(Version November 2006)
(View the pdf version (523 kb) of this publication)
The Charity Commission is the independent regulator for charitable activity. This is one of a series of reports that present our case-working experience, supplemented by additional research. Their purpose is to help increase understanding of an issue. They are part of our mission to help charities maximise their impact, comply with their legal obligations, encourage innovation and enhance effectiveness.
This report presents the findings of our research into charities' reserves management and contains ideas you may wish to consider adopting, taking into account your charity's situation.
Charities exist to create a better society and their day-to-day activities are geared towards transforming the lives of their current beneficiaries. But to ensure they can continue to make a positive difference, trustees know that it is essential to plan for the future. In an increasingly complex and changing funding environment, charities need to be able to absorb setbacks and take advantage of change and opportunity. Many provide for this by putting aside some of their current income as a reserve.
Trustees are publicly accountable for their stewardship of charity funds and information about their charities' aims, activities and finances is becoming more in demand and more widely available. There is an increasing emphasis on the need for the sector to sustain and improve the public's trust and confidence in the work of charities generally.
But underlying much public discussion of charity reserves is the belief, rightly or wrongly, that holding back significant amounts rather than spending it on the charity's current beneficiaries is similar to hoarding. This belief is likely to persist unless charities consistently and objectively explain their reserves position.
In 2002 we looked at the extent of charity reserves across the sector and the number of charities with policies for their management1.
We found many examples of best practice in reserves management but identified areas where improvements were needed. For example, many charities were planning for unforeseen circumstances by setting aside funds but were not putting a policy in place for their management.
It is pleasing that our new research has found some improvement in this situation. But more should be done. Charities have a good opportunity, through the reporting and accounting mechanisms in place2, to educate the public about the ways they operate, their successes, and the risks and challenges they face. Transparent reporting can bring about a more informed and beneficial relationship between funders and the charities they support. Charities that do not take up that opportunity leave themselves open to criticism.
This report revisits some areas we looked at last time, presents the findings of new research on charities with medium to very large incomes3 and considers how reserves are currently presented and managed.
The landscape in which charities operate is constantly changing. Since the publication of our last report on charities' reserves4 , we have seen the profile and visibility of the sector increasing. Highlighting charities' potential to deliver public services and promote active citizenship raises people's expectations of accountability and transparency and also of professionalism in their day-to-day activities.
To demonstrate responsible financial management, trustees need to balance the needs of their current and future beneficiaries by identifying the likely challenges and opportunities that the charity may face in the medium - to long - term. They can then set aside, or work towards, a level of income in reserve which can be objectively justified and clearly explained to all stakeholders.
Based on data collected on annual returns from charities with incomes over £10,0005, we are pleased to report that the proportion of charities with a reserves policy has risen from 27% in 2002 to 40%. It is clear that improvements have been made; for example 84% of very large6 charities now have a policy in place, which is an increase from 65% in 2002.
But we found that 28% of charities holding reserves still had no policy in place for their management7. The amount held in reserve unaccounted for by a policy has dropped to £3.6 billion compared with £5.6 billion in 2002, but this still means that assets amounting to around 10% of charities' total annual expenditure are apparently held without being formally justified.
The upward trend we have identified needs to continue so that all charities account responsibly for their reserves levels through a policy.
The Statement of Recommended Practice ('SORP')8 requires trustees to include a statement about their reserves in their annual report. Our definition of 'reserves' in this report is based on that used in SORP9.
Encouragingly, 84% of charities that submitted an Annual Return for 2004 confirmed they publish their reserves policy in the Trustees' Annual Report.
However, improvements are still needed. Routine checks of accounts for SORP-compliance show that very often a charity has a policy but has failed to publish it in their annual report, or, if it is present, a small amount of information is missing which, when added, will ensure full compliance. We urge charities to take steps to improve standards across the sector.
From our sample, we found that charities currently hold reserves totaling £35.5 billion. This compares with £26 billion noted in our earlier research. Very large charities hold the majority (75%) of the sector's total reserves.
While this may look like a major increase in the absolute amounts held since 2002, comparison against the growth of income and expenditure over the same time-period shows that reserves levels have not risen in line with income and expenditure. Medium-sized charities in particular are facing shortfalls in the amount available to them to put aside for the future. This echoes the increased difficulty for charities in attracting funding, reported elsewhere in sector commentary10.
Full compliance with SORP's recommendations on reserves can only help to demonstrate the charity's effective financial management, and make it better able to tell its story and justify its funding.
Our research last time found that many charities with reserves felt they were having difficulty securing funding because of them. Yet many funders we consulted as part of that research reported that they assessed each charity individually and on the merits of the proposed use of the grant, rather than by applying arbitrary rules based on the level of its reserves.
