More on the general framework is in related party disclosures.

Does materiality apply?

In practice, no. ICAEW’s guidance states that a transaction involving a trustee or other related party must always be regarded as material regardless of its size. The Commission’s 2019 accounts monitoring review adds that if there were no transactions of each type, that fact must be stated, and that the current SORP extends the nil statement to related party transactions as well as trustee remuneration and expenses. A charity with nothing to report therefore still needs three short statements.

What does a complete disclosure look like?

Illustration only. In the year, a charity paid a trustee’s law firm £4,000 for conveyancing under the statutory power in sections 185 to 186 of the Charities Act 2011, employed another trustee’s spouse as administrator at £24,000, and reimbursed £1,850 of travel to five trustees. No trustee was paid for being a trustee.

Note heading	What it says
Trustee remuneration and benefits	No trustee received remuneration or other benefits from employment with the charity or a related entity
Trustee expenses	£1,850 of travel costs reimbursed to five trustees, with last year’s figure
Related party transactions	The law firm by name, the trustee’s interest as partner, £4,000 for conveyancing, the power used and any balance owed; the administrator by name, the relationship as spouse of the named trustee and salary of £24,000

CC11 guidance on the goods and services power also requires a written agreement, kept for six years, and only a minority of trustees may be paid at any one time, so the auditor or examiner will expect to see both.

What mistakes does the Charity Commission find?

The Commission’s review of 2017 accounts from 262 charities found that full disclosure of related party transactions ranged from 55% of accounts for charities with income of £25,000 to £250,000, to 86% for charities with income of £1 million or more. Common failings were:

• disclosing a trustee’s own transactions but not those of connected persons;
• disclosing trustee and connected person pay but no other related party transactions;
• missing the nil statements altogether.

Of the 77 sets of accounts that fell short, 74 had been audited or independently examined, and none had been reported to the Commission, even though it requires auditors and examiners to report incomplete related party disclosure. Payments through a trading subsidiary are another blind spot: CC11 applies to a subsidiary employing a trustee, and the payment belongs in the disclosure. See also independent examination of charity accounts and the statement of financial activities.

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Related Accountapedia entries

• Key management personnel compensation
• Close family members as related parties
• Directors’ remuneration disclosures
• Accounts for charitable incorporated organisations
• The charity trustees’ annual report
• Disclosing secured liabilities in the accounts
• Disclosing political donations in the accounts

Sources

• GOV.UK: Paying trustees other types of trustee payments
• legislation.gov.uk: SI 2008/629, schedule 2
• ICAEW: Summary of changes
• GOV.UK: Trustee expenses what charities can pay
• ICAEW: Can ndas trump charities disclosure requirements
• GOV.UK: Accruals accounts cc17 sorp frs 102 charity accounting template
• Financial Reporting Council: FRS 102 September 2024 tmKYWO6
• GOV.UK: Paying a trustee or a connected person for providing goods or services
• GOV.UK: Reporting of related party transactions
• GOV.UK: Employing a trustee or connected person

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.