Who can be an Independent Examiner and how do Trustees choose one?
If your charity's income is over £25,000 but under £1 million (from 30 September 2026 £40,000 and £500,000 respectively), your charity is required to have an Independent Examination, although you may also need or choose to have an audit – check your governing document!
But there are rules around who exactly can do this work.
What does the law say?
The Charities Act 2011 keeps it pretty simple. An independent examiner needs to be:
- An independent person
- Someone you (the trustees) reasonably believe has the right skills and experience
- Able to carry out a competent examination of your accounts
That's the starting point!
Who can actually undertake this work?
This is where it gets more interesting, and it depends on how big your charity is...
For Smaller Charities (Income Under £250,000 increasing to £500,000 from September 2026)
If your charity prepares simple receipts and payments accounts, your independent examiner could be:
- A retired bank manager
- A solicitor
- A local businessperson
- Anyone with good financial understanding and practical experience
If your charity prepares accruals accounts (the more complex ones that follow the Charity SORP), you really need someone with proper accounting knowledge. Consider a tired accountant or better still, one who's currently practicing. Why? Because charity accounting rules have gotten way more complex over the years, and you need someone who really understands them!
Trustees should be aware though that there are Directives from the Charity Commission that the examiner must follow and evidence the work that has been undertaken - regardless of the type of accounts or income level for your charity.
For Larger Charities (Income Over £250,000 increasing to £500,000 from September 2026)
Once your charity income goes above £250,000 (£500,000), the rules get stricter as to who your examiner can be. They MUST be a member of one of these professional accounting bodies:
- Institute of Chartered Accountants in England & Wales (ICAEW)
- Institute of Chartered Accountants of Scotland (ICAS)
- Institute of Chartered Accountants in Ireland (ICAI)
- Association of Chartered Certified Accountants (ACCA)
- Association of Authorised Public Accountants (APA)
- Association of Accounting Technicians (AAT)
- Association of International Accountants (AIA)
- Chartered Institute of Management Accountants (CIMA)
- Institute of Chartered Secretaries and Administrators (ICSA)
- Chartered Institute of Public Finance and Accountancy (CIPFA)
- Fellow of the Association of Charity Independent Examiners (ACIE)
- Institute of Financial Accountants (IFA)
- Certified Public Accountants Association (CPAA)
And they must be allowed by their professional body's rules to undertake independent examinations.
Also, at this level your charity will have to prepare full SORP compliant accounts.
Who CAN’T be your examiner?
This is really important! Your examiner must be independent. That means they can't be:
- Your charity bookkeeper (they can't review their own work!)
- A trustee of your charity
- Someone closely involved in running your charity day-to-day
- A major donor or major beneficiary
- A close family member of any of the above (child, parent, grandchild, grandparent, brother, sister, spouse, civil partner, business partner or employee)
The Charity Commission is very clear on this - the examiner must not be influenced (or appear as if they could be influenced) by the trustees or their connections.
HOWEVER - being a member or supporter of your charity is usually okay! For example, if someone goes to your church but isn't on any committees or involved in decision-making, they could potentially be your examiner (as long as they have the right skills and aren't connected to trustees).
Other important things to know
Cross-Border Charities
If your charity operates in Scotland or Northern Ireland as well as England & Wales, check the rules in all countries! Scotland has slightly different requirements through OSCR (their charity regulator).
Practicing Certificates
If your examiner is a member of a professional body, they need to check if they need a practising certificate to do this work. Different bodies have different rules! You can ask any potential examiner if they have one.
Can they charge a fee?
Of course! 😊 Examiners are absolutely allowed to charge for their work, though some do it voluntarily.
Important to know: If your examiner charges a fee, they're providing an accounting service. This means they need to comply with:
This includes things like reporting suspicious activities to the National Crime Agency. Sounds serious (and it is!) but it's just part of keeping the charity sector safe.
Can they help prepare the accounts as well?
Yes, if the following applies:
- Someone else has maintained the bookkeeping/accounting records (you can’t mark your own work)
- They haven't been involved in day-to-day management or decision making
- The Trustees review and approve the accounts before the Independent Examination is signed off
They can't examine accounts they've been involved in the underlying transactions.
As an example, for our clients where we provide a fully outsourced finance department we will prepare the draft year end accounts, but they will go to another firm for Independent Examination or Audit.
Summary
When choosing your independent examiner, think about:
- Size matters - Different rules for charities above/below different thresholds
- Independence is key - No conflicts of interest
- Skills match the job - Simple R&P accounts vs complex accruals accounts need different levels of expertise
- Professional qualifications - Check the examiner has what's needed for your charity's income level
- Trust your judgment - You're looking for someone who's competent, independent, and has a good understanding charity accounting and regulations, as well as someone you can communicate well with
If you want to find out more, the Charity Commission has detailed guidance (CC31 for trustees and CC32 for examiners) – CC31 is a must read for trustees before they appoint an Independent Examiner.
Need Help?
Choosing the right examiner is an important decision. If you'd like some guidance on what scrutiny your charity needs or help finding the right examiner, just get in touch with us for a conversation.
We are an ACCA practice working solely with charities and non-profit organisations - it's all we do!
Remember - getting this right helps maintain public trust in your charity and keeps you legally compliant.