Our casework shows that some charities still believe that funders will penalise them if they have 'large' reserves. However, it is encouraging to report that our research this time found this is only true in a minority of cases. The majority of charities we asked as part of our new research (88%) said they had found that their reserves had not been a barrier to attracting funding. In addition, our casework experience does suggest a growing understanding of why charities need to provide for their future stability. Most funding bodies recognise the important way reserves contribute to a charity's long-term security and when considering an application they would prefer to see evidence of an effective policy for managing the reserves.
In a supplementary survey carried out for this report, 92% of charities said they had no difficulty developing the policy itself. For those having difficulties, this report refers you to various sources of guidance and includes a checklist we hope will help you get a SORP-compliant policy in place.
We were pleased that those with a newly formulated policy in place were very clear and positive about the benefits the process had brought. The majority of respondents (88%) said that having reserves and a policy made their charity more secure and protected it against risks and that donors now regarded the charity as more accountable.
Our research has clearly shown that a charity that plans its reserves in the wider context of a medium- to long-term strategy and tells its story effectively to beneficiaries, funders and the public generally is more likely to operate successfully. It will build the confidence of its beneficiaries, funders and wider stakeholders, therefore making its long-term future more secure.
We hope charities that have still not realised the opportunities and benefits of publishing a well-thought out policy in the Trustees' Annual Report will be encouraged by the messages in this report to act accordingly.
The landscape in which charities operate is constantly changing. Since the publication of our last report on charities' reserves, we have seen the profile and visibility of the sector increasing. Highlighting charities' potential to deliver public services and promote active citizenship increases people's expectations of their accountability, transparency and also professionalism in their day-to-day activities.
The sector itself recognises this and recent sector-led initiatives to drive up standards include the Code of Governance 11, the ImpACT Coalition and the Fundraising Standards Board self-regulatory scheme for fundraising.
The issue of holding, managing and explaining reserves has long been a target for media criticism. The charity that appears to be hoarding large sums of money which could be spent on its current beneficiaries, and the charity brought to the brink of collapse by failing to plan and set aside money for the unexpected, are equally likely to be portrayed in a negative light.
Whether justified or not in individual cases, the perception that one high-profile charity is 'getting it wrong' can damage the reputation of the whole of the sector. It is clear from our research for this report that, across the sector as a whole, there is room for improvement in the ways that charities calculate the level of reserves they need to help secure their long-term future and in how they explain their reasoning to their beneficiaries, funders and wider stakeholders.
Financial management is the lifeblood of any charity. To be most effective, financial management has to be understood and managed holistically by those responsible for the stewardship of the charity's funds.
The sector's Code of Governance makes it clear that “Trustees have and must accept ultimate responsibility for directing the affairs of their organisation, ensuring it is solvent, well-run and delivering the outcomes for which it has been set up”. This, it goes on to say, includes “setting or approving policies, plans and budgets to achieve those objectives, and monitoring performance against them”.
Ensuring a sound policy for managing reserves is included in our Hallmarks publication12, which sets out the standards that an effective charity and its trustees should aspire to. However, our case-working experience shows that problems can arise when trustees treat the development of a reserves policy as a stand-alone task rather than as an essential element of their strategic planning.
During our research we saw many charities simply describing the funds they had left over at the end of the year as reserves. We also saw policies that said the trustees' approach was to keep enough in reserve 'to continue operating'. This neither helps the charity to plan effectively for its future operation nor helps the reader understand the context in which reserves are calculated and held.
The primary measure of a charity's success is not the sheer volume of funds and assets it holds, but its ability to deliver value to its beneficiaries. The majority of charities accept that in the short term they cannot fully meet the challenges in society they are established to address. Therefore they need to decide within a structured framework about reserving money they could otherwise have spent on current beneficiaries. This framework should balance the needs of the current beneficiaries with the challenges and opportunities that the charity may face in the medium to long term.
Brent Mind is a medium-sized charity that was set up in 1974 to provide mental health services to people in Brent, London. The services are varied and include counseling, supported housing, befriending and workshops.
On their Summary Information Return13, the charity explained a difficult and unplanned situation that caused it to incur a large amount of expenditure. These costs did not form part of the normal day-to-day expenses and without suitable planning this additional burden may have put the charity services and staff at risk.
As part of the trustees' strategic planning, they had previously taken into account the risks that might affect the charity; identified funds that might be needed for unexpected costs and put aside reserves specifically to keep the charity's work going if difficulties arose. The trustees knew they needed to protect the charity's ongoing projects so in this instance they were able to use the reserves to safeguard its services..
Fortunately, the situation has now improved for this charity overall. Because the trustees set aside appropriate reserves as part of their wider strategic planning, which allows for possible risks, the charity can move forward confidently.
