Corporate report

The Churches Conservation Trust framework document 2025 to 2028

Published 16 September 2025

© Crown copyright 2025

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Introduction and background

1. Purpose of document

1.1. This framework document (the “framework document”) has been agreed between The Department for Culture, Media and Sport (“DCMS”), The Churches Conservation Trust (“the CCT”) and The Church Commissioners in accordance with HM Treasury’s handbook Managing Public Money (“MPM”) and has been approved by HM Treasury.

1.2. The framework document sets out the broad governance framework within which the CCT and DCMS operate, including with the Church Commissioners. It sets out the CCT’s core responsibilities, describes the governance and accountability framework between DCMS, the CCT and the Church Commissioners and sets out how the day-to-day relationship works in practice, including in relation to governance and financial matters.

1.3. The document does not convey any legal powers or responsibilities but both parties agree to operate within its terms. The CCT and its trustees have duties in charity law and CCT may only act in pursuance of its charitable objects. Nothing in this framework document shall prevent the CCT from carrying out its legal duties under its founding legislation or under any other law which impacts on its functions, activities or powers. The expectations set out here sit alongside the CCT’s statutory and charitable duties expected of staff and trustees. Any perceived conflicts should be brought to the attention of DCMS to discuss an appropriate way forward that ensures the CCT can comply with its statutory and charitable duties.

1.4. While commercial subsidiaries or trading arms are not subject to the same requirements as DCMS itself, the CCT’s Accounting Officers are reminded that Managing Public Money requires them to have meaningful oversight of the trading subsidiary, and that it must not be used to avoid or weaken parliamentary scrutiny.

1.5. Copies of this document and any subsequent amendments have been placed in the libraries of both Houses of Parliament and made available to members of the public on https://www.visitchurches.org.uk and gov.uk.

1.6. This framework document should be reviewed and updated at least every 3 years unless there are exceptional reasons that render this inappropriate that have been agreed with HM Treasury and the Principal Accounting Officer of the sponsor department. The latest date for review and updating of this document is July 2028.

2. Objectives

2.1. DCMS, the CCT and the Church Commissioners share the common objective of preserving our ecclesiastical heritage. To achieve this the CCT, the Church Commissioners and DCMS will work together in recognition of each other’s roles and areas of expertise, providing an effective environment for the CCT to achieve its charitable objectives through the promotion of partnership and trust, and ensuring that CCT also supports the strategic aims and objectives of DCMS and wider government as a whole within its charitable purposes.

2.2. The responsible minister has outlined their priorities for this period in the latest Settlement Letter sent to the CCT. The responsible minister expects all Public Bodies, where reasonable, to align their activities with their general priorities.

2.3. In addition, the CCT has a set of strategic priorities, details of which are set out in the CCT’s Corporate and Business plan.

3. Classification

3.1. The CCT has been classified as a central government organisation by the ONS/HM Treasury Classifications Team.

3.2. The CCT has not been administratively classified by the Cabinet Office.

3.3. The CCT is a ‘Freedoms Body’. This means that it operates under a set of exemptions from, or modifications to, a specific number of financial and operating requirements. These are detailed at Annex B: Cultural Freedoms Bodies’ Freedoms Charter.

3.4. The CCT is a registered charity in England and Wales (charity number 258612).

Purposes, aims and duties

4. Purposes

4.1. The CCT is the successor to the Redundant Churches Fund. It was established as a body corporate by section 57 of the Mission and Pastoral Measure 2011 to preserve, for the nation and the Church of England, churches and parts of churches of historic and archaeological interest or architectural quality which are closed for regular public worship.

5. Powers and duties

5.1. The powers and other duties of the CCT are set out in the Mission and Pastoral Measure 2011. The CCT is also a registered charity and must comply with the relevant regulations, except where the Mission and Pastoral Measure 2011 takes precedence.

  • The CCT’s duty is “the preservation, in the interests of the nation and of the Church of England, of churches and parts of churches of historic and archaeological interest or archaeological quality vested in the Trust, together with their contents so vested” (s. 57(4) of the Mission and Pastoral Measure 2011)

6. Aims

6.1. The CCT’s strategic aims are: 

  • Supporting Communities To Use And Love Their Historic Places of Worship
  • Sharing Our Skills To Sustain Churches
  • Promoting The Value Of Our Shared Cultural Heritage

6.2. The CCT’s vision is:

  • For historic churches to be enjoyed by everyone as places of heritage, culture, spirituality and beauty and for the significant contribution they make to communities, society and the economy.

7. Governance and accountability

7.1. The CCT shall, so far as practicable and in the light of the other provisions of this framework document and of its charitable status, or as otherwise may be mutually agreed, operate corporate governance arrangements that accord with good corporate governance practice and applicable regulatory requirements and expectations.

7.2. In particular (but without limitation), the CCT should:

  • comply with the principles and provisions of the Corporate Governance in Central Government Departments Code of Good Practice (as amended and updated from time to time) to the extent appropriate and in line with their statutory duties or specify and explain any non-compliance in its annual report

  • comply with MPM

  • in line with MPM have regard to the relevant Functional Standards as appropriate and in particular those concerning Finance, Commercial and Counter Fraud

  • take into account the codes of good practice and guidance set out in Annex A of this framework document, as they apply to ALBs

  • comply with their duties under charities law and ecclesiastical law

7.3. In line with MPM Annex 3.1 and the Charities Statement of Recommended Practice, the CCT shall provide an account of corporate governance in its annual governance statement including the Board’s assessment of its compliance with the Code with explanations of any material departures. To the extent that the CCT does intend to materially depart from the Code, the sponsor should be notified in advance.

7.4. Performance Metrics (KPIs) will be mutually agreed between the CCT, DCMS and The Church Commissioners.

7.5. These performance indicators may be reviewed over the duration of this framework document.

Role of the department

8. The responsible Minister

8.1. The responsible Minister is The Secretary of State for Culture, Media and Sport of the United Kingdom. The Secretary of State and other members of the DCMS Ministerial Team are accountable to Parliament for all matters concerning the CCT. For consistency, the Secretary of State is referred to as the responsible Minister throughout this framework document.

Appointments to the Board

8.2. Appointments to the CCT’s Board are made by HM The King on the advice of the Archbishops of Canterbury and York through the Prime Minister. There is no formal role for DCMS Ministers on CCT board appointments, including that of the Chair, because the CCT is not included in the Public Appointments Order in Council. However, DCMS officials work closely with the CCT during the process and the responsible Minister informally appoints one trustee to the board, in recognition of the Department’s role as provider of the majority of the CCT’s statutory funding.

8.3. The Chief Executive of the CCT is appointed by the CCT Board of Trustees, consulting the responsible Minister and Principal Accounting Officer, as required. A DCMS representative should sit on the appointments panel.

  • All such appointments should have regard to the principle that appointments should reflect the diversity of the society in which we live, and appointments should be made taking account of the need to appoint boards which include a balance of skills and backgrounds.

Other Ministerial powers and responsibilities

8.4. The responsible Minister is also responsible for: 

  • agreeing the policy framework within which the CCT operates
  • determining whether it is necessary to read and consider the CCT’s performance framework, strategy and annual Plan, and provide approval as required.
  • matters regarding spending approvals, acquisitions, disposals, and joint ventures in line with delegations as set out in the delegation letter and the freedoms detailed in Annex B
  • such other matters as may be appropriate and proportionate in the interests of the CCT

9. The Principal Accounting Officer

9.1. The Principal Accounting Officer (PAO) is the Permanent Secretary of the Department for Culture, Media and Sport.

PAO’s specific accountabilities and responsibilities

9.2. The PAO designates the Chief Executive as the CCT’s Accounting Officer (AO) and ensures that they are fully aware of their responsibilities. The PAO issues a letter appointing the AO, setting out their responsibilities and delegated authorities.

