Charity Commission Record-Keeping: What Trustees Need to Know

Trustees are personally responsible for records

If you are a trustee of a registered charity in England and Wales, you have a legal duty to ensure your charity maintains adequate records. This is not a nice-to-have. The Charity Commission's guidance (CC8 and the internal financial controls checklist, CC8) is clear: trustees must ensure that their charity keeps proper accounting records, maintains minutes of meetings, records conflicts of interest, and retains key governance documents.

When things go wrong — and the Charity Commission opens an inquiry — the first thing they ask for is documentation. Signed minutes, trustee declarations, financial approvals, and governance policies. If these do not exist, or exist only as informal emails and unsigned papers, trustees face serious reputational and legal consequences.

What records the Charity Commission expects

The Charity Commission does not prescribe a specific record-keeping system, but it does set clear expectations about what records must exist:

• Governing document — the charity's constitution, articles of association, or trust deed. This must be current and accessible to all trustees.
• Minutes of trustee meetings — every meeting of the trustee board (and any sub-committees) must be minuted. Minutes should record decisions made, who was present, and any conflicts of interest declared.
• Declarations of interest — trustees must declare any personal or financial interests that could conflict with their duties. These declarations should be signed and reviewed annually.
• Financial records — accounting records must be retained for at least 6 years. This includes receipts, invoices, bank statements, payroll records, and gift aid claims.
• Annual accounts and reports — the charity's annual return, accounts, and trustees' report must be filed with the Charity Commission and retained.
• Policies — safeguarding, data protection, reserves, investment, complaints, and whistleblowing policies should be documented, signed off by trustees, and reviewed periodically.
• Contracts and agreements — employment contracts, grant agreements, lease agreements, service contracts, and any other legally binding documents.

Where charities typically fall short

In our experience, the most common record-keeping failures are not dramatic — they are mundane:

• Minutes exist but are unsigned. The secretary types up the minutes and emails them to trustees, but nobody formally approves or signs them. If the minutes are later disputed, there is no evidence they were agreed.
• Declarations of interest are done once and forgotten. Trustees sign a declaration when they join the board, but annual reviews do not happen. When a conflict arises years later, the declaration is out of date.
• Policies are adopted but not signed off. The charity has a safeguarding policy (because it was required for a grant application), but there is no record of when the trustee board reviewed and approved it.
• Governing document amendments are not recorded. Changes to the charity's objects or powers are agreed at a meeting, but the amended governing document is not formally adopted and signed.

How digital signing helps

The documents that cause the most governance problems — minutes, declarations, policy sign-offs — are all documents that need signatures. Moving them to e-signatures creates a systematic, auditable process:

Meeting minutes: After the board meeting, the chair reviews the draft minutes, then e-signs to confirm approval. Every trustee receives a copy. The audit trail records when the chair signed, creating a clear record of minute approval.

Annual declarations of interest: Each year, send every trustee a declaration of interest form for e-signature. The system tracks who has signed and who has not. No more chasing by email. No more unsigned forms in the filing cabinet.

Policy reviews: When a policy is reviewed and updated, circulate it to all trustees for e-signature. The signed document — with each trustee's signature, timestamp, and consent — becomes the definitive record that the board approved the policy on that date.

Good governance is not about generating more paper. It is about having the right documents, properly signed, easily retrievable. Digital signing makes this the default, not the exception.

The Charity Commission's view on electronic records

The Charity Commission does not require paper records. Its guidance states that accounting records may be kept in electronic form, provided they are accessible and can be printed if required. The same principle applies to governance records: digital is fine, as long as the records are complete, accurate, and available for inspection.

For charities subject to independent examination or audit, the examiner or auditor will need access to your records. Digital records that are well-organised and include audit trails (who signed what, when) are generally easier for examiners to work with than boxes of paper files.

A practical system for small charities

You do not need expensive governance software. A practical system for a small charity might look like this:

• Cloud storage (Google Drive, OneDrive, Dropbox) — one shared folder with sub-folders for Governance, Finance, Minutes, Policies, and Contracts.
• E-signatures (VowTerra) — for any document that needs trustee sign-off: minutes, declarations, policies, contracts. The free tier covers 15 documents a month, which is more than enough for most small charities.
• Calendar reminders — annual declarations of interest, policy review dates, Charity Commission filing deadlines. Put them in a shared calendar so they do not depend on one person remembering.

What to do if your records are incomplete

If you have been a trustee for years and suspect the records are not what they should be, do not panic. Start from today:

• Review what records exist and identify gaps.
• At the next board meeting, agree a plan to bring records up to standard.
• Circulate and sign the current declarations of interest.
• Ensure minutes are properly approved and signed going forward.
• Adopt any missing policies and get them formally signed off.

The Charity Commission is primarily concerned with whether trustees take their responsibilities seriously. Identifying gaps and taking action to address them is exactly what good governance looks like.

The bottom line for trustees

Record-keeping is not glamorous, but it is one of the most important things trustees do. It protects the charity, protects the beneficiaries, and protects you personally as a trustee. Digital tools like e-signatures make it easier to build good habits — but the habits themselves are what matter. Sign your minutes. Renew your declarations. Review your policies. File your documents. Your future self — and any Charity Commission inquiry officer — will thank you.