Restricted and unrestricted funds guide

Supreme
Consultants

A restricted and unrestricted funds guide for CIC directors

This is for directors of community interest companies and other grant-funded organisations in South Wales who have money sitting in one bank account and conditions attached to part of it. You will finish knowing which of your income is restricted, how to record it so a funder report takes an afternoon rather than a fortnight, and where the mistakes usually happen. About nine minutes to read.

The short version

  • Restricted funds are grant or donation income you can only spend on the purpose the funder set out in writing.
  • Unrestricted funds are everything else: trading income, free donations and surpluses your directors can spend on any objects of the company.
  • A CIC is a company, so your fund split lives in your bookkeeping and your notes, not in a separate legal account.
  • Read the offer letter before the money lands. That document, not your accounting software, decides whether a fund is restricted.
  • Unspent restricted money at year end usually carries forward or goes back to the funder. Check the clause, do not assume.

What this guide covers

If you run a community interest company and you have taken grant money, someone will eventually ask you how much of your cash is restricted. That question trips up good organisations all the time, which is why this restricted and unrestricted funds guide starts with the paperwork rather than the bookkeeping.

Restricted funds are amounts a funder has given you for a named purpose. You hold the money, but you cannot decide to spend it elsewhere. Unrestricted funds are yours to direct: trading income from contracts, unconditional donations, and whatever surplus you have built up. The difference matters because funders check it, because your accounts read differently depending on the split, and because spending restricted money on the wrong thing is a breach of the agreement you signed.

CICs sit in an awkward spot here. The detailed fund accounting rules written for registered charities do not apply to you as law. The behaviour funders expect does. Most CIC grant agreements in Wales ask for spend against budget, a forecast for the remaining period, and confirmation that the money went where it was meant to go.

Below: how to tell the two fund types apart, how to set your records up so reporting is quick, what to do with unspent money, and where we see things go wrong.

What makes a fund restricted

A fund is restricted when the person giving you the money has put a condition on what it can be used for, and you have accepted that condition. The condition usually sits in the grant offer letter, the funding agreement, or an email trail that forms part of the award.

Where the restriction comes from

In practice it comes from one of three places. A funder’s offer letter naming a project, a budget line or a time period. An application you wrote, which the funder approved on the terms you set out. Or a public appeal where you told donors the money was for a specific thing.

That last one catches people. If you run a crowdfunder for a minibus and raise more than the minibus costs, the surplus is still tied to the purpose you advertised unless you said otherwise in the appeal wording.

Common restriction types

  • Purpose: the money is for a named project, cohort or activity.
  • Budget line: the funder approved a breakdown and expects spend to follow it, often with a tolerance of five or ten per cent between headings.
  • Time: the award covers a defined period and unspent money at the end is dealt with under a specific clause.
  • Capital: the money buys an asset, and the funder may have a claim if you sell it within a set number of years.

What does not make a fund restricted: your own board deciding to earmark money for something. That is a designation. It comes out of unrestricted funds, your directors can reverse it at any meeting, and it should never be presented to a funder as restricted.

Go and read your three largest funding agreements this week and note which of these four restriction types each one uses.

What counts as unrestricted income

Unrestricted income is money your directors can spend on any activity that fits the company’s objects. For most CICs we work with in Cardiff and Newport, it comes from a short list.

  • Trading income: delivery contracts, room hire, course fees, sales.
  • Service contracts from a local authority where you are paid for delivery rather than given a grant.
  • Donations with no stated purpose, including collection tins and regular givers who were not told where the money goes.
  • Bank interest, unless the funding agreement says interest earned on grant money belongs to the grant.
  • Core cost or capacity building grants, where the funder has deliberately said the money is for running the organisation.

Why unrestricted income is worth more than its face value

Restricted money rarely covers the real cost of delivering the work. Insurance, the bookkeeping, the director’s time spent writing reports, the accountancy fee: some funders allow a share of these, many cap it at a low percentage, and a few refuse overheads entirely. The gap comes out of unrestricted funds.