9.3. The respective responsibilities of the PAO and AOs for ALBs are set out in Chapter 3 of MPM. 

9.4. The PAO is accountable to Parliament for the issue of any grant-in-aid to the CCT. 

9.5. The PAO is also responsible, usually via the sponsorship team, for advising the responsible Minister on:

9.5.1. an appropriate framework of objectives and targets for the CCT in the light of the department’s wider strategic aims and priorities

9.5.2. an appropriate budget for the CCT in the light of the sponsor department’s overall public expenditure priorities

9.5.3. how well the CCT is achieving its strategic objectives and whether it is delivering value for money

9.5.4. the exercise of the Ministers’ statutory responsibilities concerning the CCT as outlined above

9.6 The PAO via the sponsorship team is also responsible for ensuring arrangements are in place in order to:

9.6.1. monitor the CCT’s activities and performance

9.6.2. address significant problems in the CCT, making such interventions as are judged necessary

9.6.3. periodically and at such frequency as is proportionate to the level of risk carry out an assessment of the risks both to the department and the CCT’s objectives and activities in line with the wider departmental risk assessment process

9.6.4. inform the CCT of relevant government policy in a timely manner

9.6.5. bring ministerial or departmental concerns about the activities of the CCT as appropriate to the CCT’s Board of Trustees, requiring explanations and assurances that appropriate action has been taken

10. The role of the sponsorship team

10.1. The DCMS Heritage Team in the department is the primary contact for the CCT. The responsible senior civil servant for this relationship is the Deputy Director with responsibility for heritage at DCMS (the senior sponsor). They are the main source of advice to the responsible Minister on the discharge of their responsibilities in respect of the CCT. They also support the PAO on their responsibilities toward the CCT.

10.2. Officials of the DCMS Heritage team in DCMS will liaise with CCT and Church Commissioner officials to review performance against plans, achievement against targets and expenditure against its DEL and AME allocations. The Heritage Team will also take the opportunity to explain wider policy developments that might have an impact on the CCT.

11. Resolution of disputes between the CCT, DCMS and Church Commissioners

11.1. Any disputes between the department, the CCT and The Church Commissioners will be resolved in as timely a manner as possible. The Department, the CCT and the Church Commissioners will seek to resolve any disputes through an informal process in the first instance. If this is not possible, then a formal process, overseen by the senior sponsor, will be used to resolve the issue. Failing this, the senior sponsor will ask the relevant policy Director General to oversee the dispute. They may then choose to ask the Permanent Secretary to nominate a non-executive member of the Department’s Board to review the dispute, mediate with both sides and reach an outcome, in consultation with the responsible Minister.

12. Freedom of Information and other data requests

12.1. Where a request for information is received by any of the parties to this framework document under the Freedom of Information Act 2000, or the Data Protection Act 1998 or 2018, the party receiving the request will consult with the other party prior to any disclosure of information that may affect the other party’s responsibilities.

13.1. The CCT shall update sponsors at the regular partnership meetings on the existence of any active litigation and any threatened or reasonably anticipated litigation. The parties acknowledge the importance of ensuring that legal risks are communicated appropriately to the sponsor in a timely manner.

13.2. In respect of each substantial piece of litigation involving the CCT, the parties will agree to appropriate and timely reporting on the status of the litigation.The parties will ensure that:

  • legally privileged documents and information are clearly marked as such
  • steps are taken to ensure that legal privilege is not waived, including ensuring any circulation within Government is limited to that which is strictly necessary

The CCT governance structure

14. The Chief Executive

Responsibilities of the chief executive as accounting officer

14.1. The Chief Executive is appointed by the Board of Trustees of the CCT and as AO is personally responsible for safeguarding the public funds for which they have charge; for ensuring propriety, regularity, value for money and feasibility in the handling of those public funds; and for the day-to-day operations and management of the CCT. In addition, they should ensure that the CCT as a whole is run on the basis of the standards, in terms of governance, decision-making and financial management, that are set out in Box 3.1 of MPM. These responsibilities include the below and those that are set in the AO appointment letter issued by the PAO of the sponsor department.

Responsibilities for accounting to Parliament and the public

14.2. Responsibilities to Parliament and the public include:

  • signing the accounts and ensuring that proper records are kept relating to the accounts and that the accounts are properly prepared and presented in accordance with any directions issued by the responsible minister
  • preparing and signing a Governance Statement covering corporate governance, risk management and oversight of any local responsibilities, for inclusion in the annual report and accounts
  • ensuring that effective procedures for handling complaints about the CCT in accordance with Parliamentary and Health Service Ombudsman’s Principles of Good Complaint Handling are established and made widely known within the CCT and published the CCT’s website]
  • acting in accordance with the terms of MPM and other instructions and guidance issued from time to time by the department, the Treasury and the Cabinet Office

  • ensuring that as part of the above compliance they are familiar with and act in accordance with:

    •  any governing legislation
    • this framework document
    • any delegation letter issued to the CCT as set out in paragraph 18.1
    • any elements of any settlement letter issued to the sponsor department that is relevant to the operation of the CCT
    • any separate settlement letter that is issued to the CCT from the sponsor department
    •  the CCT’s other governing documents
  • ensuring they have appropriate internal mechanisms for monitoring, governance and external reporting regarding non-compliance with any conditions arising from the above documents
  • giving evidence, normally with the PAO, when summoned before the PAC on the CCT’s stewardship of public funds

Responsibilities to The Department for Digital, Culture, Media and Sport

14.3. Responsibilities to DCMS include: 

  • prior to publication, presenting the CCT’s corporate and business plans to the department to demonstrate that these plans reflect the department’s wider strategic aims and agreed priorities;
  • informing the department of progress in helping to achieve DCMS’s policy objectives which coincide with the CCT’s charitable purposes and in demonstrating how resources are being used to achieve those objectives;
  • ensuring that timely forecasts and monitoring information on performance and finance are provided to DCMS; that the department is notified promptly if over or under spends are likely and that corrective action is taken; and that any significant problems whether financial or otherwise, and whether detected by internal audit or by other means, are notified to the department in a timely fashion;
  • working collectively with the department and other members of the DCMS Public Bodies group in support of each other and the group as a whole.

Responsibilities to the Board of Trustees

14.4. The Chief Executive is responsible for:

  • advising the Board of Trustees on the discharge of their responsibilities as set out in this document, in charity law and in compliance with the CCT’s governing document, the founding legislation and in any other relevant instructions and guidance that may be issued from time to time

  • advising the Board of Trustees on the CCT’s performance compared with its aims and objectives

  • ensuring that financial considerations are taken fully into account by the Board of Trustees at all stages in reaching and executing its decisions, and that financial appraisal techniques are followed; and

Managing conflicts

14.5. The Chief Executive should follow the advice and direction of the Board, except in very exceptional circumstances with a clear cut and transparent rationale for not doing so. 

14.6. If the Board, or its Chair, is contemplating a course of action involving a transaction which the Chief Executive considers would infringe the requirements of propriety or regularity or does not represent prudent or economical administration, efficiency or effectiveness, is of questionable feasibility, or is unethical, the Chief Executive in their role as AO should reject that course of action and ensure that the Board have a full opportunity to discuss the rationale for that rejection.

