We need to talk about secular humanism.

[ProfessorDavey]

It was updated since 2014 - it has a link to the 2021 legislation extending the exception to 2031. And if the charity is excepted and it tries to register when it is not required to, it is registering voluntarily.

Excepted charity: A charity that is not required to register with the Charity Commission because both of the following apply:

• It is permanently or temporarily excepted from the requirement to register by order of the Commission or by statutory instrument.

• Its gross annual income does not exceed £100,000.

(Sections 30(2)(b)-(c), Charities Act 2011.)
Nope nothing stopping them from applying once the Charities Commission gives the go ahead. It currently seems to say:

Most exceptions are permanent; only one – the exception for certain churches – has an end date (31 March 2031). This is to give the commission and denominational bodies time to help these churches prepare for registration by, or soon after this end date in 2031.
The commission is not ready to accept voluntary registrations yet; it will publish more information about this when it has made the necessary arrangements.

VG - are you really claiming that since 1996 (when church excepted charities have been required to register by a specific deadline to retain their charitable status) that the commission has refused to accept any registration from a church excepted charity.

So if a church excepted charity completed and submitted an application to the charity commission at any point since 1996 they will simply send it back saying 'sorry we cannot accept your application yet'.

You'll need to provide some hefty evidence to defend that position as it can be easily and definitively rebutted.

[ProfessorDavey]

Nice try

And I will try again.

My view is that the churches, and particularly the CofE have not made any meaningful effort to register all their church excepted charities through the 25 years since they have been required to register, against a deadline, in order to retain their charitable status. This view is based on clear evidence (precious few examples of £5-£100k excepted church charities having registered, claims of 35,000 still to apply for registration etc).

So you can either accept my view, or if you do not accept it then the onus is on you to provide evidence to counter that view, particular indicating that a significant number and proportion of £5-£100k excepted church charities have submitted applications for registration over that 25 year period.

[The Accountant, OBE, KC]

VG - are you really claiming that since 1996 (when church excepted charities have been required to register by a specific deadline to retain their charitable status) that the commission has refused to accept any registration from a church excepted charity.

So if a church excepted charity completed and submitted an application to the charity commission at any point since 1996 they will simply send it back saying 'sorry we cannot accept your application yet'.

You'll need to provide some hefty evidence to defend that position as it can be easily and definitively rebutted.

I am not making any claims - I am copying and pasting what is on the government's own website that contradicts the claim you made.  I see you have still failed to come up with any evidence to support your claim of wilful obstruction to registration from the religious charities.

[ProfessorDavey]

I am not making any claims - I am copying and pasting what is on the government's own website that contradicts the claim you made.

Then it is a complete irrelevance - if you are unable to support a claim that church excepted charities have not been allowed to submit applications for registration throughout the period since 1996, or indeed do not wish to make that claim we are back to my original view. That is that despite being able to apply for registration and being required to register in advance of a deadline that the churches, and in particular the CofE, not made any meaningful effort to register all their church excepted charities through those 25 years.

[The Accountant, OBE, KC]

And I will try again.

My view is that the churches, and particularly the CofE have not made any meaningful effort to register all their church excepted charities through the 25 years since they have been required to register, against a deadline, in order to retain their charitable status. This view is based on clear evidence (precious few examples of £5-£100k excepted church charities having registered, claims of 35,000 still to apply for registration etc).

So you can either accept my view, or if you do not accept it then the onus is on you to provide evidence to counter that view, particular indicating that a significant number and proportion of £5-£100k excepted church charities have submitted applications for registration over that 25 year period.

Oh I see - you have withdrawn your claim of wilful obstruction because you couldn't find any evidence to support it. You should make that clear, given how anal you are about asking other people to withdraw claims. A bit of humility is good for the soul (except you don't believe in souls) 

No I agree the churches have not registered. I am just wondering why they have not registered - specifically why the government have stated on their website that the excepted religious charities need help to voluntarily register if other charities don't need help. 

And I will reserve judgement until I have some evidence regarding why, rather than jump to assumptions like you based on your atheist prejudices.

[ProfessorDavey]

I am copying and pasting what is on the government's own website that contradicts the claim you made.

