VAT Challenges for Conservation Organisations in 2026: Grants, Trading Activities & Partial Exemption Rules

Published by Malaika Sohail posted in Conservation Organisations, VAT on December 22, 2025

Conservation organisations will enter 2026 with tighter finances and growing VAT complications. Charity income remains under pressure, with NCVO reporting a sector-wide “big squeeze” as funding drops while public demand rises. The Charity Commission also confirms a 77% fall in charity sector headroom between 2020 and 2022. As funding structures shift, VAT challenges for conservation organisations continue to rise, especially where income comes from mixed sources such as grants, donations, admissions, workshops and retail activity.  This article explains the key VAT challenges conservation organisations face in 2026 and what to review to remain compliant.

Understanding VAT Challenges for Conservation Organisations

1. Grants vs Contracts: VAT Treatment Depends on the Agreement

Correctly identifying whether funding is a grant or a payment for services is essential.

  • Grants are usually outside the scope of VAT, as no supply is provided in return.

  • Contracts are taxable where a funder receives services, outputs or deliverables

Conservation organisations frequently receive:

  • Local authority environmental project funding
  • Research-based funding
  • Payments tied to biodiversity reports or habitat surveys

Some of these are grants; others are clear service contracts. Misclassification can cause VAT underpayments or lost VAT recovery, making strong charity VAT compliance processes important for 2026.

2. Trading Activities That Trigger VAT Registration

Many conservation charities now run trading ventures to support their work. These may include:

  • visitor centre admissions
  • retail shops
  • cafés
  • guided walks and tours
  • paid workshops or courses

HMRC treats any sale of goods or services as a business activity. If taxable turnover reaches the VAT registration threshold, VAT registration becomes mandatory.

Why this matters in 2026

More charities are crossing the threshold due to:

  • returning visitor numbers
  • seasonal tourism growth
  • diversification of income
  • new fundraising activities

Monitoring taxable turnover is crucial for charity VAT compliance and to avoid late registration penalties.

3. Charity Partial Exemption VAT Rules and VAT Recovery Limits

Conservation organisations often carry out both:

  • taxable business activities.
  • exempt or non-business charitable activities

HMRC confirms that organisations carrying out both types are partly exempt

Partial exemption requires charities to:

  • attribute VAT directly to taxable or exempt use
  • Allocate shared VAT using a fair method
  • Complete an annual adjustment

Typical shared costs include:

  • tools, equipment and maintenance
  • staff time split across projects
  • rent and utilities
  • marketing
  • IT systems

Incorrect calculations can reduce recoverable VAT or create HMRC challenges, so accurate application of charity partial exemption VAT rules is essential.

4. Separating Non-Business Activities from VAT Activity

Some conservation activities fall outside the VAT system entirely. HMRC defines non-business activity as a charitable activity with no charge or fee

Examples include:

  • volunteer conservation work
  • free habitat restoration projects
  • unpaid species monitoring
  • community outreach with no charges

VAT relating to non-business activity is not recoverable, so correct allocation is essential.

5. New VAT Relief for Donated Goods Starting in April 2026

The UK Government will introduce a new VAT relief on business donations of goods to charities from 1 April 2026.

Businesses will no longer need to account for VAT on certain donated goods when they are:

  • used by the charity in its work
  • distributed to beneficiaries

Conservation organisations may benefit from more donated materials and equipment. Support teams should keep clear records showing how items are used to apply the relief correctly.

Common VAT Risks for Conservation Organisations in 2026

Conservation charities may face:

  • VAT due on contracts wrongly treated as grants
  • late VAT registration due to trading income growth
  • Lower VAT recovery due to incorrect partial exemption working
  • incorrect treatment of non-business activities
  • poor records for donated goods under the new relief in 2026

These risks can reduce available funds for conservation work.

Practical Steps for Conservation Organisations

Conservation organisations can prepare for VAT challenges by:

  • reviewing all funding agreements to confirm VAT treatment
  • monitoring trading income monthly
  • reviewing partial exemption calculations regularly
  • separating business, exempt and non-business activity costs
  • preparing record-keeping systems for donated goods from 2026
  • documenting VAT decisions clearly for future audits

Good VAT systems can protect financial stability and support long-term conservation projects.

How Apex Accountants Can Help

At Apex Accountants, our specialist VAT team works closely with conservation organisations to put these steps into practice. We help charities assess VAT treatment on grants and contracts, monitor trading thresholds, and design partial exemption methods that withstand HMRC scrutiny. 

Our advisors also review record-keeping systems, support Making Tax Digital compliance, and provide ongoing VAT guidance so trustees and finance teams can make confident decisions while staying focused on conservation impact.

Conclusion

VAT remains one of the most complex areas for conservation organisations, especially where funding mixes grants, contracts and trading income. With clear classifications, accurate records and careful review of partial exemption rules, conservation charities can reduce risk and protect funds for environmental work.

Contact us today to discuss your VAT position and take the next step with confidence.

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