So a CIC that is fully grant funded with no unrestricted income is fragile, even when the bank balance looks healthy. We have sat with CIC directors who had a strong five-figure balance and no money they were actually allowed to spend on the rent.

A note on contracts versus grants

If a council pays you to deliver a defined service and can ask for the money back if you do not deliver, that is usually trading income rather than a restricted grant, and it may have VAT and corporation tax consequences a grant would not. Check how each award is worded before you assume it is a grant.

List your income sources for the current year and mark each one restricted or unrestricted. Anything you cannot classify from the paperwork, ask the funder.

Setting your books up so reporting is quick

One bank account is fine. Funders almost never require a separate account, and juggling four accounts creates more errors than it prevents. What they do require is that you can show, on demand, how much of each award you have spent and on what.

The set-up we use in Xero

We put each restricted award on a tracking category. Every transaction that belongs to that award gets tagged, including the share of salaries, and anything untagged is unrestricted by default. That one rule removes most of the guesswork, because you can run a report at any point and see tagged spend against the budget you agreed.

Code to the funder’s budget headings, not your own. If the offer letter says staff costs, venue, materials and evaluation, make your chart of accounts or tracking lines mirror those four words. When the spend report form lands, you are copying figures across rather than rebuilding them from bank statements.

Allocating shared costs

Most costs are shared. A project worker split across two grants, the office, the phone. Pick a basis, write it down once, and apply it every month:

  • Staff: hours recorded on a timesheet, or a fixed percentage agreed with the funder at the application stage.
  • Premises: floor space or sessions used.
  • Everything else: a sensible percentage, documented, applied consistently.

Funders rarely argue with a method that is written down and used the same way every month. They do argue with a number that appears at year end with nothing behind it.

Do it monthly

A CIC that tags transactions weekly can produce a quarterly spend report in under an hour. One that leaves twelve months of untagged bank lines spends a fortnight on it and still gets questions back.

If your bookkeeping is already behind, start the tagging from today and rebuild backwards in blocks of one month.

Unspent restricted money at year end

This is the question we get asked most, usually in February when the year end is approaching and there is grant money still sitting in the account.

Read the clause first

Your funding agreement will say one of three things. The money carries forward into the next period, often with written approval. The money is repayable. Or the funder wants to discuss a variation, which is common when a project ran late for a reason outside your control.

Never quietly absorb it into general funds. If a funder later reconciles your accounts against their award and finds money they thought was ringfenced has gone on something else, you have a problem that is far harder to fix than an email asking for a carry forward.

How it shows in the accounts

A CIC files accounts at Companies House like any other company. Unspent restricted money is still your money in the balance sheet, but the useful presentation separates it out so a reader can see what is committed. We usually show the split in the notes and set out fund movements in a schedule the directors can hand straight to a funder.

The other side of this is overspend. If you have spent more on a restricted project than the award covers, the excess has landed on unrestricted funds whether you planned it or not. That is worth knowing before you commit to the next bid at the same price.

Overspend and underspend both need a conversation

Funders deal with these constantly. A six-week delay in recruiting a project worker is a normal thing to report. The relationship damage comes from silence, and from a report that arrives three months late with figures nobody can trace.

Diarise a check of restricted balances two months before your year end, and email any funder with an underspend at that point rather than after.

What funders actually ask you for

We write grant reports for more than ten community interest companies in and around Cardiff. The requests vary in wording and barely vary in substance.

The standard quarterly or six-monthly pack

  • Spend to date against the approved budget, by heading, with the variance shown.
  • A short explanation of any heading more than about ten per cent out.
  • A forecast for the rest of the funding period, so the funder can see whether you will spend the award in full.
  • Evidence for a sample of costs: invoices, payslips, a bank statement line.
  • Confirmation that restricted money has gone only where the agreement said.

