From summer 2025, the regulation of charities in Scotland will be changing. The next tranche of reforms from the Charities (Regulation and Administration) (Scotland) Act 2023 is due to bring in three key measures:
- Trustee details will need to be provided to OSCR, and trustee names will be published;
- Increased criteria for the automatic disqualification of trustees; and
- All charity accounts will be published.
These changes will affect all Scottish charities and any cross-border charities registered with OSCR. As such, charity trustees and senior management will need to be aware of and comply with these new regulations. The key points to note are:
1. Providing trustee details to OSCR and the publication of trustee names
From 30 June 2025, charities will be required to provide detailed information about their trustees, including names, home addresses, email addresses, telephone numbers, dates of birth, and dates of appointment.
These details will be kept and used by OSCR for the purpose of regulation and ease of contact. From the end of 2025, the first and last name of each trustee will also be published on the Scottish Charity Register, with the aim of enhancing transparency and public trust. There will, however, be exemptions for those who can prove that publication of their name is likely to affect the safety or security of any person or premises.
To prepare for this regulatory change, we recommend that charities inform their trustees as soon as practicable, gather the necessary information, and ensure that the people responsible for entering the information have applied for a username and password to access OSCR online.
A new tab called ‘Manage Charity Trustees’ will be available on the OSCR online webpage for adding and amending trustee information.
2. Automatic disqualification
In addition to the existing criteria under the Charities and Trustee Investment (Scotland) Act 2005, new criteria for automatic disqualification will come into effect from 31 August 2025. These will include:
- Conviction of offences under bribery legislation;Conviction under proceeds of crime legislation;
- Conviction for perverting the course of justice;
- A conviction for terrorism or association with a proscribed terrorist group;
- Misconduct or negligence as a public official;
- Disobedience of a order of court; and
- Sexual offences subjection to notification.
The new criteria will also now relate to those undertaking a senior management function for a charity, whether or not this is reflected in their job title and potentially if they are a volunteer.
It will be the responsibility of individuals to check whether they meet any of the criteria for automatic disqualification and OSCR will have limited power to waive automatic qualification.
As we look ahead to the implementation of this change, charities should assess who within their organisation undertakes a senior management function and confirm with those individuals that none of the criteria for automatic disqualification apply.
3. Publication of all charity accounts
From the end of 2025, all charity accounts (regardless of charity size or legal form) will be published in full on the Scottish Charity Register, as OSCR will no longer delete personal information before publication. Accounts will then be visible for five years.
Charities should consider what information to include in their accounts, especially given the new duty to provide trustee details. It is important to evaluate whether it is necessary or appropriate to include details of volunteers or beneficiaries.
This change aims to demonstrate effective financial management and transparency, thereby garnering increased trust from donors and funders. Although many charities may already be publishing unredacted accounts via Companies House (if they are a company limited by guarantee) or on their own website, it is likely smaller charities that will feel this regulatory change the most, and thoughtful forward planning will be required.
Charities should ensure that their accounts can be easily displayed online, with all information being accurate and submitted on time. Using digital or typed signatures rather than handwritten ones and regularly checking trustee details is recommended, as when submitting an online annual return, OSCR will ask you to confirm that the details they hold are correct.
Published 30 June 2025