14.7. If the Chair or Board of the CCT is minded to instruct its AO to carry out a course inconsistent with their duties as AO, then the CCT AO should make their reservations clear, preferably in writing. If the Board is still minded to proceed, the CCT AO should then:

  • ask the PAO of the sponsor department to consider intervening to resolve the difference of view, preferably in writing 
  • if the Board’s decision stands, seek its written direction to carry it out, asking DCMS to inform HM Treasury
  • proceed to implement without delay
  • follow the routine in paragraph 3.6.6 of MPM.

15. The Board of Trustees

Composition of the Board of Trustees

15.1. The CCT will have a board of trustees in line with good standards of corporate governance and as set out in its establishing statute and in guidance as set out in Annex A. The role of the board shall be to run the CCT, and to deliver the charitable objectives, in accordance with the purposes as set out above, their statutory, regulatory, charity law and common law duties and their responsibilities under this framework document and any other governing documents. Detailed responsibilities of the board shall be set out in the Board terms of reference. Remuneration of the Board will be disclosed in line with the guidance in the Government Financial Reporting manual (FReM).

15.2. The Board will consist of members whose skills and experience align with the strategic direction of the CCT, such as fundraising, education, community engagement, finance, legal issues, operational delivery, corporate services such as HR, technology, property asset management, estate management, communications and performance management. The CCT Board shall consist of a Chair and not less than four nor more than eleven other members, and the Chair and other members shall be appointed by His Majesty, and before any such appointment the advice of the Archbishops of Canterbury and York shall be submitted to His Majesty through the Prime Minister.

Board Committees

15.3. The Board may set up such committees as necessary for it to fulfil its functions. As is detailed below at a minimum this should include an Audit and Risk Committee chaired by an independent and appropriately qualified non-executive member of the Board. 

15.4. Where there is disagreement between the relevant committee and the Board, adequate time should be made available for discussion of the issue with a view to resolving the disagreement. Where any such disagreement cannot be resolved, the committee concerned should have the right to report the issue to the sponsor team, PAO and responsible Minister. They may also seek to ensure the disagreement or concern is reflected as part of the report on its activities in the annual report.

15.5. The Chair should ensure board committees are properly structured with appropriate terms of reference. The terms of each committee should set out its responsibilities and the authority delegated to it by the Board. The Chair should ensure that committee membership is periodically refreshed.

Duties of the Board of trustees

15.6. The board of trustees is specifically responsible for: 

  • establishing and taking forward the strategic aims and objectives of the CCT, consistent with its overall strategic direction, charitable aims, taking account of the policy and resources framework determined by the responsible Minister and The Church Commissioners. 
  • providing effective leadership of the CCT within a framework of prudent and effective controls which enables risk to be assessed and managed
  • ensuring the financial and human resources are in place for the CCT to meet its objectives
  • reviewing management performance
  • ensuring that the Board receives and reviews regular financial and management information concerning the management of the CCT
  • ensuring that it is kept informed of any changes which are likely to impact on the strategic direction of the CCT or on the attainability of its targets, and determining the steps needed to deal with such changes and where appropriate bringing such matters to the attention of the responsible Minister and PAO via sponsorship team or directly
  • ensuring that any statutory or administrative requirements for the use of public funds are complied with; that the Board operates within the limits of its statutory authority and any delegated authority agreed with the sponsor department, and in accordance with any other conditions relating to the use of public funds
  • ensuring that in reaching decisions, the Board takes into account guidance issued by the sponsor department

  • ensuring that as part of the above compliance they are familiar with:

    • this framework document
    • their duties as trustees under charity law
    • any delegation letter issued to the CCT as set out in paragraph 18.1
    • any elements of any settlement letter issued to the sponsor department that is relevant to the operation of the CCT
    • any separate settlement letter that is issued to the CCT from the sponsor department
    • that they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding any conditions arising from the above documents and ensure that the Chief Executive and the CCT as a whole act in accordance with their obligations under the above documents
  • demonstrating high standards of corporate governance at all times, including by using external expertise or an independent audit committee to help the board to address key financial and other risks
  • appointing a Chief Executive and, in consultation with the department, setting performance objectives and remuneration terms linked to these objectives for the Chief Executive which give due weight to the proper management and use and utilisation of public resources
  • putting in place mechanisms for independent appraisal and annual evaluation of the performance of the Chair, taking into account the views of relevant stakeholders. The outcome of that evaluation should be made available to the responsible Minister
  • putting in place mechanisms for the Chief Executive to have visibility of Board activity with sufficient time before Board decisions are agreed. The mechanism will enable the Chief Executive to take action where needed as per paragraph ‘Managing conflicts’
  • determining all such other things which the Board considers ancillary or conducive to the attainment or fulfilment by the CCT of its objectives, including its charitable purposes

15.7. The Board should ensure that effective arrangements are in place to provide assurance on risk management, governance and internal control. 

15.8. The Board should make a strategic choice about the style, shape and quality of risk management and should lead the assessment and management of opportunity and risk. The Board should ensure that effective arrangements are in place to provide assurance over the design and operation of risk management, governance and internal control in line with the Management of Risk – Principles and Concepts (The Orange Book).

15.9. The Board must set up an Audit and Risk Assurance Committee chaired by a suitably experienced or qualified trustee member/an independent and appropriately qualified non-executive member to provide independent advice and ensure that the department’s Audit and Risk Assurance Committee are provided with routine assurances with escalation of any significant limitations or concerns. The Board is expected to assure itself of the adequacy and effectiveness of the risk management framework and the operation of internal control.

16. The Chair’s role and responsibilities

16.1. The Chair is responsible for leading the board in the delivery of its responsibilities. Such responsibility should be exercised in the light of their duties and responsibilities as set out in their appointment letter, the priorities in the chair’s letter issued to them by the sponsor team, the statutory authority governing the CCT’s governing documents and charity law, this framework document and the documents and guidance referred to within this framework document.

16.2. Communications between the CCT’s Board and the responsible Minister should normally be through the Chair.  

16.3. The Chair is bound by the Code of Conduct for Board Members of Public Bodies, which covers conduct in the role and includes the Nolan Principles of Public Life.

16.4. In addition, the Chair is responsible for: 

  • ensuring (including by monitoring and engaging with appropriate governance arrangements) that the CCT’s affairs are conducted with probity
  • ensuring that policies and actions support the responsible Minister’s wider strategic policies and where appropriate, these policies and actions should be clearly communicated and disseminated throughout the CCT.

16.5. The Chair has the following leadership responsibilities: 

  • formulating the Board’s strategy
  • ensuring that the Board, in reaching decisions, takes proper account of guidance provided by the responsible Minister or the department
  • promoting the efficient and effective use of staff and other resources
  • delivering high standards of regularity and propriety
  • representing the views of the board to the general public

16.6. The Chair also has an obligation to ensure that:

  • the work of the Board and its members are reviewed and are working effectively including ongoing assessment of the performance of individual board members with a formal annual evaluation and more in-depth assessments of the performance of individual board members when being considered for re-appointment
  • that in conducting assessments that the view of relevant stakeholders including employees and the sponsorship team are sought and considered 
  • that the Board has a balance of skills appropriate to directing the CCT’s business, and that all trustees (including the Chair) and the Chief Executive continually update their skills, knowledge and familiarity with the CCT to fulfil their role both on the Board and committees. This will include but not be limited to skills and training in relation to financial management and reporting requirements, risk management and the requirements of board membership within the public sector
  • board members are fully briefed on terms of appointment, duties, rights and responsibilities
  • they, together with the other board members, receives appropriate training on financial management and reporting requirements and on any differences that may exist between private and public sector practice
  • the responsible Minister is advised of the CCT’s needs when board vacancies arise
  • there is a Board Operating Framework in place setting out the role and responsibilities of the board consistent with the Government Code of Good Practice for Corporate Governance 
    • there is a code of practice for board members in place, consistent with the Cabinet Office Code of Conduct for Board Members of Public Bodies
  • In line with best practice, the Chair’s performance will be appraised annually by DCMS, factoring in the views of board members and the Chair’s self-appraisal.

