Scottish charities face a clear compliance calendar. The Scottish Government has set 5 March 2026 for the final elements of the Charities (Regulation and Administration) (Scotland) Act 2023 to take effect. This is delivered through Scottish Statutory Instrument 2026/98-Commencement No. 3 and Transitional Provision-made on 17 February and laid on 19 February, according to legislation published on legislation.gov.uk. With this step, the 2023 Act is fully commenced.

From 5 March, the Scottish Charity Register must include the names of each charity’s trustees. This requirement sits in section 2 of the 2023 Act and updates the Charities and Trustee Investment (Scotland) Act 2005. A limited dispensation under section 3(4) of the 2005 Act remains, allowing the Office of the Scottish Charity Regulator (OSCR) to withhold a trustee’s name where publication would be inappropriate, including potential safeguarding concerns.

Existing charities get a practical runway. For organisations already on the Register before 5 March 2026, OSCR will not display trustee names until the charity provides them-typically through the annual return or an update via the OSCR Online portal. New applicants after that date should expect trustee names to appear as part of the initial registration entry.

Section 10 introduces a second pillar: preservation and access to financial statements. Each charity must submit its statement of account together with the independent report on accounts-the external scrutiny report from an independent examiner or an auditor-and OSCR must keep both for at least five years from the end of the relevant financial year. OSCR is then required to publish the documents and make them publicly available.

The commencement of section 10 also activates connected provisions in the Charities Accounts (Scotland) Amendment Regulations 2025 (S.S.I. 2025/341), aligning terminology and filing expectations around the independent report on accounts. For finance teams, this should reduce ambiguity over what exactly needs to be lodged and retained.

Operationally, the workload shifts to record‑keeping and timely updates. Finance leads should ensure trustee details-legal names, appointment dates and resignations-are accurate and consistently applied across filings. Where a trustee wishes to use a preferred name publicly, boards should agree a clear policy and document any safety‑based redactions sought under the 2005 Act’s dispensation, balancing transparency with duty of care.

On costs, most charities already commission an auditor or independent examiner; the change formalises that the scrutiny report must travel with the accounts into the public domain. Expect modest extra administration for packaging, approvals and portal uploads rather than a structural change to professional fees. Larger charities may still ask their examiner or auditor to review public‑facing wording before submission for consistency and clarity.

Consider a mid‑sized service charity with £2m annual income and a June year‑end. If its filing window falls after 5 March 2026, the independent examiner’s report should be finalised alongside the accounts, uploaded together, and cross‑checked so trustee names in the report match the Register entry. Treat the exercise as a governance tune‑up: conflicts registers, appointment minutes and resignation notices should all reconcile cleanly.

For funders and donors, the benefits are straightforward. Standardised trustee names on the Register and five‑year retention of accounts and scrutiny reports will speed due diligence and make year‑on‑year comparisons easier. That transparency will reward organisations with tidy governance and consistent reporting-and will more quickly surface where oversight has slipped.

Key dates matter for planning. The instrument was made on 17 February 2026, laid on 19 February, and takes effect on 5 March 2026. In practice, most charities should now verify trustee data, review any privacy considerations, and prepare to submit the independent report with the next set of accounts. OSCR’s portal will carry the workload, but the quality of what goes in remains the responsibility of trustees and finance leads.