Charities operate in a changing, uncertain and increasingly complex environment and face growing funding pressures. And with increasing expectations of transparency and accountability on the part of beneficiaries, funders and wider stakeholders, each charity must clearly and objectively justify and explain any reserves it holds to ensure that the charity is not open to criticism of hoarding.
“Our reserves policy explains to funders why we appear to be 'sitting on' a large amount of money.”
- Administrative and Financial Director - Theatre Alibi
Having decided on the appropriate level of reserves and put in place a comprehensive reserves policy to manage them, an efficient charity will publish that policy to explain to interested parties that it has good reason to withhold this money from its current beneficiaries.
The absence of a policy, or having a vague and uninformative policy, will inevitably raise more questions than it answers. With increasing competition for funding and charities' financial documents becoming more available to public scrutiny14, this could make it difficult for the charity to attract new financial support. It could even contribute to an overall decline in public trust and confidence in the charity concerned and perhaps in the charitable sector as a whole.
Often, a charity may hope for a higher level of reserves than it can easily achieve. But the important aspect is for the charity to be able to demonstrate that it would be imprudent or even irresponsible not to hold, or work towards holding, that particular level of funding in reserve.
*Charities' Reserves (CC19) - provides guidance for trustees and staff on how to make decisions about reserves levels in a way that is consistent with the legal requirements for the use of charity income.
*Charity Accounts: The framework (CC61) - sets out the revised charity accounting framework.
*The Hallmarks of an Effective Charity (CC60) - considers the achievements, performance and impact of an effective charity as well as the principles we expect charities and charity trustees to meet. These are overarching principles rather than a list of legal requirements. The publication is mainly aimed at charities with an annual income above the audit threshold, currently £250,000, but recognises that different types and sizes of charities may have different ways of achieving each Hallmark.
Accounting and Reporting by Charities: Statement of Recommended Practice PDF 674kb (revised 2005) - usually referred to as SORP 2005, this includes recommendations and guidance and is supplemented by examples of charity reports and accounts prepared under SORP 2005. Guidance on the preparation of receipts and payments accounts by smaller non-company charities is also available on our website.
Good Governance: A Code for the Voluntary and Community Sector - published by the National Governance Hub (a partnership of organisations working to improve governance of charities and other voluntary and community organisations). The code encourages trustees to set, maintain and regularly review systems of financial and internal controls, which include reserves policies. It is a practical and easy-to-use guide to help charities develop best practice. For smaller charities the Governance Hub has produced Learning to fly: Piloting your local voluntary or community organisation. See www.governancehub.org.uk for further details.
Reserves: overview and Reserves policy for smaller charities are two summary factsheets produced by NCVO, available in the 'ask ncvo' area of its website at www.ncvo-vol.org.uk
The SORP has always required trustees to have a policy that justifies the level of reserves both to donors and to beneficiaries. As a minimum, the policy should contain:
As a matter of best practice, we suggest that trustees should state the level or range of reserves they believe the charity needs; explain how the charity establishes or maintains reserves at the agreed level or range and also explain how the policy will be monitored and reviewed. Where material funds have been designated, the reserves policy should state how much money has been designated and why and, where money is set aside for future spending, when it is likely to be spent.
Our research showed that compliance with these requirements was patchy at best. While the number of charities with a policy is increasing, there is still much room for improvement.
Our analysis presents a more encouraging picture than our earlier research. We found that the proportion of charities with a reserves policy has increased, from 27% in 2002 to 40%. Perhaps not surprisingly, the likelihood of a charity having a reserves policy increases with size: whereas only 31% of medium-sized charities now have a policy in place, this rises to 73% for large and 84% for very large charities, compared with 51% and 65% respectively in 2002. We are pleased with this improvement.
When determining the policy, setting the desired level of reserves depends entirely on the particular circumstances of each charity - no universal formula can be applied when deciding on an appropriate amount to hold back or aspire to. The amount trustees decide they need to hold in reserve will depend on what the charity is set up to do and those it seeks to assist, and should take into account the likelihood of any opportunities and risks.
During our visits we often come across policies that just fall short of meeting the SORP recommendations simply because they miss out a small amount of detail.
Brighton and Hove Philharmonic Society is a large charity which provides the local community with varied classical music programmes. It supports the work of Brighton Philharmonic Orchestra by which name it is better known.
We recently visited the charity as part of our Review Visits programme and it was clear that the trustees were aware of the SORP recommendation to have a policy in place to manage reserves and to publish that policy.
For example, the charity did have a reserves policy that included details of why the charity needed to retain funds (in this case to make advance commitment for artists or other expenses, as part of its programme of events and so that the Society could meet its obligations even if the intended funding sources failed to meet targets). It also explained where the reserves were held and the trustees published the policy in the Trustees' Annual Report.