17. Individual trustees’ responsibilities

17.1. Individual trustees should: 

  • comply at all times with the  Code of Conduct for Board Members of Public Bodies, which covers conduct in the role and includes the Nolan Principles of Public Life as well as rules relating to the use of public funds and to conflicts of interest
  • demonstrate adherence to the 12 Principles of Governance for all Public Body Non-Executive Directors as appropriate
  • not misuse information gained in the course of their public service for personal gain or for political profit, nor seek to use the opportunity of public service to promote their private interests or those of connected persons or organisations
  • comply with the Board’s rules on the acceptance of gifts and hospitality, and of business appointments
  • act in good faith and in the best interests of the CCT
  • ensure they are familiar with any applicable guidance on the role of public sector non-executive directors and boards that may be issued from time to time by the Cabinet Office, HM Treasury or wider government
  • ensure that they are familiar with guidance on the duties of trustees under charity law 
  • comply with the CCT’s governing document

Management and financial responsibilities and controls

18. Delegated authorities

18.1. The CCT’s delegated authorities are set out in the delegation letter issued annually at the start of a new Financial Year. This delegation letter may be updated and superseded by later versions which may be issued by the sponsor department in agreement with HM Treasury.

18.2. In line with MPM Annex 2.2 these delegations will be reviewed on an annual basis.

18.3. The CCT shall obtain the department’s and where appropriate HM Treasury’s prior written approval before: 

  • entering into any undertaking to incur any expenditure that falls outside the delegations or which is not provided for in the CCTs annual budget as approved by the department
  • incurring expenditure for any purpose that is or might be considered novel or contentious, or which has or could have significant future cost implications
  • making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by the department
  • making any change of policy or practice which has wider financial implications that might prove repercussive or which might significantly affect the future level of resources required
  • carrying out policies that go against the principles, rules, guidance and advice in MPM

19. Spending authority

19.1. Once the budget allocation has been approved by the sponsor department and subject to the conditions of the Funding Order for each given financial year, the CCT shall have authority to incur expenditure approved in the budget and in line with their freedoms as set out in Annex B without further reference to the sponsor department, on the following conditions:

  • the CCT shall comply with the delegations set out in the delegation letter. These delegations shall not be altered without the prior agreement of the sponsor department and as agreed by HM Treasury and Cabinet Office as appropriate
  • the CCT shall comply with MPM regarding novel, contentious or repercussive proposals
  • inclusion of any planned and approved expenditure in the budget shall not remove the need to seek formal departmental approval where any proposed expenditure is outside the delegated limits or is for new schemes deviating significantly from activities and expenditure anticipated in the Corporate and/or Strategic Plan
  • the CCT shall provide the sponsor department with such information about its operations, performance, individual projects or other expenditure as the sponsor department may reasonably require.

20. Banking and managing cash

20.1. As a Freedoms Body [see Annex B], the CCT does not need explicit approval from DCMS to change banking provider, but should provide written notification to DCMS upon doing so.

20.2. The AO is responsible for ensuring the CCT has a banking policy as set out in MPM and ensuring that policy is complied with.

21. Procurement

21.1. As a Freedoms Body the CCT has the flexibility to opt in and out of central procurement and is exempt from a number of other spend controls [see Annex C for details]. Nonetheless, the following standards of good practice apply.

21.2. The Churches Conservation Trust will ensure that its procurement policies are aligned with and comply with any relevant UK or other international procurement rules and in particular the current Public Procurement Regulations (For Example but not exclusive to Public Contracts Regulations 2015 and Procurement Act 2023).

21.3. The CCT shall establish its procurement policies and document these in a Procurement Policy and Procedures Manual. 

21.4. In procurement cases where the CCT is likely to exceed its delegated authority limit, and where the relevant Freedom exemption does not apply, procurement strategy approval for the specific planned purchase must be sought from the department’s sponsor team.

21.5. Goods, services, and works should be acquired by competition where necessary and appropriate. Proposals to let direct award or restricted contracts shall be limited and exceptional. The direct award financial Threshold value (where no competition has taken place to select a supplier) is set at £139,000 (ex VAT) for each contract or requirement.

21.6. Where appropriate and proportionate, procurement by the Churches Conservation Trust of works, equipment, goods, and services shall be based on a full option appraisal and value for money (VfM), i.e. the optimum combination and whole life costs and quality (fitness for purpose). The delegated limit for director award contracts is set out in clause. The Churches Conservation Trust must comply with the direct award process as outlined and as otherwise communicated to them by the Department.

21.7. The CCT shall:

  • engage fully with department and government wide procurement initiatives that seek to achieve VfM from collaborative projects
  • comply with all relevant Procurement Policy Notes issued by Cabinet Office
  • cooperate fully with initiatives to improve the availability of procurement data to facilitate the achievement of VfM

21.8. The CCT shall comply with the commercial operating standards and grants standards. These standards apply to the planning, delivery, and management of government commercial activity, including management of grants in all departments and ALBs, regardless of commercial approach used and form part of a suite of functional standards that set expectations for management within government.

22. Risk management

22.1. The CCT shall ensure that the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and develop a risk management strategy, in accordance with the Treasury guidance Management of Risk: Principles and Concepts.

22.2. The CCT will allow for risk-based DCMS involvement in Audit and Risk Committee meetings.

23. Counter fraud and theft

23.1. The CCT should adopt and implement policies and practices to safeguard itself against fraud and theft.

23.2. The CCT should act in line with guidance as issued by the Counter Fraud Function and in compliance with the procedures and considerations as set in in MPM Annex 4.9 and the Counter Fraud Functional Standard. It should also take all reasonable steps to appraise the financial standing of any firm or other body with which it intends to enter a contract or to provide grant or grant-in-aid.

23.3. The CCT should keep records of and prepare and forward to the department an annual report on fraud and theft suffered by the CCT and notify the sponsor department of any unusual or major incidents as soon as possible. The CCT should also report detected loss from fraud, bribery, corruption and error, alongside associated recoveries and prevented losses, to the counter fraud centre of expertise in line with the agreed government definitions as set out in Counter Fraud Functional Standard.

24. Staff

Broad responsibilities for staff 

24.1. Within the arrangements approved by the responsible Minister [and the Treasury] and subject to any relevant Freedom, the CCT will have responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities toward its staff are to ensure that: 

  • the rules for recruitment and management of staff create an inclusive culture in which diversity is fully valued; appointment and advancement is based on merit; there is no discrimination against employees with protected characteristics under the Equality Act 2010 
  • the level and structure of its staffing, including grading and staff numbers, are appropriate to its functions and the requirements of economy, efficiency and effectiveness
  • the performance of its staff at all levels is satisfactorily appraised and the CCT performance measurement systems are reviewed from time to time
  • its staff are encouraged to acquire the appropriate professional, management and other expertise necessary to achieve the CCT’s objectives
  • proper consultation with staff takes place on key issues affecting them
  • adequate grievance and disciplinary procedures are in place
  • whistle-blowing procedures consistent with the Public Interest Disclosure Act are in place
  • a code of conduct for staff is in place based on the Cabinet Office’s Model Code for Staff of Executive Non-departmental Public Bodies.