No it doesn't as the statement makes no claim that the commission has not been able to accept applications over the past 25 years. And, of course there is amply evidence that some excepted church charities have applied for registration (a small proportion) and that those applications have been accepted and approved by the commission.

I think you will find the 'not ready to accept voluntary registrations yet' is a temporary measure and more likely to be covid related as the commission is advising all charities to delay registration under the current circumstances:

'The Charity Commission is currently prioritising the response to the coronavirus crisis and its impact on the charity sector. While we are keen to take every step that we can to support charitable endeavour at this challenging time, we would ask that people intending to establish charities which do not relate to addressing the crisis and its effects consider delaying doing so, to allow our Registration team to focus on those applications which will help to address the crisis directly.

If you have already established a charity which is required to register by law, then this requirement still stands. In the current circumstances trustees may wish to consider delaying their application to register for a short time and may find that their time and resources can be focussed elsewhere. In line with the flexible and pragmatic approach which we are adopting to our regulatory work during the period of this crisis, we will not proactively enforce this duty in the short term, but in the longer term we do require all charities which are required to register to apply to do so.

So that accounts for failure to register £5k-£100k church excepted charities over the past two years. Over to you VG to justify the churches lack of action from 1996 to early 2020.

[The Accountant, OBE, KC]

Then it is a complete irrelevance - if you are unable to support a claim that church excepted charities have not been allowed to submit applications for registration throughout the period since 1996, or indeed do not wish to make that claim we are back to my original view. That is that despite being able to apply for registration and being required to register in advance of a deadline that the churches, and in particular the CofE, not made any meaningful effort to register all their church excepted charities through those 25 years.

Nope - not a complete irrelevance to point out where you are going wrong in your previous claims of wilful obstruction.

Also, again stop misrepresenting me - I have not made a claim that the excepted charities have not been allowed to submit applications since 1996.

What I said was that if the government do not want them to register now and have stated on their website that the Charity Commission is not yet ready to accept registrations and will notify when they are, I am wondering if the Charity Commission delayed registrations before. This could be a Covid-related Charity Commission staff shortage now that obviously did not exist since 1996 - but I am interested in finding out what caused the lack of progress in registrations since 1996 before jumping to any conclusions. Probably because I don't have a prejudice against religious organisations that compel me to criticise them at every available opportunity for bureaucratic issues until I know how much of the failure to register was down to their own inefficiency/ incompetence of employees / volunteers and how much may have been due to Charity Commission issues and lack of resources. 

[The Accountant, OBE, KC]

No it doesn't as the statement makes no claim that the commission has not been able to accept applications over the past 25 years. And, of course there is amply evidence that some excepted church charities have applied for registration (a small proportion) and that those applications have been accepted and approved by the commission.

I think you will find the 'not ready to accept voluntary registrations yet' is a temporary measure and more likely to be covid related as the commission is advising all charities to delay registration under the current circumstances:

'The Charity Commission is currently prioritising the response to the coronavirus crisis and its impact on the charity sector. While we are keen to take every step that we can to support charitable endeavour at this challenging time, we would ask that people intending to establish charities which do not relate to addressing the crisis and its effects consider delaying doing so, to allow our Registration team to focus on those applications which will help to address the crisis directly.

If you have already established a charity which is required to register by law, then this requirement still stands. In the current circumstances trustees may wish to consider delaying their application to register for a short time and may find that their time and resources can be focussed elsewhere. In line with the flexible and pragmatic approach which we are adopting to our regulatory work during the period of this crisis, we will not proactively enforce this duty in the short term, but in the longer term we do require all charities which are required to register to apply to do so.

So that accounts for failure to register £5k-£100k church excepted charities over the past two years. Over to you VG to justify the churches lack of action from 1996 to early 2020.

Sorry but that is not how it works - I don't need to justify their lack of action. Happy to agree there has been a lack of action though. All I needed to do is point out the lack of evidence to support your claim of wilful obstruction. If I happen to come across any information on the reason for their lack of action, I will let you know. I have not looked into what the Charity Commission advice has been since 1996 regarding the deadline and the likelihood of it being extended.

Maybe it was viewed in a similar way to the Stamp Duty holiday deadline during Covid, which was extended from 31 March to 30 June. People were predicting it would be extended before they announced the extension. Maybe the excepted charities were given the impression that the exception would be extended, so they didn't bother registering.

