Charities registered with OSCR to prepare for trustee information requirements and new automatic disqualification criteria

In our June e-alert, we discussed the impending changes to trustee information requirements and automatic disqualification criteria by the Scottish charity regulator, OSCR. OSCR has provided more details on these changes and provided updated timelines for their implementation.

Trustee information requirements

Scottish charities are now able to provide trustees' personal information to OSCR via OSCR Online. This means every trustee's full name, home address, email address, telephone number and date of birth will have to be submitted. OSCR has published a detailed guide to assist charities to complete this process here.

From early 2026 (initially this was scheduled for late 2025), the full names of trustees will be published on the Scottish Charity Register (unless they successfully apply for an exemption). All other information will be kept confidential.

Any Scottish charity completing a new online annual return created on or after 30 June 2025, will be required to include this information as part of the submission. While this is not required for online annual returns created before 30 June 2025, OSCR strongly encourages that charities provide these details as soon as possible to ensure compliance with the new rules.

Accounts

As discussed in our previous article, OSCR currently only publishes accounts for certain charities. This is determined by their legal structure and income, and personal details are hidden.

From early 2026 (initially this was scheduled for late 2025), all accounts submitted to OSCR will be publicly available on the Scottish Charity Register for at least five years. There will not be any redaction, even on any personal information contained in the documents.

Automatic disqualification

The changes to automatic disqualification will apply from 31 August 2025.

As discussed, the main changes are:

• Automatic disqualification may apply to people performing management roles (regardless of job title). Previously these provisions only applied to trustees.
• Extended disqualification criteria to include a wider range of offences. For example, someone convicted of a terror offence or listed on the sex offenders register will be automatically disqualified.