In this case the trustees only needed to add the level of reserves to achieve a fully compliant policy. The trustees improved on this and added that they had considered key areas of financial risk when considering what the level ought to be - which is, in part, a good example of how reserves management is an integral part of effective strategic planning.
Brighton and Hove Philharmonic Society reserves policy - extract from 2005 Trustees' Annual Report:
The need for reserves: The Society needs short-term reserves to cover setbacks in funding or cash flow due to the concert season not starting until the second half of each financial year. It also requires long-term reserves to reduce the impact of risks from the external environment and because concert planning often requires the Society to make advance commitment to expenditure before all necessary funding has been attracted or confirmed. Reserves are therefore necessary to ensure the Society can meet its obligations if intended funding sources fail to meet the required targets.
The level of reserves In considering the appropriate level of reserves the Board took into account 20 key areas of financial risk. These equate to 7-8 months' operating costs of approximately £270,000.
Where reserves are held It is the Board's policy to keep only sufficient reserves in the General Fund that are necessary for the day to day running of the concert season, with an agreed shortfall made up by periodic transfers from the Legacy Fund, where the majority of funds are held.
Investment policy With regard to risk, the investment policy has been revised to hold approximately half of the Legacy Fund in longer term investments that offer balanced capital growth and income, and all other funds in cash. The Legacy Fund therefore has a regularly reviewed portfolio of shares, currently 17 share holdings. Remaining funds are held as cash in high interest COIF deposit accounts or a high interest CAF Cash current account. With regard to ethics, the investment policy is to retain shares that are received in the form of donations or legacies, except where holdings are in companies whose activities obviously conflict with those of the Society. Professional advice is taken regularly on the balance of the Society's investments.
In 2002, our research found that 69% of charities lacked a policy for managing reserves. This meant they were holding around £5.6 billion apparently without having any strategy or reason for withholding this money from their current beneficiaries.
Our new research found that the percentage of charities without a policy has fallen to 57%. This represents some improvement, but we are concerned that more than half of all charities still lack a reasoned argument for retaining funds they are not spending immediately.
It is true that many of these charities do not currently hold any money in reserve and this may be why they have adopted no policy. However, a charity that has no reserves may still need to justify this - nil is still a level of reserves and a charity in this position needs to be clear that this is appropriate in their circumstances and should have a reserves policy to help guide its future.
We do not expect small charities to produce a sophisticated or complicated policy - the amount of time spent preparing the policy, and the detail in which it is set down, should be proportionate to the scale and complexity of the charity's affairs.
But our research also found that 28% of charities that do hold reserves do not have a policy for managing them16. Although the amount held in reserve unaccounted for by a policy has reduced to £3.6 billion since 2002, it is worrying that such a large amount of money is still held apparently for reasons that are unjustified or unexplained. This sum represents around 10% of registered charities' annual expenditure, or 10% of the total reserves held by all registered charities. While the majority of these charities are medium-sized, still around 8% of charities with an income of over £250,000 a year hold reserves without a policy and charities with an income of over £1 million are holding around £2 billion unaccounted for.
When there is no policy in place it is unclear how funds are being managed. Charities that fail to be open and transparent about funds held in reserve could face a loss of public support and their reputation may be tarnished. Ultimately, this could result in a loss of funds to the charity and less public confidence in the sector as a whole.
We urge these charities to consider and make clear publicly why they are holding these amounts of money. Our case-working experience shows that some charities are already familiar with the concept of having reserves and are managing their surpluses at the end of the financial year without necessarily calling it 'reserves management'. In these cases, if the charity can justify its holdings, as part of its wider strategic plan, it should put in place a SORP-compliant policy and publish that in the Annual Report. This is only a simple next step - to explain what it already does and develop the concept further.
However, trustees who find they are holding an unjustifiable level of reserves will need to plan to bring them down to an acceptable level or increase them within a realistic timescale.
*Milestones: Managing key events in the life of a charity (RS6) - looks at various issues and phases of development that are relevant to charities. It also includes a checklist of standard questions for trustees to consider at various stages of development.
If one main advantage of having a reserves policy is to demonstrate a charity's transparency and accountability, then it makes sense to make that policy available to its stakeholders. In England and Wales, all registered charities must produce a Trustees' Annual Report, and SORP has always recommended that this report should include a statement on reserves for all charities, regardless of size and type.
With information about charities and their operation becoming increasingly available, for example on our own website, this is a logical step towards telling the charity's story more effectively.
Our research found that 84% of charities with a reserves policy also confirmed that they publish it in the Trustees' Annual Report. Very large charities especially are leading the way in best practice, with 93% publishing the policy they have drawn up.
Following our routine checks of charity accounts, a medium-sized charity set up to advance education did not appear to have a reserves policy published in the Trustees' Annual Report so we met with the trustees to discuss the issue.
