A charity can be ready for a Charity Commission inquiry if trustees can evidence how decisions were made, how conflicts and risks were managed and why money was spent. 

Six checks test this: minutes, payment evidence, the conflicts register, serious incident reporting, the risk register and recorded trustee challenge.

A statutory inquiry is not a finding of wrongdoing, but it can test whether trustees have met their legal duties. Often the greater risk lies in the charity's inability to show what was decided, why, and how risks and conflicts were managed, rather than in the original concern.

The key question is this: if the regulator reviewed your charity tomorrow, could you clearly evidence sound governance?

Quick inquiry-readiness checklist

  • Minutes are approved, retained and explain significant decisions
  • Material expenditure is supported and properly authorised
  • Connected-party payments are justified and disclosed
  • The interests register is current and conflicts are documented
  • Serious incidents can be escalated, assessed and reported
  • Decisions not to report potential incidents are recorded
  • The risk register is tailored and reviewed regularly
  • Trustees can evidence scrutiny of strategy, fundraising and finances
  • Board actions are assigned, monitored and completed
  • Resources can be shown to further the charity’s purposes.

A timely example: Stoke Air Ambulance CIO

In February 2026, the Charity Commission announced a statutory inquiry into Stoke Air Ambulance CIO. The inquiry is examining:

  • the management of potential conflicts of interest and the extent to which there has been any private benefit to the trustees or connected individuals
  • the proportion of income used exclusively for charitable purposes
  • the charity’s fundraising arrangements, and
  • its ability to further its charitable objects, including its business and strategic planning.

In August 2026, the charity announced that it would close and begin an orderly winding-up process after trustees concluded that developing an operational air ambulance service was no longer in its best interests.

The closure was a decision by the trustees, not the published conclusion of the Charity Commission’s inquiry. The matters under investigation should therefore not be treated as findings of wrongdoing.

Nevertheless, the case is a timely reminder that charities must be able to demonstrate effective governance, proper oversight and informed decision-making.

1. Do your minutes explain decisions?

Minutes should do more than record decisions. For significant matters, they should show how trustees exercised independent judgement by documenting:

  • the information, options and risks considered
  • professional advice and trustee challenge
  • conflicts and how they were managed
  • the reasons for the decision, and
  • agreed actions, owners and deadlines.

This is especially important for major expenditure, connected-party arrangements and strategic decisions. Minutes need not be transcripts, but they should provide a clear audit trail.

2. Can your charity support every material payment?

Material or unusual expenditure should be traceable from approval to payment and accounting treatment. Evidence may include:

  • invoices, contracts and authorisation
  • evidence that goods or services were received
  • the link to the charity’s purposes
  • procurement records where relevant, and
  • bank records and trustee approval where required.

Connected-party payments require particular care. Record the legal authority, how the conflict was managed, why the arrangement was appropriate and how value for money was assessed.

3. Is your conflicts of interest register up to date?

A conflicts policy is effective only if trustees use it. Keep an up-to-date register covering relevant employment, directorships, family links, supplier interests and relationships with funders or partners.

  • who declared the conflict;
  • whether they received papers or joined the discussion;
  • whether they left the meeting or voted; and
  • how the remaining trustees reached their decision.

A conflict can exist even when an arrangement appears sensible or good value. The practical rule is simple: identify, declare, remove, manage and record.

4. Would your charity recognise and report a serious incident?

A serious incident is an actual or alleged event that causes, or risks, significant harm to people, assets, property, the charity’s work or its reputation. Your process should state:

  • who identifies and escalates concerns
  • who assesses significance
  • when trustees are notified
  • who may submit a report, and
  • how decisions and remedial actions are documented.

Trustees retain ultimate responsibility, even when reporting is delegated. The aim is timely consideration and a clear record, not automatic over-reporting.

5. Does your risk register reflect what the charity actually does?

A generic register reviewed once a year is weak evidence of active risk management. Record each major risk, its impact, controls, further action, owner, deadline and residual position.

  • financial sustainability
  • safeguarding and fundraising
  • cybersecurity and compliance
  • delivery partners and reputation, and
  • strategic viability.

The register should reflect the charity’s actual activities and help trustees test whether major plans are achievable, funded and aligned with its purposes.

6. How can trustees evidence constructive challenge?

Trustees should scrutinise management proposals rather than accept them without sufficient review. Evidence may include:

  • questions recorded in minutes
  • requests for further financial information
  • alternative options and revised forecasts
  • follow-up of overdue actions
  • scrutiny of fundraising costs and charitable outcomes, and
  • proposals being amended, deferred or rejected.

Constructive challenge is not confrontational. It means asking proportionate questions, obtaining reliable information and reaching an independent decision.

Final thought

Inquiry readiness means maintaining clear records, managing conflicts, challenging assumptions and embedding accountability into routine board business, rather than assembling evidence after a regulatory letter arrives.

The real test is not whether trustees believe they acted properly, but whether the charity’s records allow an independent regulator to reach the same conclusion.

Sources and further guidance

Disclaimer: This article provides general information for trustees and charity leaders and is not legal advice. The Stoke Air Ambulance CIO inquiry is ongoing; opening an inquiry is not a finding of wrongdoing.

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