Preena Patel
- Associate
- Charities & Not-for-Profit
Grant making disclosures under SORP 2026: transparency without risk
From 1 January 2026, charities preparing accruals accounts moved to SORP 2026. For grant making charities, one area worth revisiting early is how grants are described and disclosed in the annual report and accounts.
The good news? The SORP continues to allow flexibility and recognises that full public disclosure isn’t always the right answer.
Telling the story
SORP 2026 expects trustees to explain grant making clearly in the trustees’ annual report and in the notes to the accounts, and in a way that helps readers understand what the charity funds, why those grants are made, and how charitable resources are being used. There’s no single correct format. Grants can be presented by theme, programme, geography or activity, so long as the picture is clear. For many charities, especially those working internationally or across multiple programmes, this approach can be far more meaningful than a long list of recipients.
Naming grant recipients
Charities do not necessarily need to name every grant recipient. Where grants are made to organisations, trustees must consider materiality. If the total funding given to a particular organisation is material in the context of overall charitable expenditure, the default position is that it would usually be identified in the accounts. Where grants are not material at that level, the SORP allows a more aggregated approach provided the disclosure still explains the nature and purpose of the activity.
The “serious prejudice” exemption
SORP 2026 also recognises that disclosure can create real risks. Where naming a grant recipient could reasonably be expected to cause serious prejudice to the charity, the recipient organisation, or individuals connected with it, trustees may withhold identifying information. This is particularly relevant for grants to individuals and grants made in high‑risk or politically sensitive contexts, where public identification could expose people to harm or intimidation.
Importantly, this isn’t a blanket non‑disclosure. Even where identities are withheld, charities must still disclose, in aggregate, the number, total value and general purpose of the grants, and explain that the serious prejudice exemption has been applied.
Trustees approach to disclosure in the annual report
Trustees are expected to exercise judgement and to do so carefully. In practice, this means:
- Making a clear trustee decision about the disclosure approach.
- Assessing both materiality and risk (not convenience).
- Documenting the rationale.
- Retaining full grant information internally for audit and regulatory purposes.
SORP 2026 places clear weight on the exercise of trustee judgement. Decisions to reduce or aggregate disclosure should be taken consciously and for proper reasons. Where trustees rely on the serious prejudice exemption, they should be able to explain by reference to objective factors why public disclosure would not be appropriate in the circumstances.
The key takeaway
SORP 2026 does not force charities to choose between transparency and safety. It allows trustees to be open about how funds are used, while also protecting beneficiaries, partners and the charity itself where there are genuine risks.
For grant making charities, reviewing disclosure practices now, and ensuring trustee decisions are well reasoned and well recorded, is an important part of getting ready for the year ahead.
This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.
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