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When a household-name charity faces scrutiny for a "toxic" workplace culture, it is tempting to see it as an isolated problem. But the Charity Commission's 2025 assessment of World Vision UK, a charity that does so much to help children in some of the world's most dangerous places with water provision, healthcare, child protection and income generation, now faces allegations of racism, sexism, exclusion, and mishandled grievances. This shows that serious incidents can happen to any charity, no matter how confident or prepared the charity trustees may feel. The Charity Commission ('the Commission'), understands that things can go wrong at times, even for the best run charities. It's what the charity trustees do about the incident and how quickly they act that matters.
Serious incidents may sometimes emerge from unresolved cultural issues, overlooked risks, or failures to escalate concerns early, precisely the gaps a robust Serious Incident Policy is designed to address. World Vision deny the allegations but nonetheless, submitted a Serious Incident Report (SIR). An SIR is not an admission of liability but a statutory requirement in the face of serious allegations. Submitting a properly prepared SIR promptly, demonstrates to the regulator and the outside world that the charity trustees are familiar with their obligations with this important aspect of charity governance, helping to keep your charity safe from harm and/or undue risk.
The Commission defines a serious incident as an adverse event, actual or alleged causing or risking significant harm to a charity's beneficiaries, staff, volunteers, assets, services, or reputation. Incidents do not need to be proven, of a criminal nature, or public to be reportable; allegations alone may meet the threshold. Trustees must therefore ask whether an issue poses serious risk to the charity, its operations, or those it serves and consider "Significant" in the context of their own charity taking account of its staff, operations, finances and/or reputation.
In the Charity Commission Guidance "Report serious wrongdoing at a charity as a worker or volunteer", the Commission describesexamples of serious harm include:
- if someone's health or safety is in danger, for example, if a charity does not use its safeguarding policy
- a criminal offence, for example theft, fraud or financial mismanagement
- if a charity uses its activities as a platform for extremist views or materials
- loss of charity funds, for example, when a charity loses more than 20% of its income or more than £25,000
- if the charity does not meet its legal obligations, for example, if someone uses a charity for significant personal advantage
In different sectors, serious incidents can take many forms. Heritage sites may face repeated volunteer misconduct complaints; museums may accidentally share school or donor data; or culturally significant objects may go missing. Significant health and safety failures (often where parallel RIDDOR reports are also required) or harmful governance or fundraising lapses also qualify. Trustees are responsible for reporting to the Commission, even when operational tasks are delegated to a third party.
Charities do not need to complete an investigation before filing an SIR. They must act once aware of a potential serious incident. SIR's should be submitted promptly, with updates if new material emerges. Further detail about reporting and the form you need to use can be found:
Reporting or Updating a serious incident
CC47, the Charity Commission's Raising a concern with the Charity Commission (CC47) - GOV.UK guidance,explains what concerns should be raised, how they are prioritised, and the Commission's remit. It focuses on issues causing serious harm to people, significant loss, or misuse of funds or assets, breaches of charity law, or threats to public trust, and directs when other regulators (police, HMRC, ICO, HSE) should be contacted.
The June 2025 update clarified which issues require reporting, the correct channels (Whistleblowing, Serious Incident Reports or material significance) and where other regulators are responsible, without changing trustees 'legal duty to report serious incidents promptly'. CC47 states that when the Commission are making an assessment, they will look at how the trustees have responded to the concerns. For example:
- whether the trustees have met their legal duties to act honestly and reasonably, and solely in the charity's best interests
- what action trustees have taken or propose to take to deal with the issue, including whether they have prioritised the needs of the charity's beneficiaries as a whole
They state that the regulatory action they take will be proportionate to how serious the impact or harm is and will only use significant protective powers, for example, freezing bank accounts and appointing interim managers to the charity, in the most serious cases.
Charities with income over £25,000 must confirm in their annual return that no reportable serious incidents have been left undisclosed, embedding SIR oversight into governance.
A Serious Incident Policy should set thresholds for reporting, internal escalation routes, and decision-making authority. It should reflect evolving regulatory expectations.
The World Vision UK case highlights that culture, governance, and risk rarely exist in isolation. Policies must be supported by wider risk management: insurance including cyber, data protection, and trustee indemnity; effective whistleblowing arrangements; and practical PR and crisis-response plans. Together, these measures transform SIR reporting from a reactive obligation into a marker of mature governance.
Large institutions such as the British Museum, which have faced incidents like the loss of hundreds of artefacts, provide a useful comparison. As stated, trustees of charities with income over £25,000 including World Vision UK and the Museum are required to confirm in the annual return that all reportable serious incidents have been disclosed. SIRs are confidential submissions and do not have to appear in published accounts, so narrative disclosure is optional. A brief review of the Museum's reports between 2022 and 2026 describe governance and risk issues but do not reference SIR filings; nevertheless, timely annual returns indicate regulatory compliance.
The British Museum commissioned an independent review by Sir Nigel Boardman which provided helpful guidance on future proofing their policies and procedures. World Vision UK publicly acknowledged its SIR, demonstrating transparency in addition to compliance. It should be noted that the British Museum case involved potential criminal misconduct and therefore, charity trustees must seek advice in such situations as to what can and cannot be made public without putting any criminal investigation in jeopardy.
The key lesson for trustees is that prompt reporting and proper certification in the annual return are mandatory, while narrative disclosure can be tailored to the specific facts and in line with their trustee obligations (see CC 27 Guidance to trustees).
Charities must see the raised stakes in this new time, a time when even the Commission feels a need to provide guidance on hostile environments (How charities can respond to the current hostile environment - GOV.UK) by ensuring serious incident awareness and whistleblowing protections are fully embedded in governance.
Aside from a considered PR Crisis Management Plan, charities must regularly review all policies especially Serious Incident Policies (and internal reporting forms) and Whistleblowing Policies ensuring they are aligned with employee contracts and volunteer and trustee agreements, to demonstrate that a charity is forward-looking and well-prepared, able to meet challenges with foresight and vision rather than merely reacting when a crisis morphs into a storm of reputational and operational catastrophe.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
