OSCR’s new trustee information requirements: what Scottish charities need to know

The Office of the Scottish Charity Regulator (OSCR) has announced significant changes to the way Scottish charities must report and publish trustee information. These changes are designed to increase transparency and improve regulatory oversight, but they also introduce new responsibilities for charities and their trustees.

Below, we summarise the key points and offer practical steps for charities to prepare.

What’s Changing?

Mandatory Online Submission of Trustee Details

Later this summer—on a date yet to be confirmed—it will become mandatory for all Scottish charities to submit detailed trustee information through OSCR Online. This is part of the new online annual return process. Importantly, charities will not be able to complete their annual return without supplying trustee details.

The exact date for when this requirement comes into force will be announced shortly by OSCR.

What Information Will Be Required?

For each trustee, charities will need to provide:

• Full name
• Home address
• Email address
• Telephone number
• Date of birth

OSCR will store this information securely for regulatory purposes and to enable direct contact with trustees if necessary.

Publication of Trustee Names

From the end of 2025, the first and last names of all charity trustees will be published on the Scottish Charity Register. This is a significant shift towards greater transparency in the sector.

Exemption Process

If there is a risk to personal safety or security, it will be possible to apply for an exemption from the publication of a trustee’s name. More information about how to apply for an exemption will be available when the data collection process begins.

Publication of Charity Accounts

Also from the end of 2025, all charity accounts submitted to OSCR will be published in full on the Scottish Charity Register for a minimum of five years. There will be no redaction, so any personal information included in the accounts will be publicly visible.

How Does This Compare to Other Regulators?

The information OSCR is now requiring broadly matches what charities already provide to the Charity Commission in England and Wales. Therefore, for many charities, the main change will be the need to submit this information through OSCR Online.

What Should Charities Do Now?

• Prepare trustee details: Ensure you have up-to-date information for all current trustees.
• Review your accounts: Be aware that any personal information in your accounts will be published in full—consider whether any changes are needed to your reporting practices.
• Monitor OSCR communications: Watch for the official announcement regarding the mandatory submission date and further guidance on exemptions.
• Inform your trustees: Make sure all trustees are aware of these changes, particularly regarding the publication of their names and the possibility of applying for an exemption if there are safety or security concerns.

Final Thoughts

While these changes will require some additional administrative work, they are largely in line with existing requirements elsewhere in the UK. The move towards greater transparency is intended to strengthen public trust in the charitable sector. By preparing now and keeping up to date with OSCR’s announcements, charities can ensure they remain compliant and continue to operate smoothly.

If you have concerns about privacy, or if you believe a trustee may be at risk if their name is published, keep an eye out for OSCR’s forthcoming guidance on the exemption process.

If you would like further advice or support in preparing for these changes, please get in touch with our team.

Laura Patriche, Trainee Solicitor (Author of article): lpa@bto.co.uk / 0131 381 5041

Michael Cox, Partner: mco@bto.co.uk / 0131 381 5041