Staff costs

24.2. Subject to its delegated authorities, the CCT shall ensure that the creation of any additional posts does not incur forward commitments that will exceed its ability to pay for them.

Pay and conditions of service

24.3. The CCT’s staff are subject to appropriate levels of remuneration and terms and conditions of service (including pensions). As a Freedom Body the CCT will not be subject to the Public Sector Civil Service Pay Remit Guidance (“PRG”) and will have the ability to offer average pay awards in excess of caps set out in this guidance.that  They shall continue to engage with their Sponsor Department during the process of making a pay remit application, particularly prior to completion. They shall also continue to provide outturn data to HM Treasury and adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office. 

24.4. If civil service terms and conditions of service apply to the rates of pay and non-pay allowances paid to the staff and to any other party entitled to payment in respect of travel expenses or other allowances, payment shall be made in accordance with the Civil Service Management Code except where prior approval has been given by the department to vary such rates. 

24.5. Staff terms and conditions should be set out and available to both staff and DCMS if requested. 

24.6. The CCT shall continue to adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office, including the Senior Pay guidance.

24.7. The travel expenses of board members shall be tied to the rates allowed to senior staff of the CCT. Reasonable actual costs shall be reimbursed.

Pensions, redundancy and compensation

24.8. Compensation scheme rules and pension scheme rules should reflect legislative and HM Treasury guidance requirements regarding exit payments.

24.9. The CCT staff shall normally be eligible for a pension provided by its own scheme. Staff may opt out of the occupational pension scheme provided by the CCT. As a Freedoms Body the CCT has the right to opt out of the Principal Civil Service Pension Scheme for new starters. 

24.10. Any proposal by the CCT to pay any redundancy or compensation for loss of office requires the prior approval of the department. Proposals on severance must comply with the rules in chapter 4 of MPM.

Business plans, financial reporting and management information

25. Corporate and business plans

25.1. The CCT shall share with the department its multi-year strategic plans in advance of publication, and provide annual progress updates. The plan shall reflect the CCT’s statutory and/or other duties, its charitable purposes, and indicate where it supports the priorities set from time to time by the responsible Minister (including decisions taken on policy and resources in the light of wider public expenditure decisions). The plan shall demonstrate how the CCT contributes to the achievement of the department’s medium-term plan and priorities and aligned performance metrics and milestones in line with its charitable objectives.  

25.2. The business plan shall include measurable targets and milestones, strategies for achieving them, and demonstrate how these contribute to the department’s priorities. It should identify SROs and resources for critical projects, and underpinning activities such as workforce reform. It should include a forecast of income and expenditure suitably classified by activity and key objectives, taking account of guidance on resource assumptions and policies provided by the Department at the beginning of the planning round. These forecasts should represent the CCT’s best estimate of its available income, including any grant or grant in aid or any other funding within the CCT.

25.3. The following key matters should, where necessary and relevant, be included in the plans: 

  • key objectives and associated key performance targets for the forward years, and the strategy for achieving those objectives 
  • key non-financial performance targets 
  • a review of performance in the preceding financial year, together with comparable outturns for the previous 2-5 years, and an estimate of performance in the current year
  • alternative scenarios and an assessment of the risk factors that may significantly affect the execution of the plan but that cannot be accurately forecast
  • other matters as agreed between the department and the CCT

26. Budgeting procedures

26.1. Each year, in the light of decisions by the department on the updated draft corporate plan, the department will send to the CCT within an agreed timetable:

  • a formal statement of the annual budgetary provision allocated by the department in the light of competing priorities across the department and of any forecast income approved by the department
  • a statement of any planned change in policies affecting the CCT

26.2. The annual business plan will take account both of approved funding provision [where this applies] and [where this applies] any forecast receipts. It will include a budget of estimated payments and receipts together with a profile of expected expenditure and of draw-down of any departmental funding and/or other income over the year. These elements form part of the business plan for the year in question.

27. Grant-in-aid and any ring-fenced grants

27.1. Any grant-in-aid provided by the department for the year in question will be voted in the department’s Supply Estimate and be subject to parliamentary control. 

27.2. The grant-in-aid will normally be paid in monthly instalments on the basis of written applications showing evidence of need. The CCT will comply with the general principle, that there is no payment in advance of need. Cash balances accumulated during the course of the year from grant-in-aid or other Exchequer funds shall be kept to a minimum level consistent with the efficient operation of the CCT. Grant-in-aid not drawn down by the end of the financial year shall lapse.

27.3. In the event that the department provides the CCT separate grants for specific (ring-fenced) purposes, it will issue the grant as and when the CCT needs it on the basis of a written request. The CCT shall provide evidence that the grant was used for the purposes authorised by the department. The CCT shall not have uncommitted grant funds in hand, nor carry grant funds over to another financial year.

28. Annual report and accounts

28.1. The CCT Board must prepare annual reports and accounts following the direction given by the Sponsor department (or HM Treasury) in line with Government Resource and Accounts Act 2000 (or the entity’s relevant legislation).

28.2. Information on performance against key financial targets is included within the annual report and subject to the auditor’s consistency opinion. The report and accounts shall be laid in Parliament and laid at General Synod, and made available on the CCT’s website, in accordance with the guidance in the FReM.

29. Reporting performance to the department

29.1. The CCT shall operate management, information and accounting systems that enable it to review in a timely and effective manner its financial and non-financial performance against the budgets and targets set out in the corporate and business plans. 

29.2. The CCT shall inform the sponsor department of any changes that make achievement of objectives more or less difficult. It shall report financial and non-financial performance, including performance in helping to deliver Ministers’ policies, and the achievement of key objectives regularly.

29.3. The CCT’s performance shall be formally reviewed by DCMS and The Church Commissioners twice a year. These Tripartite Meetings will cover either a six month or full year performance review that includes a discussion of the CCT management accounts and the CCT risk register. 

29.4. The responsible Minister will meet the Chair and Chief Executive ideally once a year.

29.5. The PAO will meet the Chief Executive at least once a year.

30. Information sharing

30.1. The department has the right of access to all the CCT’s records and personnel for any purpose including, for example, sponsorship audits and operational investigations. However, a Data Sharing Agreement/MoU will be required prior to the transfer of any personal data. The department does not have a data sharing agreement with The Church Commissioners.

30.2. The CCT shall provide the sponsor department with such information about its operations, performance, individual projects or other expenditure as the sponsor department may reasonably require.

30.3. The department and HM Treasury may request the sharing of data held by the CCT in such a manner as set out in central guidance except where it is prohibited by law. This may include requiring the appointment of a senior official to be responsible for the data sharing relationship.

