The Charities Accounts (Scotland) Amendment Regulations 2025: business and regulatory impact assessment

Section 4: Additional implementation considerations

Enforcement / compliance

OSCR’s role as regulator remains unchanged, as the underlying regulations have not substantially altered. Consequently, its enforcement responsibilities continue as before. The same applies to auditors and independent examiners, whose duty to identify issues and report matters of material significance remains consistent.

However, there may be an impact for independent examiners working with larger charities following the change to the audit income threshold. For charities preparing fully accrued accounts, below the audit income threshold, the regulations require that the independent examiner must be a member of one of the professional bodies listed, ensuring they are appropriately qualified in accounting and financial administration. Engagement with the professional bodies during the audit roundtable discussions suggests that any impact should be minimal.

UK, EU and International Regulatory Alignment and Obligations

Internal Market / Intra-UK Trade

Raising the audit income threshold will bring Scots charity law into closer alignment with current legislation in England and Wales. However, it will create a divergence from the law in Northern Ireland. That said, this difference is unlikely to have any practical impact, as the approximately 1,300 cross-border charities on the Scottish Charity Register operating in Scotland are registered with the Charity Commission for England and Wales, rather than with the regulator in Northern Ireland.

International Trade Implications

The proposal will not:

• affect imports or exports of a specific good or service, or groups of goods or services
• affect trade flows with one or more countries
• place particular technical requirements upon imported goods
• include different requirements for domestic and foreign businesses

EU Alignment consideration

The proposal is not relevant to the Scottish Government’s policy to maintain EU alignment.

Legal Aid

The proposal should have no effect on fulfilling individuals' right to access justice through availability of legal aid and possible expenditure from the legal aid fund.

The proposal should not result in additional people seeking legal assistance or being taken through the courts.

Digital impact

There should be no effect.

Business forms

This proposal will not bring in any new forms for business or charities to complete for monitoring or reporting.