Confusion reigns – is the PCC a charity?

Author: Miss Susan Bunting

Published on: 8 March 2019

Yes! all PCC are charities. Currently PCCs with incomes over £100,000 a year need to register with the Charity Commission.

Smaller PCCs are currently excepted from registering with the Charity Commission by statute which means that they do not have a Registered Charity number. For some grant applications and other purposes, you can supply the Inland Revenue “Gift Aid” claims reference number as a substitute, but you should be clear that this is what you are supplying. The Charity number for Norwich Diocesan Board of Finance Ltd should not be used by a PCC.

Does this mean that PCC members are trustees?

Yes! PCC members fulfil the same roles and have the same responsibilities as trustees.

Does the PCC have to follow the Charity Commission’s Statement of Recommended Practice (SORP) accounting and reporting rules?

Yes, it does. Detailed guidance on this is provided at on the Accounting and Reporting pages.

Are some people excluded from being trustees? Can they be members of the PCC?

Paragraph 46A of the Church Representation Rules should ensure that people are not elected to PCCs, who are disqualified from acting as charity trustees. PCCs should do what is reasonable to ensure that the PCC does not contain any individuals disqualified from acting as a charity trustee and that the persons appointed are suitable. Guidance on eligibility for trustees can be found on the Charity Commission’s website

What reserves are we allowed to keep as a Charity?

Whether you are blessed with significant reserves, or scraping by with nothing spare, every PCC needs to do two things:

1.Develop a policy on the level of reserves and why they are needed

You will need to develop and communicate to the wider church a simple policy on the level of reserves, and what they are being held for. This is recommended “Good Practice” for all charities, and is essential if the church is seeking grant funding at any point. Determining the level of reserves necessary to meet both the current and future needs of the church, will take thought and prayer. The time spent in devising such a policy is likely to be dependent on the level of reserves the PCC holds rather than the size of the congregation or where the church happens to be located. The importance of taking care of reserves applies equally to the small rural parish as well as the large suburban one.

The following documents can be found at

  • A simple guide to Parish Reserves Policies
  • Example Reserves Policies.

2. Decide where your reserves will be invested

However much or little you hold, PCCs will need to decide where its reserves will be invested, even if this is as simple as opening a deposit account for surplus cash. This should be reviewed periodically, particularly when economic circumstances change – either at the parish level, or within the wider economy.

Why spend time thinking about reserves?

This is an important topic for a number of reasons:

  • The principles of accountability and transparency make it important that the members of a PCC are aware of the ‘free reserves’ for which they are responsible.
  • It is good stewardship to ensure these reserves are used to gain maximum benefit for the parish as a whole in its pursuit of the whole mission of their church. The idea of simply keeping some money for a ‘rainy day’ is no longer adequate as a policy.

If you would like to know more or have and questions, please contact or 01603 882377.

The author...

Miss Susan Bunting

Director of Finance

This article is from...

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