[ProfessorDavey]

Happy to agree there has been a lack of action though.

Good so we are in agreement - effectively we agree that the churches, and in particular the CofE, have not made any meaningful effort to register all their £5k-£100k church excepted charities through the 25 years since they have been required to register, against a deadline, in order to retain their charitable status.

[The Accountant, OBE, KC]

Good so we are in agreement - effectively we agree that the churches, and in particular the CofE, have not made any meaningful effort to register all their £5k-£100k church excepted charities through the 25 years since they have been required to register, against a deadline, in order to retain their charitable status.

No sorry - I can't agree about whether they have made any meaningful effort or not - since I don't have information on what efforts they made or didn't make and if there were any reasons for them not registering. If they were led to believe that the exception would be extended then I don't blame them for not registering as it wouldn't be a priority. As a voluntary trustee myself, I barely have time to deal with the priorities. And I have come across many voluntary trustees of the charity I volunteer for who do not seem to take their admin responsibilities seriously and it's a struggle to get them to even do what is necessary let alone any voluntary admin. 

So I can see it's possible that some of the trustees of these excepted charities may not have be motivated to deal with registering if they thought the exception would be extended and there would be no penalty for not registering.

[ProfessorDavey]

No sorry - I can't agree about whether they have made any meaningful effort or not - since I don't have information on what efforts they made or didn't make and if there were any reasons for them not registering.

Oh dear and there was me thinking we had some sort of agreement - I've laid out my evidence for lack of action, over to you to find the evidence to support an opposite conclusion that you don't agree with my claim.

So we are back to the need for you to provide evidence that:

1. The churches have made loads of applications for registration, presumably a significant proportion of their £5k-£100k excepted church charities (disproved by a quick check on the commission database that shows a tiny number of applications and the claim of 35,000 still to apply) or.
2. That they have been prevented from making applications over that 25 year period due to the commission refusing to accept their applications (disproved by a quick check on the commission database that shows that although a small proportion have been registered some have which means the commission has been happy to receive and accept applications).

Otherwise I think my claim stands.

[ProfessorDavey]

If they were led to believe that the exception would be extended then I don't blame them for not registering as it wouldn't be a priority.

Which would still support my claim that the churches have not made any meaningful effort to register, wouldn't it. If you think the issue will simply go away by you doing nothing then you are, by definition, not taking any meaningful action to register, quite the reverse.

[The Accountant, OBE, KC]

Which would still support my claim that the churches have not made any meaningful effort to register, wouldn't it. If you think the issue will simply go away by you doing nothing then you are, by definition, not taking any meaningful action to register.

Like I said I am more interested in why they or the government have not taken any meaningful action e.g. whether the government led the excepted charities to believe they did not have to register as the deadline would be extended. And would like to know why the deadline keeps being extended - is the main reason due to lack of resources for the Charity Commission to deal with thousands of applications, as has been suggested by the post on the government's website saying the Charity Commission is not ready to accept voluntary registrations yet and will notify when it is.

[ProfessorDavey]

... as has been suggested by the post on the government's website saying the Charity Commission is not ready to accept voluntary registrations yet and will notify when it is.

Red herring - as I've pointed out the commission are currently recommending that all charities delay registration due to covid. There is no evidence this was the case prior to 2020. So we've dealt with the past 2 years - how about the other 23 VG.

[The Accountant, OBE, KC]

Red herring - as I've pointed out the commission are currently recommending that all charities delay registration due to covid. There is no evidence this was the case prior to 2020. So we've dealt with the past 2 years - how about the other 23 VG.

No idea - if any information comes to light on what caused the inertia by the government and the charities, I will be sure to update you. We've had both Tory and Labour governments since then, but maybe this was not a high priority issue for either party - maybe both thought the voters were not bothered about the issue.

The current legislation seems to have added another 10 years to the deadline - so the current government still don't seem to have prioritised it as an urgent issue.

[ProfessorDavey]

- but maybe this was not a high priority issue for either party -

High enough priority to legislate via regulations that need to be passed in parliament and also require a level of statutory consultation (albeit very limited as we have seen) - to retain the special privilege for churches.