30.4. As a minimum, the CCT shall provide the department with information monthly that will enable the department satisfactorily to monitor:

  • the CCT’s cash management
  • its draw-down of grant-in-aid
  • forecast outturn by resource headings
  • other data required for the Online System for Central Accounting and Reporting (OSCAR)
  • data as required in respect of its compliance with any applicable Cabinet Office Controls pipelines or required in order to meet any condition as set out in any settlement letter

Audit

31. Internal audit

31.1. The CCT shall: 

  • establish and maintain arrangements for internal audit
  • ensure that any arrangements for internal audit are in accordance with the Public Sector Internal Audit Standards (PSIAS) as adopted by HM Treasury.
  • ensure the sponsor department is satisfied with the competence and qualifications of the Head of Internal Audit and the requirements for approving appointments in accordance with PSIAS
  • set up an audit committee of its board in accordance with the Code of Good Practice for Corporate Governance and the Audit and Risk Assurance Committee Handbook
  • forward the audit strategy, periodic audit plans and annual audit report, including the CCT’s Head of Internal Audit opinion on risk management, control and governance as soon as possible to the sponsor department
  • keep records of and prepare and forward to the department an annual report on fraud and theft suffered by the CCT and notify the sponsor department of any unusual or major incidents as soon as possible
  • will share with the sponsor department information identified during the audit process and the Annual Audit Opinion Report (together with any other outputs) at the end of the audit, in particular on issues impacting on the department’s responsibilities in relation to financial systems within the CCT

32. External audit

32.1. The CCT’s audited accounts are passed to the responsible Minister, who will lay the accounts before parliament. CCT must consult with the NAO on the appointment of a new auditor, with the NAO being offered the opportunity to audit the CCT’s accounts. Where the NAO declines this role, they should instead be kept informed about the identity of the new auditors.

32.2. Subject to any overriding legal rights or obligations, DCMS has the right of access to all the CCT records and personnel for any purpose including, for example, sponsorship audits and operational investigations.

32.3. Any differences of opinion or approach arising between DCMS and the CCT [as to audit] should be resolved between the CCT and the sponsoring team in the first instance. Should the difference not be resolved in this way, it should be referred to DCMS’s Public Body team, who will advise on the appropriate escalation process. Irreconcilable issues will be resolved between the PAO and AO, or the Minister and Chair of the CCT as appropriate.

Reviews and winding up arrangements

33. Review of the CCT’s status

33.1. The CCT will be reviewed as part of the wider Public Bodies Reviews programme, at a time determined by the department’s ministers and their PAO.

34. Arrangements in the event that the CCT is wound up

34.1. DCMS shall put in place arrangements to ensure the orderly winding up of the CCT in accordance with its governing document. In particular it should ensure that the assets and liabilities of the CCT are passed to any successor charitable organisation with similar charitable purposes and accounted for properly. Where appropriate, any assets wholly or partly funded by grants or grants-in-aid from the sponsor department may revert to the sponsoring department to the extent that valid and legally enforceable conditions have been imposed at the time of the grant. In the event that there is no successor charitable organisation, the assets and liabilities should be passed to a charity with similar charitable objects. To this end, the department shall: 

  • have regard to Cabinet Office guidance on winding up of ALBs
  • ensure that procedures are in place in the CCT to gain independent assurance on key transactions, financial commitments, cash flows and other information needed to handle the wind-up effectively and to maintain the momentum of work inherited by any residuary body
  • specify the basis for the valuation and accounting treatment of the CCT’s assets and liabilities
  • ensure that arrangements are in place to prepare closing accounts and pass to the C&AG for external audit, and that, for non-Crown bodies funds are in place to pay for such audits. It shall be for the C&AG to lay the final accounts in Parliament, together with his report on the accounts
  • arrange for the most appropriate person to sign the closing accounts. In the event that another charitable ALB takes on the role, responsibilities, assets and liabilities, the succeeding ALB AO should sign the closing accounts. In the event that the department inherits any assets and liabilities, the sponsor department’s AO should sign

34.2. The CCT shall provide the department with full details of all agreements where the CCT or its successors have a right to share in the financial gains of developers. It should also pass to the department details of any other forms of claw-back due to the CCT.

34.3. The Church Commissioners and Church of England Legal Office shall provide advice to DCMS and the CCT on an appropriate winding-up process consistent with the Mission and Pastoral Measure 2011 and with ecclesiastical law, in respect of the disposal of church buildings vested in the CCT.

Signatures

Ruth Hannant and Polly Payne
Directors General, Policy, DCMS
Date: 21 August 2025

Greg Pickup
Chief Executive, Churches Conservation Trust
Date: 20 August 2025

Annex A: Guidance

The CCT shall comply with the following guidance, documents and instructions unless subject to an explicit exemption as a consequence of their status as a Freedoms Body:

Corporate governance

Financial management and reporting

Management of risk

Commercial management

Public appointments

The following are relevant where public bodies participate in public appointments processes.

Staff and remuneration

General

Charity law

Annex B: Cultural Freedoms Bodies’ Freedoms Charter (May 2023)

Background

The ‘Operational Freedoms’ are a set of exemptions from, or modifications to, a discrete number of financial and operating requirements applying to a group of arm’s length bodies (ALBs)[footnote 1]. These ‘Freedoms Bodies’ have been granted these flexibilities in recognition of their distinct public-facing role and hybrid public/commercial funding model.

The following set of Freedoms was approved by HM Treasury and Cabinet Office on 26 April 2023. This document is an updated version of the Charter that was previously agreed by those parties and the Freedoms Bodies’ Sponsor Departments in Q1 2022/23[footnote 2].

It will be reviewed in Q3 2024/25, or at the next Spending Review, whichever is sooner. The Freedoms are extended at HM Government’s discretion and may be paused or withdrawn where circumstances dictate.

Freedoms- at a glance

Financial freedoms

1. Freedom to maintain and spend reserves of self-generated income.

2. Freedom to invest non-grant income.

3. Exemption from the requirement to use the Government Banking Service.

4. The power to borrow through voted loans from sponsoring departments.

5. Favourable consideration of requests for Departmental Expenditure Limit (DEL) cover to meet exceptional depreciation charges.

6. Freedom to offer pay awards in excess of caps set out in the Pay Remit Guidance.

7. Freedom to opt out of the Principal Civil Service Pension Scheme for new starters.

Spend control freedoms

8. Flexibility to opt in or out of central procurement on a case by case basis.

9. Exemption from advertising, marketing, and communications spend controls.

10. Exemption from the commercial spend control.

11. Exemption from property spend controls.

12. Exemption from facilities management spend controls.

Increases to delegated limits

13. Digital and Technology spend.

14. Self-funded capital projects (HMT delegated limit for DCMS Freedom Bodies only).

Financial freedoms

1. Freedom to maintain and spend reserves of self-generated income

HM Treasury will provide Freedoms Bodies with budgetary cover (for both Resource and Capital spend) for the required use of reserves. It will be based on Freedom Body forecasts and made via Supplementary Estimates. The use of reserves in excess of the allocation will be considered an overspend for which Bodies must alert DCMS/relevant department as early as possible.

2. Freedom to invest non-grant income

Freedoms Bodies are free to invest non grant income in line with the relevant Charity Commission guidance on investments.

3. Exemption from the requirement to use the Government Banking Service

Freedoms Bodies are exempt from the requirement to use the Government Banking Service (GBS). They will continue to provide DCMS/relevant department (“The Department”) with the normal monthly forecasts including the amount of cash held in their bank accounts. They should also continue to seek help and guidance from the GBS to help negotiate value for money banking contracts.

Where Freedoms Bodies elect to open non-GBS accounts, formal HM Treasury approval is not required, but Bodies must inform The Department and provide them with balances held in these accounts at set times during the year as communicated to them by the Department.

4. The power to borrow through voted loans from sponsoring departments

Freedom Bodies have the power to borrow to access seed funding which can be used for cost savings measures and to develop revenue raising projects.