Although the charity did not have a published reserves policy, the trustees had considered the management of the charity's reserves. However, they had set out this information only in the minutes of the trustees' meetings.
The trustees had discussed and planned for a level of reserves which, after proper investment, would give them a sufficient level of income so that the charity did not need to rely on additional donations to meet its projected expenditure.
Unfortunately, by not having a formal reserves policy and by not publishing it in the Trustees' Annual Report, they fell short of complying with SORP.
After our meeting the trustees followed our recommendations to set out a clearly defined policy in the Trustees' Annual Report showing stakeholders why the charity retains its current level of reserves. This followed the principles already in place but in doing so improved transparency and ensured compliance with the recommendations of the SORP.
During our routine monitoring of accounts, we often find that a reserves policy is missing. Yet when we query this with charities, we find that in many cases the trustees have discussed and decided why they are holding money in reserve, and their reasoning is sensible and legitimate. The reserves policy may be recorded in the charity's internal planning documents and management information. However, this will not help the public and other stakeholders to understand why the charity needs the stated level of reserves.
Charities' accounts and reports are falling increasingly under the spotlight, and many donors are keen to make more informed choices about the charities they support. If no explanation about a charity's reserves is publicly available, a potential donor to the charity may be put off by what they perceive to be a large 'nest egg'.
Overall, we are pleased that the number of charities with an accessible policy in the Trustees' Annual Report is increasing. But our message for those that still have none is that standards in the sector really can be raised in this area with little effort by those responsible for the Trustees' Annual Report.
It is reasonable to expect charities without a reserves policy to put a SORP-compliant policy in place - and publish it.
In 2002, we found that the total held in reserves by our sample was £26 billion, roughly equivalent to their total income for the year. Our new research has found that the charities in our sample held £35.5 billion in reserve, compared to a total annual income of £39.2 billion.
Breaking this down by income band, a sizeable gulf appears between smaller and larger charities in terms of the total amounts of reserves they hold. While medium-sized charities make up 81% of the sample, they hold just 12% of the reserves. In contrast, very large charities with an income of over £1 million represent just 7% of the sample, yet hold around 75% of the total reserves.
The absolute amount held in reserves across our sample has increased in cash terms, but analysis of the data suggests an overall decrease when reserves levels are expressed as a proportion of expenditure.
One way in which some charities identify an appropriate level of reserves is for trustees to decide on a range in terms of a number of months' coverage of expenditure. To compare trends across the income bands in our sample, our new research includes analysis of coverage ratios from data collected in 2001 and 200418.
Coverage is down from 13.6 months to 11.4 months overall. Breaking the figures down by income band shows that the highest reserves-to-expenditure ratio is found in the medium-sized charities group. But this income band has seen the biggest drop in reserves holdings over a short period: from 29.3 months in 2001 to 18 months in 2004.
Comparison of the percentage changes in expenditure compared to reserves levels over the period shows that overall, whereas expenditure has increased by 61%, reserves levels have only increased by 35%.
Again, medium-sized charities appear to have been the most affected. Although their expenditure has increased by 75%, reserves levels have grown less, going up by just 8% over the same period.
Comparisons of expenditure and reserves levels, 2001-2004.
Very large charities have experienced the least disparity between expenditure and amounts held in reserve (a 61 % increase in expenditure compared to a 42% rise in reserves).
This echoes research across the sector19 which has found a widening gap between the largest and smaller charities and reflects the increasingly difficult fundraising climate for charities, especially those in the lower income bands. There may be many reasons for this and it is difficult to draw any firm conclusions from these limited data.
However, a charity that is accountable and transparent to its stakeholders and has a sound system in place for its financial management stands a better chance of being able to tell its story effectively and convincingly to funders and wider stakeholders.
Setting the level of reserves depends entirely on the unique circumstances of each charity - no universal formula applies when deciding on an appropriate amount to either hold back or aspire to. It will normally depend on what the charity is established to do and whom it seeks to assist and should take into account any opportunities, risks, scale and growth of charitable activity, financial commitments and plans, and the likelihood of those risks affecting the charity.
For example, a charity providing a direct service to a group of beneficiaries requiring continuing help may need to hold more in reserve to offset unexpected costs or uncertain outcomes. A lower level of reserves may be needed if the charity makes one-off grants; receives guaranteed funding; or has a regular and reliable income without much risk that an interruption to its income stream may affect its work.
Once the trustees have decided on a reserves level, it is not always possible to reach the amount required. Even so, trustees can still decide on and publish in the charity's reserves policy an ideal level of reserves whether or not the actual level currently differs from the ideal level. If the actual level of reserves is less than the desired level, the trustees can then take this into account by including in their strategic plan their proposals for addressing the shortfall, over several years if necessary.