What makes a report come back with questions

Round numbers with nothing behind them. A staff cost that does not reconcile to payroll. A figure that contradicts the previous quarter with no explanation. Salary recharges that nobody can tie to a timesheet.

The timing problem nobody warns you about

Grant deadlines rarely line up with your company year end. A funder may want last year’s finalised accounts in March when your accounts are not legally due until much later. That is why we get accounts finished early for CIC clients with live bids, rather than filing at the deadline, because an application that misses a window waits a full round.

Where it helps, we introduce CIC clients to a fundraising consultant who works on the next bid while we deal with the reporting on the current one.

Pull your funder’s reporting template now and check it against what your current records can produce. The gap between those two things is the work.

How CICs differ from charities here

A lot of the guidance online about restricted funds is written for registered charities, and CIC directors read it and worry about rules that do not apply to them.

The regulatory position

A community interest company is a limited company. You file accounts at Companies House, a CIC34 community interest report alongside them, a confirmation statement, and a corporation tax return with HMRC. You are regulated by the CIC Regulator on the community interest test and the asset lock. There is no Charity Commission oversight and no requirement to follow the charity sector’s accounting framework.

The practical position

Funders do not care about that distinction. They want the same discipline on restricted money from you as from a charity, because their own accountability runs the same way. So the sensible approach for a CIC is to borrow the fund discipline without pretending to be a charity in your filings.

Two things CICs forget

  • Grant income can still be taxable. Corporation tax treatment depends on the nature of the payment, and a CIC with a surplus can owe tax even where the money came from a grant. Check this before the year end rather than after.
  • The asset lock limits what happens to assets bought with any funds, restricted or not, if the company is wound up or transfers assets out.

If you are weighing up whether a CIC or a charity structure fits what you are building, read our CIC vs charity guide before you commit, because changing structure later is expensive.

What to do this month

Four steps that turn a pile of grant letters into records you can report from.

  1. Build a one page fund register List every award you currently hold: funder, amount, start and end dates, purpose in one line, budget headings, reporting dates, and the clause covering unspent money. One spreadsheet tab. Most CIC directors have this information scattered across email and have never seen it on a single page, and the gaps show up immediately.
  2. Classify every income source Go through your bank feed for the current year and mark each receipt restricted or unrestricted. Where the answer is unclear, the offer letter decides, not your memory of the conversation. If the paperwork genuinely does not say, email the funder and ask them to confirm in writing, then keep that email with the agreement.
  3. Set up tracking in your software Create a tracking category or fund code for each live restricted award and tag transactions as they come in. Match your codes to the funder’s budget headings word for word. Anything untagged is unrestricted. Tag weekly, not at year end, and the quarterly report becomes a report you run rather than a project you start.
  4. Write down your allocation method Decide how you split shared staff time, premises and overheads between funds. Write it in a short note, apply it every month, and keep the timesheets or floor plans behind it. When a funder queries a salary recharge, you send them the method and the evidence the same day.
  5. Diarise the reporting dates Put every funder deadline in a calendar with a two week warning, and add a restricted balance check two months before your company year end. Add your Companies House accounts date, the CIC34, and the corporation tax deadline to the same calendar so nothing competes for the same week.
  6. Check your unrestricted position Take total funds, subtract unspent restricted balances, and look at what is left. That number is what the organisation can actually spend on rent, insurance and the costs no grant pays for. If it is thin, that is a board conversation about core funding and trading income, and it is better had in October than in March.

Where it goes wrong

These are the five patterns we see most often when a new CIC client brings us a year of records.

