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ARTICLE · 31 JULY 2026

Structured Risk Reviews: What Do They Mean For Charities?

Withers LLP
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HMRC has extended its Structured Risk Review process to charities, introducing comprehensive scrutiny across all operational aspects including governance, fundraising, and subsidiary relationships. The review process involves extensive documentation requests and can result in penalties up to 100% of tax liability for identified errors. Charities must maintain robust tax compliance and governance practices as the SRR cannot be adequately prepared for at short notice.

United StatesTax
Alana Petraske
Alana Petraske
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HMRC's Structured Risk Review (SRR) has now been rolled out to charities, marking a significant development in regulatory scrutiny of the not-for-profit sector.

Whilst HMRC has always undertaken reviews of charities, these have generally been focused, limited reviews, such as Gift Aid audits, or overseas payments reviews. By contrast, the SRR is intended to give HMRC a holistic and complete picture of an organisation's operations as a means to ensuring tax compliance.

The scope of an SRR is therefore extensive, potentially across all aspects of a charity's organisational practices, such as governance, fundraising, investment, and relationships with subsidiaries. Charities involved in an SRR can expect HMRC to request wide-ranging documentation, trustee minutes, reports, and bank statements, as well as narrative explanations.

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