Loans will be made available to Freedom Bodies by The Department up to a limit of £60m per year (across all Freedoms Bodies) and no longer than 25 years in length.

DCMS will include all requests within its Supplementary Estimates return to HM Treasury. Freedoms Bodies may request loans during each financial year up until the Supplementary Estimates return is submitted. Cash can however be made available ahead of Supplementary Estimates as HMT approval at Supplementary Estimates is assumed if DCMS provides the necessary approval to the loan request.

Loan requests from Freedoms Bodies will require a single-stage business case submission to be approved by The Department. If the loan request forms part of a larger business case, the request should be incorporated into an appropriate business case stage (although no earlier than Outline Business Case) . The Department will review any loan requests at an appropriate Committee that aligns with the value of the request.

5. Favourable consideration of requests for additional budgetary cover to meet exceptional depreciation charges

In exceptional circumstances, the impact of depreciation may result in a breach of the HM Treasury ring-fenced budgetary total. The Department will ensure it retains sufficient cover for any known depreciation charges and will explore avenues to manage exceptional depreciation charges within the delegated control totals. It may be for example that requests for additional budgetary cover can be made outside of the supplementary estimates window.

In the unlikely event that this is not possible, the Department would ask HM Treasury to look favourably on any breach caused by these circumstances.

Freedoms Bodies should proactively notify their Department if such an event is anticipated, so that HMT can be informed and remedies can be explored.

6. Freedom to offer average pay awards in excess of caps set out in the Pay Remit Guidance

Freedom Bodies are not subject to the Pay Remit Guidance (“PRG”). However they shall continue to engage with their Sponsor Department during the process of making a pay remit application, particularly prior to completion. They shall also continue to provide outturn data to HM Treasury and adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office. This freedom can include multi-year pay settlements as long as they are affordable and this does not prejudice future spending reviews.

This Freedom may be paused under extraordinary future circumstances, and should be reviewed as part of Spending Reviews.

7. Freedom to opt out of the Principal Civil Service Pension Scheme for new starters

Bodies may close, or amend the eligibility criteria to restrict access to the Civil Service Pension Schemes (CSPS) for new members. Current active and non-contributory members will be allowed to continue to accrue and receive their respective benefits. The CSPS closes completely once the last active scheme employee leaves the organisation.

The decision to use this Freedom will be taken by the Body’s Board of Trustees.

To take advantage of this Freedom, Bodies should first consult with The Department, setting out the case for the proposed course of action. They must also confirm that:

(a) relevant statutory requirements have been followed; (b) agreed Trade Union/Management negotiating processes have been undertaken as part of the consultation with staff; (c) a reasonable number of alternative pension providers have been considered to ensure good value.

Following this process, the Freedom Body will need to liaise with the Cabinet Office and Government Actuarial Department (GAD). The decision to close, or restrict access to the CSPS to new starters may incur an “exit charge”. This charge will be determined by the GAD, based on the particular circumstances of the Freedom Body, and will take into account current and future scheme liabilities and the impact on the CSPS. The presumption is that the Freedom Body will pay the exit charge from its own funds and/ or reserves, although they may be able to access the voted loans fund for this purpose.

Spend control freedoms

8. Flexibility to opt in or out of central procurement

Freedoms Bodies may decide whether or not to use central procurement for all items of expenditure on a case by case basis. Where centralised procurement deals exist, Freedoms Bodies should satisfy themselves that any contract outside of these arrangements demonstrates better whole life value for money.

9. Exemption from advertising, marketing, and communications spend control

Freedom Bodies are exempt from the Cabinet Office’s central advertising, marketing and communications (AME) spending control.

10. Exemption from the commercial spend control

Freedoms Bodies are exempt from the Cabinet Office’s Commercial spend control approval processes. This does not, however, supersede the requirement to adhere to the Government Functional Standard and other Cabinet Office guidance for those Bodies that make grants using public funding.

11. Exemption from property spend controls

Freedoms Bodies are exempt from the control on property spend, including the requirement to seek approval for all new facilities management contracts and contract extensions.

12. Exemption from facilities management spend controls

Freedoms Bodies are exempt from the spend control on facilities management, enabling them to procure specialist services, and to do so independently and at pace.

Increases to delegated limits (new)

13. Approval for digital and technology spend

All public bodies are required to record all spend in a digital and technology pipeline as part of a joint Cabinet Office / departmental assurance review process. The control applies to digital spend over £100,000 and technology spend over £1 million.

For Freedoms Bodies, this threshold is increased to £10m for both digital and technology spend. This threshold will be reviewed as part of review of wider freedoms - in Q3 2024/25, or at the next Spending Review, whichever is sooner.

14. Approval for self-funded capital projects (DCMS Freedom Bodies only)

HM Treasury has increased DCMS’ Delegated Capital Expenditure Limit from £30m to £60m for majority-self-funded ALB capital projects. This avoids the requirement of Treasury Approval Points for any projects below £60m, but does not negate the requirement for DCMS approval.

Freedoms retired

The final group of Freedoms may be more accurately described as ‘service level agreements’ (SLAs). They were intended to help streamline the process of complex approvals processes for Freedoms Bodies. Following a review of these commitments, they were found to be largely redundant or irrelevant. As such they will be replaced in the manner described below.

Freedoms retired

The final group of Freedoms may be more accurately described as ‘service level agreements’ (SLAs). They were intended to help streamline the process of complex approvals processes for Freedoms Bodies. Following a review of these commitments, they were found to be largely redundant or irrelevant. As such they will be replaced in the manner described below.

  • HM Treasury commitment to respond to capital business cases within 28 days, and training to ensure business cases are proportionate and cost-effective.

   - To be replaced with departmental-led guidelines which clarify businesses case clearance processes, roles and responsibilities; these may include response time Service Level Agreements (SLAs).

  • Cabinet Office commitment to respond to redundancy and restructuring applications within two business days.

   - To be replaced with departmental-led process maps which clarify roles and responsibilities; these may include response time SLAs.

  • Pre-application guidance from HM Treasury to reduce the administrative burden from severance payment business cases and to achieve quicker decisions.

   - To be replaced with departmental-led process maps which clarify roles and responsibilities; these may include response time SLAs.

Schedule 1: List of Freedom Bodies

Department for Culture, Media & Sport (DCMS)

British Museum

Horniman Museum and Gardens

Imperial War Museums

Museum of the Home

National Gallery

National Museums Liverpool

National Portrait Gallery

Natural History Museum

Royal Armouries

Royal Museums Greenwich

Science Museum Group

Sir John Soane’s Museum

Tate Gallery

V&A Museum

Wallace Collection

British Film Institute

Historic England

British Library

Churches Conservation Trust

Department for the Environment, Food and Rural Affairs (Defra)

Royal Botanic Gardens Kew

Ministry of Defence (MOD)

National Army Museum

National Museum of the Royal Navy

Royal Air Force Museum

Schedule 2: List of Sponsor Departments

Department for Culture, Media & Sport (DCMS)

Department for the Environment, Food & Rural Affairs (Defra)

The Ministry of Defence (MOD)

Annex C: DCMS Commercial Requirements for the CCT

The following outlines in full the commercial requirements of DCMS ALBs, as well as a list of mandated reporting requirements. This document provides additional detail to ALBs Framework Documents, in order to support their compliance with commercial and procurement requirements.

Public Procurement Regulations

1. The CCT shall comply with the Public Contracts Regulations 2015 (PCR) (as amended) in its procurement activity.

Central government policy and processes

2. The CCT shall acquire goods and services through fair and open competition, in accordance with the Government Commercial Operating Standards (including the Outsourcing Playbook), delivering value for money through procurement, and operating in line with UK and other international law, including restrictions on state aid/subsidy controls.