Trustees of other charities may realise that they hold unnecessarily high levels of reserves, in which case these need to be managed down in a responsible way, again over several years if necessary.
Community Energy Plus (CEP) is a large charity which exists to educate the public in energy conservation and efficiency.
We recently met with the trustees as part of our Review Visits programme. The charity had a reserves policy which appeared in the accounts, but the trustees were concerned that stakeholders might consider the level of reserves inappropriately high.
The trustees told us that as the charity continues to grow their major consideration for setting an appropriate reserves level is to maintain a sufficient cash flow. In addition to this they have identified a potential risk: if the charity were to lose a major contract which supplied a large part of its funding, this might affect the charity's future.
This is a valid consideration when deciding on appropriate reserves levels and the trustees felt that the level of reserves was not excessive but reasonable to ensure the long-term security of the charity.
As a result we recommended that the trustees revisit their reserves policy to clarify the reasons for the level of reserves. We suggested the level of reserves should take account of:
A clear and transparent reserves policy which explains the amount held or aspired to and also the reasons behind it, can reassure stakeholders that the trustees are acting responsibly and in the best interests of the charity and its beneficiaries.
Not all charities need to hold money in reserve; although most do. It is notable that, overall, our research found fewer charities that are potentially vulnerable because they have no reserves at all.
In 2001, 14% of charities confirmed that they had no reserves20. The percentage of charities in this situation has decreased to 9% this time. This suggests that more charities are now setting funds aside when they are able to. There may be various reasons for this, but a recurring theme in our research showed that more charities are aware of the importance of planning for funding difficulties by considering reserves.
We also know from our case-working experience and research that charities are becoming more aware of the SORP recommendations and so the increase in charities holding reserves may also be because they are now more accurately designating funds as reserves which they had previously accounted for differently.
Charities that choose not to maintain reserves should ensure that they fully consider the potential pitfalls of having low or no reserves and that they manage risks properly.
Reserves checklist - see Annex A of this report.
*Charities' Reserves (CC19) - provides guidance for charity trustees and staff on how to make decisions about reserves levels in a way that is consistent with the legal requirements for the use of charity income.
*Charity Reserves (RS3) - our earlier research on reserves. It looks at the challenges facing trustees when developing a well-thought-out reserves policy, setting a level of reserves that is appropriate to the charity's needs and clearly explaining this to its stakeholders and other interested parties.
*Small Charities and Reserves (RS5) - this explored the same issues as Charity Reserves (RS3) but focused on charities with an annual income of less than £10,000.
*Charity Commission and Regulation - outlines the significant changes to our approach to regulating the charity sector.
Charities Accounting and Reporting by Charities: Statement of Recommended Practice PDF 674kb (revised 2005) - this includes recommendations and guidance for preparing charity accounts and annual reports. Guidance on the preparation of receipts and payments accounts by smaller non-company charities is also available.
Asking for it - Honest Answers to Tough Questions: The essential Q&A for all charities - produced by NCVO, it is aimed at both charities and the public. The publication seeks to increase general awareness and understanding about charities. It is available from the NCVO website www.ncvo-vol.org.uk
We were pleased to note that several charities that did not have a reserves policy at the time of our earlier research22 stated on their 2004 Annual Return forms that they now had one in place. We conducted a supplementary survey to find out the effect this had had on those charities23.
Most charities we contacted said that the change was due to an increased awareness of the requirements to account for reserves.
As part of our role under the Charities Act 1993 to promote the effective use of charitable resources, we have helped raise awareness in this area in several ways, for example through:
We asked the charities we surveyed how difficult it was to set up a reserves policy. For the majority of respondents, setting up the policy was not complicated: 92% of respondents said they had found the process relatively straightforward. Where there were difficulties, these appeared to be because of resource implications rather than because the process itself was complicated.
“Minor time and resource issues…[we are] a small charity with limited resources to research and implement new policies. But undoubtedly, [it] was a useful process.”
- respondent to our survey
For trustees and advisers who are finding the process difficult, our publication Charities' Reserves gives more guidance on areas to consider when setting a policy and the checklist at Annex A may also be helpful.
Once the policy is established, trustees will need to review it periodically, taking account of any significant change in the charity's financial circumstances. By revisiting the policy in the wider context of the charity's strategic plan, and the nature of the risks facing the charity, they can ensure that the level of reserves they have, or are aiming to have, remains appropriate to the charity's current position and future prospects.
We also asked our sample of charities about the benefits of having a policy.
The majority of responding charities (88%) said that having reserves made the charity more secure and protected it against risks, while donors regarded the charity as more accountable.
Our survey found that a few charities use reserves to generate income. What is not clear is whether such charities simply receive income because they have invested reserves or whether their sole reason for having reserves is to generate income.