The governments of the day are indicating their priorities - they are prepared to devote parliamentary and government time and effort to maintain the special privilege. If they didn't prioritise the issue then the special privilege would have lapsed in 2001.

[ProfessorDavey]

Really good piece on the matter, written in 2016:

https://www.secularism.org.uk/opinion/2016/05/did-christian-charities-really-need-twenty-years-to-complete-a-form

Note their final line:

'Let's hope there isn't a Charities (Exception from Registration) (Amendment) Regulations 2021 being prepared.' - well guess what, when the government asked the churches (and only the churches) whether they'd like the special privilege to be extended for a further 10 years until 2031, they unanimously said 'yes'. Do bears defecate in largely wooded areas.

[Walt Zingmatilder]

Really good piece on the matter, written in 2016:

https://www.secularism.org.uk/opinion/2016/05/did-christian-charities-really-need-twenty-years-to-complete-a-form

Note their final line:

'Let's hope there isn't a Charities (Exception from Registration) (Amendment) Regulations 2021 being prepared.' - well guess what, when the government asked the churches (and only the churches) whether they'd like the special privilege to be extended for a further 10 years until 2031, they unanimously said 'yes'. Do bears defecate in largely wooded areas.

But, since this thread is about you and those like you, could you please give us a comprehensive breakdown of what's wrong about this so far it's special privilege, and lazy or complicit government but these are thinks that could happen in a solely secular context. What then is the religious aspect to the wrong
You see going on here?

[ProfessorDavey]

But, since this thread is about you and those like you,

No it isn't - it is about double standards by which some charities are required to be registered and are therefore regulated while other charities, of the same size, aren't. It amounts to a special privilege to a small groups of charities in most cases based on their being christian churches. So it is actually about everyone, given that there is significant evidence that registration and regulation of charities is very important to provide confidence in charities.

could you please give us a comprehensive breakdown of what's wrong about this

It is a special privilege - I think that all charities above an income threshold need to be registered with an independent public body that regulates their activities. To give some charities an opt out on the basis of religion is wrong and saps confidence in the entire system.

... so far it's special privilege,

Indeed, and special privileges are wrong regardless of whether they apply to religious groups, non-religious groups, groups based on gender, race etc etc - the law and its underpinning regulation should apply to everyone equally.

and lazy or complicit government but these are thinks that could happen in a solely secular context.

Government isn't being lazy as it is devoting parliamentary time and effort regularly to maintain the special privilege, so I think there is definitely a level of complicity. And that, of course would have nothing to do with the fact that there are significant numbers of active members of the organisations that might be affected as MPs and ministers, and that the 26 most senior officials of the organisation most affected are automatic members of one of the houses of parliament, with unrivalled access to MPs, ministers etc. And those 26 preside over cathedrals, within incomes in the millions, and often assets in the tens of millions which, although, charities are also unregistered.

What then is the religious aspect to the wrong
You see going on here?

The religious aspect is that the major block of excepted charities are given that special privilege specifically because they are christian churches - and there is another unfairness element, namely that no non-christian religious organisation gets the same special privilege. Now of course the answer isn't to extend exception to other religions, but to scrap it altogether. But overall this particular issue is an excellent example of the special privilege to established religion in our country.

[Walt Zingmatilder]

No it isn't - it is about double standards by which some charities are required to be registered and are therefore regulated while other charities, of the same size, aren't. It amounts to a special privilege to a small groups of charities in most cases based on their being christian churches. So it is actually about everyone, given that there is significant evidence that registration and regulation of charities is very important to provide confidence in charities.
It is a special privilege - I think that all charities above an income threshold need to be registered with an independent public body that regulates their activities. To give some charities an opt out on the basis of religion is wrong and saps confidence in the entire system.
Indeed, and special privileges are wrong regardless of whether they apply to religious groups, non-religious groups, groups based on gender, race etc etc - the law and its underpinning regulation should apply to everyone equally.
Government isn't being lazy as it is devoting parliamentary time and effort regularly to maintain the special privilege, so I think there is definitely a level of complicity. And that, of course would have nothing to do with the fact that there are significant numbers of active members of the organisations that might be affected as MPs and ministers, and that the 26 most senior officials of the organisation most affected are automatic members of one of the houses of parliament, with unrivalled access to MPs, ministers etc. And those 26 preside over cathedrals, within incomes in the millions, and often assets in the tens of millions which, although, charities are also unregistered.
The religious aspect is that the major block of excepted charities are given that special privilege specifically because they are christian churches - and there is another unfairness element, namely that no non-christian religious organisation gets the same special privilege. Now of course the answer isn't to extend exception to other religions, but to scrap it altogether. But overall this particular issue is an excellent example of the special privilege to established religion in our country.