3. Subject to the exemptions listed (‘Freedoms’) at Annex B, the CCT shall comply with current and future requirements on additional spend controls, delegated authorities and authorisations on procurement and leases as notified to them by the Department.

4. The CCT shall not be required to comply with the Cabinet Office Learning and Development Spend control Guidance, nor any of the caps or restrictions set out in it.

5. ALBs designated as a freedom body have flexibility to opt in or out of central procurement on a case by case basis. However, where possible and appropriate, the CCT shall utilise whichever Crown Commercial Services frameworks are relevant to its needs..

6. The CCT must support the wider Government Commercial Function’s strategies and programmes in their design, implementation and sustained application.

7. The CCT must embed all applicable current and future Procurement Policy Notes into its commercial operations. In particular, the CCT must:

  • Support the Government’s SME agenda through appropriate procurement activity where this does not conflict with the CCT’s charitable or Freedom body status.

  • Promote the inclusion of the Social Value Act and its associated principles in procurement activity wherever possible.

  • Comply with Government transparency policies and commitments.

8. Support Commercial Procurement and Contract Management improvement and oversight initiatives including:

  • Contract Classification for all contracts

  • Internal spend control assurance and governance processes, aligned to the department and Cabinet Office Commercial Spend Control approval processes (subject to exemptions detailed at Annex B - ‘Freedoms’)

  • Pipeline reporting where relevant

  • Assurance and audit implementation and reporting

  • Contracts Finder compliance reporting

  • Contract KPI reporting for external public publication

  • Commercial Systems and Data improvement initiatives eg. CASIE

9. Attend Cabinet Office training programmes designed to raise commercial awareness and improve commercial capability, including Playbook and GCOS masterclasses, and Contract Management Capability Training.

Departmental policy and processes

10. Subject to the exemptions listed (‘Freedoms’) at Annex B, the CCT shall comply with departmental spend controls as set by DCMS Commercial.

11. In procurement cases where the CCT is likely to exceed any applicable delegated authority limit, procurement strategy approval for the specific planned purchase must be sought from the DCMS Commercial Director.

12. Direct Award Contracts: The Churches Conservation Trust must notify DCMS a minimum of 48 hours in advance of its intention to award a single tender contract the value of which exceeds the delegated threshold. These requirements do not apply to purchases for collections, acquisitions, core public offerings, or subscriptions that support these (e.g. subscriptions to unique journals).

13. The CCT must adhere to requirements of its charitable status (where relevant), and inform the DCMS Commercial Director if there may be a conflict with public law and its charitable status.

Collaborative initiatives

The CCT shall:

  • Support all Commercial Procurement and Contract Management improvement and oversight initiatives from DCMS and the Cabinet Office.

  • Support collaborative procurement and commercial efforts across the department and its ALBs. This will include supporting the establishment of a DCMS Commercial Council or similar body, where such a group has been instituted, and wider commitments to support knowledge-sharing and training for staff involved in Commercial and Procurement activity across DCMS ALBs.

  • Support the formation and ongoing activities of a commercial function across the DCMS family of public bodies, through engagement with the DCMS Commercial team.

  • Engage with department and Government wide procurement initiatives that seek to achieve VfM from collaborative projects.

Grants and other bodies

14. If applicable, The CCT shall comply with the government functional standard for the management of grants. These standards set expectations for the management of grants, and to promote efficient and effective grant making to ensure funding is used as intended and provides value for money through high quality delivery.

15. In circumstances where The CCT finds itself having oversight and assurance of other public bodies or the procurement activities of private bodies spending public money The CCT shall ensure, as far as is reasonably practicable, and in so far as it has legal authority to do so, that all such parties adhere to the principles of Managing Public Money including the encouragement of transparent and robust practices and compliance with any applicable law.

Management Information and Compliance

16. The Department and The CCT are committed to sharing information to ensure transparency and alignment.

17. The CCT recognises that the Department will at times need to request information on an ad hoc basis and/or with a short time frame as required. The CCT must (within any reasonable timescale required by DCMS) supply any information requested by DCMS, and should proactively seek to provide DCMS with advance sight of events and publications which the Government would take an interest in.

18. In addition to this ad hoc information and open lines of communication, DCMS expects The CCT to provide regular information as listed below at Part 2 (reporting requirements). The list is not definitive, and intended to enable advanced planning for periodic Departmental commissions.

B. Reporting requirements - Freedom Bodies

Commission title Timescale DCMS lead team Purpose
Consultancy Spend Control pipeline and compliance return (including nil returns) Quarterly Commercial For DCMS and the Cabinet Office to plan and keep track of the public sector consultancy contracts and approvals
Commercial Spend Control Pipeline return (including nil returns) Quarterly Commercial For the submission of the Departments quarterly Commercial Spend Control pipeline to Cabinet Office in accordance with Cabinet Office guidelines
Contract register To be kept updated and accessible if requested by DCMS Commercial For oversight of commercial liability and risk across sectors, categories and suppliers, if a contract register is available.
Government Commercial Operating Standards (GCOS) return If required / requested Commercial For the submission of the Department’s Government Commercial Operating Standards (GCOS) return and update against improvement plans.
Contracts finder compliance report Six months Commercial Transparency policy compliance reporting
Submission of procurement spend transactions to Bravo Annually Commercial To comply with Cabinet Office spend reporting requirements
Government Key Contracts Public KPIs return (including nil responses if not on CCS) If relevant - quarterly Commercial For the submission of the Department’s quarterly Key Contracts Public KPIs return to the Cabinet Office
Procurement pipeline for publication return (including nil responses if not on CCS) Quarterly Commercial For the submission of the Departments quarterly pipeline return for publication on .Gov.uk
Social Value reporting return If required / requested Commercial To comply with Cabinet Office policy on Social Value reporting. Specifically at (a) pipeline (b) procurement strategy (c) Contract award (d) contract close subject to PPN06/2020
Prompt Payment reporting for contracts Annually Commercial To ensure accurate reporting to Cabinet Office of in-scope contracts including any exclusions and exemptions requested
Return for the review of key metrics, targets and reports related to procurement, contract management and commercial resourcing Quarterly Commercial To benchmark procurement spend, compliance assessment to policy and provide data on economic effect of spend by Departments and PBs including 3rd party spend and commercial risk reporting.
Direct and Indirect SME spend Quarterly and Annually Commercial To support the Government’s SME Agenda and the DCMS SME Action Plan

C. Delegated financial limits

All delegations are subject to the requirement that spending proposals falling within Managing Public Money Annex 2.2, box A.2.2C should be referred to DCMS. These are:

  • Items that are novel, contentious, or repercussive, even if within delegated limits

  • Items that could exceed the agreed budget and Estimate limits.

  • Contractual commitments to significant spending in future years for which plans have not been set. Appropriate planning should be carried out to account for DCMS & HMT approval if required.

  • Items requiring primary legislation (e.g. to write off NLF debt or PDC)

  • Any item which could set a potentially expensive precedent

  • Where Treasury consent is a specific requirement of legislation. Please refer to Managing Public Money and Framework Agreements for further detail.

A breakdown of delegated financial limits can be found in the delegations letter, issued by DCMS to ALBs annually shortly after the start of each financial year.

  1. Refer to Schedule 1 at the end of this document ↩

  2. Refer to Schedule 2 at the end of this document ↩

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