In the first case, generating income from reserves is entirely appropriate; in fact it would be imprudent not to invest retained income in some way. A short-term delay in spending income is justified if the income needs to be kept back for legitimate operational reasons. However, trustees who hold income in reserve solely to generate future income may not be complying with their duty to spend income on the charity's purposes within a reasonable period of receiving it.
A few charities have an express legal power25 in their charity's governing document allowing the charity to hold income in reserve. However, in some situations other charities have an implied power to accumulate funds. For example, some charities have to maintain a service over a number of years and need reserves to guarantee this service; other charities need to raise money for a particular project, for instance, a piece of equipment for a hospital or the construction of a community building. In such cases, it would be inappropriate to expect a charity to use its income before the final appeal total had been reached.
But whether trustees have an implied or express power, they should exercise it with the charity's beneficiaries in mind. The trustees should still, either by designating funds or in the published reserves policy, demonstrate why the income is held back rather than being spent directly on the charity's beneficiaries in the year in question.
Earlier in this report, we noted that some charities still thought that holding reserves would create funding difficulties26, so as part of this survey we asked trustees whether they felt this was still a factor for them. It is pleasing to report that one of the main reasons charities said a reserves policy was beneficial was that it made them more accountable to funders. In addition, holding reserves was not preventing the majority of charities we surveyed from getting the funding they need.
“We were apprehensive that reserves that we built up may have been 'clawed back' by one of our funders - this however was not the case.”
Charities have told us that a clearly-defined and well-founded policy which they openly publish can help justify to potential funding bodies, other stakeholders and the public why the charity needs to retain some of its income. Section 6 looks at the issue of Funders and reserves in more detail.
This report is written at a time of much debate about whether charities and the wider voluntary sector should take a greater role in public service delivery. As the independent regulator of charities in England and Wales, the Commission itself is neutral about whether charities deliver public services27. We recognise the added value that charities can offer and are concerned only with improved services to beneficiaries and ensuring that charities stay independent, remain focused on their objects and properly meet their beneficiaries' needs.
Often, funding for the provision of these services is for a fixed period. And a current issue for the sector is how to recover the full costs attributed to a project (full cost recovery). In some cases, a charity may not be aware of the need - or know how - to calculate the 'behind-the-scenes' costs of delivering the project. In other cases, the funding body may be unwilling to meet these costs. But the charity needs to consider its long-term stability and the implications for its financial health if and when the public sector funding ceases. Well-managed reserves can be called upon if this happens. But only if they have very good reason to do so should charities spend reserves to 'prop up' the services for which they have been unable to obtain sufficient funding.
In 2002 our casework experience showed that some grant-making bodies automatically refused grants if reserves exceeded a certain amount. In these circumstances, a charity was often left wondering what level of reserves funding bodies would think acceptable, rather than what level was appropriate to its needs.
Yet many funders we consulted as part of our earlier research reported that they assessed each charity individually and on the merits of the proposed use of the grant, rather than by applying arbitrary rules. Recently, we have found that some grant-makers are now more flexible on this issue, recognising the important part reserves can play in firming up the charity's long-term stability.
“We recognise that reserves are an important part of any charity's long-term stability. We would prefer to see evidence that a reserves policy and an accompanying fund is in place, helping the organisation to manage problems like minor cash-flow issues, rather than award a grant to a charity which may fold when grants aren't paid on time or some other crisis occurs."
- Big Lottery Fund28 (November 2005)
However, our casework shows that some charities still believe that funders are unsympathetic to the issue of building up reserves.
The representatives of one large charity we visited said that most of the funding is awarded to them for specific projects and they have no room to build up general reserves for contingencies.
This time, our research found that difficulties like this are only true in a few cases and may arise from specific policies set by some funding bodies.
Generally we find that if charities comply with the SORP by explaining convincingly why they need to retain funds at a certain level, then the great majority of donors, supporters and beneficiaries will accept that they need these reserves and this will not affect further support.
We encourage this approach and do not criticise charities for holding reserves at levels that have been carefully assessed and well managed.
Full cost recovery: a guide and toolkit on cost allocation - published by New Philanthropy Capital and ACEVO - assists with calculating the full costs of your projects and outlines the steps towards recovering, or funding, the full costs of your organisation. Available from: www.philanthropycapital.org/html/full_cost_recovery.php or to order the toolkit visit www.acevo.org.uk/publications.
Our research has shown that a charity that plans its reserves in the wider context of a medium- to long-term strategy, and tells its story effectively to beneficiaries, funders and the public generally, is more likely to operate successfully. It will build the confidence of its beneficiaries, funders and wider stakeholders, therefore making its long-term future more secure.