  • Treating a designation as restricted Directors decide to set aside money for a future project and then describe it to a funder as restricted. It is not. A designation comes out of unrestricted funds and the board can reverse it. Calling it restricted overstates your commitments and understates the money available to run the organisation.
  • Charging overheads nobody approved A share of rent, insurance and bookkeeping gets posted against a grant that capped overheads at a set percentage or excluded them. The funder spots it at the reconciliation, disallows the cost, and the organisation repays money it has already spent. Check the overhead clause before the first invoice is coded.
  • Leaving the tagging until year end Twelve months of untagged transactions means somebody reconstructs the fund split from bank statements and guesswork. The figures that come out are defensible at best and wrong at worst. Weekly tagging takes minutes. Reconstruction takes days and still invites questions you cannot answer.
  • Assuming grant income is never taxable A CIC is a company and pays corporation tax on its taxable profits. Whether a particular grant is taxable depends on what it was for and how it was structured. We have seen CICs with a comfortable surplus and no idea a tax bill was coming. Ask the question before your year end, not after the return is due.

When to bring in an accountant

If you hold one small grant on simple terms and your bookkeeping is current, you can run the fund split yourself with a tracking category and a spreadsheet. Plenty of CICs do.

It is worth getting help when one of these is true:

  • You hold several awards at once with different budget headings, reporting dates and overhead rules, and staff time is split across them.
  • Your funder wants quarterly or six-monthly spend, budget and forecast reports and nobody in the organisation can produce them.
  • You need accounts finalised early because a grant deadline falls months before your filing date.
  • You are not sure whether your grant income is taxable, or whether past years were handled correctly.

We do CIC formation, annual CIC accounts, the community interest report and the grant reports funders ask for, on a fixed fee agreed in writing before any work starts. Calls, meetings and emails are never charged on top, and tax investigation cover is included free for every client. Answer the questions on the site and Mudassir replies the same working day.

Frequently asked questions

Does a CIC need a separate bank account for restricted funds?

Almost never. Funders ask you to account for the money separately, which is a records question rather than a banking one. One account with proper tagging gives you the same answer with fewer errors. Check your agreement in case a specific funder insists, which happens occasionally with large capital awards.

Can we move restricted money into unrestricted funds?

Only with the funder’s written agreement, or where the original terms allow it. The usual route is an email setting out what you want to do and why, agreed before you spend. Doing it first and explaining afterwards is where relationships break, and it can turn into a repayment demand.

Is restricted grant income subject to corporation tax?

It depends on what the payment was for and how the agreement is worded. A CIC is a company and pays corporation tax on taxable profits, so a grant can form part of that calculation. This is general information rather than advice on your situation, so get your own award letters looked at before the year end.

What happens if we spend restricted money on the wrong thing?

Tell the funder as soon as you find it. Most will accept a correction, a transfer from unrestricted funds to put the project back where it should be, and an explanation of how it happened. Repayment is possible. Silence until the final reconciliation makes every outcome worse.

Do the charity SORP rules apply to a community interest company?

No. A CIC is a limited company regulated by the CIC Regulator, filing accounts and a CIC34 at Companies House. The charity accounting framework is not a legal requirement for you. Funders still expect clear fund reporting, so borrow the discipline without claiming a status you do not have.

How far back should we keep grant records and invoices?

Keep invoices, payslips, bank statements and your fund allocation workings for at least six years. Some funders set longer retention periods for capital awards, particularly where they hold a claim over an asset. Check each agreement and store the paperwork with the offer letter so it stays together.

Final thoughts

The whole of this restricted and unrestricted funds guide comes down to two habits. Read the offer letter before the money arrives, so you know what you have agreed to. Tag the spend as it happens, so the report is something you run rather than something you rebuild.

Get those right and a funder request becomes an afternoon’s work. Get them wrong and you are reconstructing a year of bank statements under deadline, with a funder waiting and a grant window closing.

If you run a CIC in Cardiff, Newport, Swansea, Caerphilly, Barry or Port Talbot and your funder reports are the thing you dread, answer the questions on the site. Mudassir reads them and replies the same working day. If we are a fit, we agree your fixed fee in writing before any work starts, and we take the reporting off your desk.