Bollocks is this thread not about how secular humanist praxis isn't about secular humanist dogma.

Where you say this isn't about extending privilege to all and thus neutralise it. I would put that against banning it so secular humanists get what they want and a bit of a power kick as well on any occasion.

Your position Is that you want it all and you want it now.

[ProfessorDavey]

Your position Is that you want it all ...

If by that you mean that I want all charities of similar sizes to be register with and regulated by an appropriate independent public regulatory body regardless of whether the charity is religious or not, then yes, I want that. And I make no apology for wanting that.

... and you want it now.

Oh you are the comedian aren't you Vlad.

The whole point about this debate is that the church excepted charities have been told that their exception is temporary since 1963 and were given a deadline to register in 1996, which was to be 2001. Yet the special privilege will extend to at least 2031 (due to further extensions in 2001, and in 2007, and in 2012, and in 2014 and again in 2021), that is 68 years after the original decision that the exception would be temporary. Effectively I have been waiting my entire lifetime for the temporary exception to end.

So rather than want it now I think the term you need to use is that I, and others with my view, have had the patience of a saint.

[jeremyp]

If by that you mean that I want all charities of similar sizes to be register with and regulated by an appropriate independent public regulatory body regardless of whether the charity is religious or not, then yes, I want that. And I make no apology for wanting that.
Oh you are the comedian aren't you Vlad.

The whole point about this debate is that the church excepted charities have been told that their exception is temporary since 1963 and were given a deadline to register in 1996, which was to be 2001. Yet the special privilege will extend to at least 2031 (due to further extensions in 2001, and in 2007, and in 2012, and in 2014 and again in 2021), that is 68 years after the original decision that the exception would be temporary. Effectively I have been waiting my entire lifetime for the temporary exception to end.

So rather than want it now I think the term you need to use is that I, and others with my view, have had the patience of a saint.

I think the problem is extending the deadlines. Parishes know that they needn't worry about it because the deadlines always get extended. If the government said "your exemption will end in 2024, no exceptions and no extension", every CodE parish will be registered in time for the deadline. I've just checked the requirements to set up a charity and get it registered and they are not onerous. There are certain supporting documents required, but a church parish could just take the equivalent documents for another parish as a template for these. You are required to have your accounts properly audited, which is why my suggested deadline is 2024 and not 2023 - to give time for a full audited financial year to pass, but that is the only even slightly tricky hurdle.

[ProfessorDavey]

I think the problem is extending the deadlines. Parishes know that they needn't worry about it because the deadlines always get extended. If the government said "your exemption will end in 2024, no exceptions and no extension", every CodE parish will be registered in time for the deadline. I've just checked the requirements to set up a charity and get it registered and they are not onerous. There are certain supporting documents required, but a church parish could just take the equivalent documents for another parish as a template for these. You are required to have your accounts properly audited, which is why my suggested deadline is 2024 and not 2023 - to give time for a full audited financial year to pass, but that is the only even slightly tricky hurdle.

Yes I agree - until the government actually sticks to a deadline then there is no incentive for the churches to do anything to get themselves registered.

And I'd actually go further, doing nothing makes it almost certain that the government will simply extend again, so there is a clear incentive to do nothing.

So as far I can see the CofE has done virtually nothing to register its churches, given that they haven't even bothered to register their largest and most significant churches, namely their cathedrals. So as a deadline approaches their line is effectively 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission'. So the government extends and years later the CofE says, 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission'. And on it goes.

But this is, of course, a choice by the CofE - there is absolutely no requirement for 35,000 churches to be registered - it is entirely in the CofE's discretion to group churches into larger charitable units which are registered as a single charity. The most obvious block being a diocese as there are already organisational and administrative structures that require individual parishes to report to and be controlled under the diocese structure. So this would mean presenting just 44 charities for registration, rather than 35,000. And there is a precedence, in that this is exactly how the catholic church has sorted its charities. But why would the CofE make this choice, when it can just ignore the requirement knowing that it can play its trump card of 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission' every 5-10 years and still retain the special privilege.