We recognise that some charities may still be having difficulty in formulating and presenting a reserves policy. Our publication Charities' Reserves30 gives more guidance on considerations affecting the level that may be needed, such as forecasting income and expenditure and thinking about any risks the charity may face. For trustees who have already established a policy, this report includes a checklist at Annex A that may help you think about the issues you need to consider when reviewing and presenting that policy.
We hope that the messages in this report will encourage charities to comply if they have still not realised the opportunities and benefits of having a well-thought out policy and publishing it in the Trustees' Annual Report.
1 You can find the results of our earlier research carried out in 2001 in our report, Charity Reserves (RS3, published in 2002). All Charity Commission publications referred to in this report are available from our website.
2 Currently, the Charities Act 1993, the Charities (Accounts and Reports) Regulations issued in 2005 ('the Regulations'), and where appropriate, The Statement of Recommended Practice: Accounting and Reporting by Charities ('SORP 2005').
3 Definitions of 'medium', 'large' and 'very large' charities for the purposes of this report are in Annex B. In our report Small Charities and Reserves we looked separately at how small charities (with gross income or total expenditure of £10,000 or less) manage their reserves. This latest research does not include this group. However, if small charities hold reserves, these issues will still be relevant to them and so, as a matter of best-practice, we recommend that they should act accordingly and proportionately, depending on the size and nature of the charity.
4 The results of our earlier research can be found in our report, Charity Reserves (RS3, published in 2002).
5 Our sample included over 62,000 registered charities with an income of £10,000 and over providing information for financial years ending in 2004 on Part B of the Annual Return. Charities with an income below £10,000 were not required to complete Part B.
6 Definitions of 'medium', 'large' and 'very large' charities for the purposes of this report are in Annex B.
7 9,348 charities had reserves but no reserves policy.
8 Accounting and Reporting by Charities - Statement of Recommended Practice (revised 2005). SORP sets out the recommended practice for charities in preparing annual reports and accounts.
9 The full text relevant to reserves is set out in Annex F.
10 For example, The UK Voluntary Sector Almanac 2006: The State of the Sector, NCVO (2006) and Charity Trends 2006, Charities Aid Foundation (2006). Note: the samples of organisations on which NCVO's, CAF's and our research are based differ.
11 Good Governance: A Code for the Voluntary and Community Sector, 2005.
12 The Hallmarks of an Effective Charity (CC60).
13 The Summary Information Return ('SIR') is a form designed for very large charities to provide the public with an easily accessible summary of key information. It asks for details of the charity's financial situation and, if relevant, details of significant financial commitments that can make clear the need for reserves at certain levels.
14 For example, on our own website.
15 This is just a small sample of the guidance and support available. Where not cited here, contact details for all organisations are mentioned in Annex D.
* These are Charity Commission publications. Full details on how to obtain copies can be found in Annex D.
16 9,348 charities confirmed that they had more than £nil in reserves, and also said that they had no policy for their management in questions B8a and B8c of the Annual Return form for 2004.
17 This is just a small sample of the guidance and support available. Where not cited here, contact details for all organisations are mentioned in Annex D.
* This is a Charity Commission publication. Full details on how to obtain copies can be found in Annex D.
18 This is based on totals for each income band. Within each income band, some charities will hold no reserves, some reserves or a large amount of reserves. The results are therefore not typical of any one charity but are included to show an overall trend.
19 For example, most recently The UK Voluntary Sector Almanac 2006: The State of the Sector, NCVO (2006) and Charity Trends 2006, Charities Aid Foundation ('CAF'). Note: the samples of organisations on which NCVO's, CAF's and our research are based differ.
20 Of the charities answering question B8c of the Annual Return 2004.
21 This is just a small sample of the guidance and support available. Where not cited here, contact details for all organisations are mentioned in Annex D.
* These are Charity Commission publications. Full details on how to obtain copies can be found in Annex D.
22 8,738 charities did not have a policy in the 2001/02 financial year, but did by 2003/04.
23 We sent a short questionnaire to 250 of these charities and received a 19% response rate.
24 Guidance and publications available have been listed throughout in the resources boxes.
25 Trustees without an express power will have to rely on their implied power - a power not written into the governing document but one that the trustees possess in order to take actions that are necessary for the charity to function properly. As with all discretionary powers, trustees are justified in exercising their power to hold reserves - whether express or implied - only if in their considered view it is necessary in the charity's best interests to do so.
26 See section on Funders and reserves.
27 Our Policy statement on Charities and Public Service Delivery is available on our website.
28 The Big Lottery Fund uses lottery funding to make grants to organisations to regenerate and revitalise communities, with a particular emphasis on tackling disadvantage.
29 This is just a small sample of the guidance and support available. Where not cited here, contact details for all organisations are mentioned in Annex D.
30 Charities' Reserves (CC19).
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