As you may be aware, the Charities (Amendment) Bill 2022 is with the Oireachtas to be passed into legislation. Upon the passing of this bill, this will bring significant changes to the Charities’ Act 2009.

The bill will make Charities SORP (FRS 102) mandatory for organisations who meet certain thresholds.

The proposed thresholds are as follows:

Charities SORP

The updated legislation will apply to all registered charities in Ireland. Please note the following:

  • There is an understanding that the exemption in place regarding educational bodies will remain, however university foundations will no longer be exempt.
  • It is also expected that a charity will be able to prepare in accordance with another industry wide recommended practice e.g. Housing SORP.

The Bill is expected to pass by the end of 2023 with the expected applicable dates to be accounting periods starting 01 January 2025. This will mean mandatory Charities SORP will be applicable for year ends 31 December 2025.

What steps should I take now?

  • As SORP will require two years of comparative figures with the breakdown of figures between restricted / unrestricted, you should ensure that from the 2024 accounting period, the information recorded in the accounts package is posted in line with SORP or presented in the SORP format in charities management accounts. This information will be essential for the annual audit.
  • A working should be prepared to ensure reserves are split between restricted and unrestricted as appropriate.
  • Ensure your current accounts package is adequate for the needs of Charities SORP postings.
  • Attend any webinars available over the coming months hosted to help you become familiar with the legislation and requirements.

While your organisation may be already preparing the financial statements in accordance with Charities SORP, you may need to review available resources to ensure FULL compliance is being met once Charities SORP is introduced.

Please contact Elaine Murphy, Assistant Manager in our Audit & Assurance department if you have any queries regarding the migration to SORP.

Disclaimer: The information contained above is accurate at the time of publication and as the Bill has not been fully published, the information is subject to final changes.

In 2021, all charities registered in Ireland must complete their first annual Compliance Record Form to comply with the Charities Regulatory Authority (CRA) Governance Code (the Code). 

How to demonstrate compliance with the Code

  1. The Code sets out the minimum standards that charity trustees should meet to effectively manage and control their charity.
  2. To demonstrate compliance with the Code, charities must complete the Compliance Record Form and subsequently update the Compliance Record Form every year.
  3. The Code operates on a ‘comply or explain’ basis, meaning that charities must comply with the Code or else explain why they have not done so.
  4. Compliance with each specific standard must be demonstrated as part of the Compliance Record Form. Organisations must record the actions that the charity has taken to meet each standard of the Code and reference the evidence that backs this up. The Compliance Record can also be used to explain why a charity is not in compliance with any particular standard in the Code.

Reporting on compliance with the Code in 2021

Under the Charities Act 2009, every registered charity in Ireland is required to submit an Annual Report to the Charities Regulator within ten months of the charity’s financial year-end. From 2021, charities will be required to submit a declaration in relation to compliance with the Code with their Annual Report.

A charity will be required to determine if:

  1. It does not need to meet the Additional Standards of the Charities Governance Code.
  2. It does need to meet the Additional Standards of the Charities Governance Code.
  3. It has not yet commenced compliance with the Charities Governance Code.

Additional standards of the code are those standards which a charity that is considered “complex” should meet or charities who are not complex but decided to apply the additional standards.

The CRA has not defined what is considered a “complex” charity and the charities trustees of each organisation are best placed to make that decision. Charity trustees can base this decision on indicators such as income streams, number of employees, complexity of activities, working with vulnerable people or operating overseas.

The charity will be required to declare if, at the time of filing its Annual Report, they have:

  1. Complied with all sections of the Charities Governance Code.
  2. Complied with some of the sections of the Charities Governance Code.

Formal adoption of the Code at Board meetings

All charities are expected is to discuss and agree at board meetings how they will meet the standards of the Code and to document their decisions in the minutes. The Compliance Record Form should record the actions taken to meet each standard of the Code and all minutes of meetings relevant to each standard of the Code.


The Charities Regulator will adopt a balanced and proportionate response in relation to any charity which is not in full compliance with the Code in 2021, with an emphasis on understanding common reasons for partial or non-compliance. This will enable the Regulator to identify common reasons for non-compliance and provide further guidance to charities on meeting the standards set out in the Code.

How Crowleys DFK can help

We recognise that completing the Compliance Record Form and ensuring compliance is properly documented is a time-consuming task and the process will be challenging for many organisations. At Crowleys DFK, we can assist you through the process of completing the Compliance Record Form. We have developed a suite of templates for the Compliance Record Form and the various policies and documents needed as evidence of compliance.

For more information and expert advice, contact a member of our Charities & Not-for-Profit team.

Budget 2018 introduced a Charities VAT Compensation Scheme. This will take effect from 1 January 2018 but will be paid one year in arrears i.e. in 2019 charities will be able to reclaim some element of the VAT costs arising in 2018.

Charities will be entitled to a refund of a proportion of their VAT costs based on the level of non-public funding they receive.

For example, where a charity’s gross income for 2018 involves 30% funding from State/EU/international organisations and 70% privately sourced income including fundraising, subscriptions and donations, they may claim 70% of their VAT input costs for the year.

Not eligible for relief under the scheme will be VAT incurred on private non-charity-related expenses; VAT incurred that is subject to an existing VAT refund order and VAT incurred that is otherwise deductible.

From 2018 onwards, charities will need to ensure that their accounting systems are designed to enable them quantify the total VAT cost and the proportion that is eligible for refund.

We would be happy to assist charities with implementing/upgrading their accounting systems to identify VAT costs so they can easily be reclaimed and on how best to structure their activities to ensure they maximise the amount of VAT they can reclaim.

You can view the Department of Finance’s document in full here.

If you would like further information, please contact us.