So my solution would be that the government and commission should set a non-extendable deadline and also indicate that the commission can only register a specific number of charities per year and it is therefore up to the churches (and specifically the CofE) to work out how to organise its charities registrations to allow the commission to register them, or lose their charitable status. I suspect if the government and commission did this, we rapidly see 44 registration applications coming forward in short time.

[ProfessorDavey]

I've mentioned the cathedrals earlier in the thread, but thought I should expand on this.

The CofE cathedrals are charities, with 6 or 7 figure incomes, yet they aren't registered with the charity commission. This is really quite shocking to me as it means that the information publicly available even for the small charity that I am a trustee of (income approx. £13k) is simply unavailable in a transparent way to the public for charities that have have annual incomes in excess of £10 million and financial assets of £50 million. For registered charities all this information, including 5 years of accounts and reports plus details off the charity trustees is available to anyone on the commission searchable database, simply using the charity registration number. Yet this isn't the case for the cathedrals

So for example:

Canterbury Cathedral - has no charity registration number (as it isn't registered), has no accounts or details of trustees publicly accessible on its website. None of these details are available on the commission database as it isn't registrered - it does have the following statement buried deep in the 'legal' subsection of its website:

Canterbury Cathedral is a charity and its annual accounts are available by contacting the Cathedral’s Accounts’ Department.

A complete lack of transparency over its governance and finance as a charity.

York Minster is a little better - there is a  single year of accounts (for the most recent year) - the commission database will include five years of accounts. It has the following statement in that report:

York was selected as one of the pilot cathedrals to undertake a dummy application process with the Charity Commission, and is therefore likely to be one of the first Cathedrals to formally register, in all likelihood, at some point before the end of 2021.

Yet more delay - why on earth do you need a pilot and a dummy application? Just register! And it is now beyond the end of 2021, so presumably York Minster is now successfully registered with the commission. Nope - still not registered - a charity that reports typical annual income of over £10million, and with net assets exceeding £50million and sitting on unrestricted reserves of over £13million is not registered with any independent public regulatory body.

Quite astonishing.

[jeremyp]

Yes I agree - until the government actually sticks to a deadline then there is no incentive for the churches to do anything to get themselves registered.

And I'd actually go further, doing nothing makes it almost certain that the government will simply extend again, so there is a clear incentive to do nothing.

So as far I can see the CofE has done virtually nothing to register its churches, given that they haven't even bothered to register their largest and most significant churches, namely their cathedrals. So as a deadline approaches their line is effectively 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission'. So the government extends and years later the CofE says, 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission'. And on it goes.

But this is, of course, a choice by the CofE - there is absolutely no requirement for 35,000 churches to be registered - it is entirely in the CofE's discretion to group churches into larger charitable units which are registered as a single charity. The most obvious block being a diocese as there are already organisational and administrative structures that require individual parishes to report to and be controlled under the diocese structure. So this would mean presenting just 44 charities for registration, rather than 35,000. And there is a precedence, in that this is exactly how the catholic church has sorted its charities. But why would the CofE make this choice, when it can just ignore the requirement knowing that it can play its trump card of 'sorry, I know we were meant to register our excepted church charities, but we haven't got around to it. And there are 35,000 of them so we'd overwhelm the commission' every 5-10 years and still retain the special privilege.

So my solution would be that the government and commission should set a non-extendable deadline and also indicate that the commission can only register a specific number of charities per year and it is therefore up to the churches (and specifically the CofE) to work out how to organise its charities registrations to allow the commission to register them, or lose their charitable status. I suspect if the government and commission did this, we rapidly see 44 registration applications coming forward in short time.

No, the idea of grouping the parishes is unworkable. It would mean each parish relinquishing control of its finances and that would cause a lot of trouble. Furthermore, there are only 12,500 CofE parishes, not 35,000. The other 22,500 charities must be related to other things than actual parishes. Registering all of the 12,500 parishes in one go might be an issue, but it could be resolved by lowering the exemption limit gradually over a few years.