ACCA welcomes the opportunity to respond to DCMS in respect of the proposed uplifting of various financial thresholds in charity law. Thresholds set in absolute amounts offer clarity in application but over time can have unintended consequences in covering a greater portion of the charitable sector due to the effect of inflation but ACCA would also note that changes in the economic environment, operational context of the charity sector and public expectations as to the oversight of charities are also factors that should affect the level at which thresholds are set.
ACCA makes the following suggestions:

• ACCA would favour the commitment to the periodic review of financial thresholds under charity law
• In setting thresholds DCMS should balance the proportionality that having thresholds offers with the issue of complexity in having many different thresholds; where possible a threshold should therefore be common to more than one matter
  
• Although the DCMS’ intention is to be: ‘…proportionate and reduce unnecessary administrative burdens on charities where possible, particularly for small organisations’ this needs to be balanced with the importance and benefits that having thresholds brings to encouraging and underpinning good charity governance of the money entrusted to the sector.
• DCMS should consider an ongoing dialogue with the other UK jurisdictions of Northern Ireland and Scotland around synchronising future threshold reviews so that there is an opportunity for a more coherent UK approach to setting charity law financial thresholds and also to allow the sharing of good practice and experience in the oversight of the charity sector
  

To read our response in full, please download the consultation document found on this page.