Lessons From Centore v The Charity Commission for Successful Charity Registration 

What this Tribunal decision means for charity registration

The 2026 first-tier tribunal decision in Centore & Anor v The Charity Commission for England and Wales offers an instructive and detailed insight at how the Charity Commission and the tribunal evaluate charitable incorporated organisation (CIO) registration applications – particularly where the subject matter is unusual or intellectually specialised.

The appeal was brought by Andrea Centore and Bernd-Christian Otto (the appellants), following the Charity Commission’s 2024 refusal of their application to register a CIO centred on the academic study of esotericism.

Their proposed organisation, the Research Network for the Study of Esoteric Practice (RENSEP), was intended to advance public education in the field.

Following the Charity Commission’s decision, which was upheld in April 2025, the appellants appealed to the tribunal – a judgment finally delivered on 20 January 2026.

The tribunal’s decision highlights key considerations for CIO registration: the drafting of charitable objects, clarity of purpose, the demonstration of public benefit, and the evidence required to show that an organisation is genuinely charitable.

Background to the charity registration refusal

The application sought to register RENSEP as a CIO with the stated purpose of “advancing the education of the public” through academic research into esotericism. The proposed activities included:

• funding and supporting academic research
• publishing accessible educational materials
• organising conferences, seminars and courses
• archiving and digitising records relevant to esoteric traditions.

Prior to the application to become a CIO, the organisation was established as an unincorporated association, with the two appellants acting as trustees.

During the tribunal hearing, two witnesses gave oral evidence (one of which was the appellants themselves). Counsel for the appellants and the Charity Commission also appeared.

Why the subject matter did not meet charity registration requirements

A good starting point is understanding esotericism itself; although even the appellants found difficulty in being able to pinpoint a conclusive definition, noting it was ‘tricky’.

Esotericism is generally understood as the teachings or forms of knowledge intended for a limited group, rather than the general public.

Esotericism therefore is an ‘umbrella term’, often associated with traditions considered “rejected knowledge” such as:

• Hermeticism (teachings attributed to Hermes Trismegistu, a syncretic Hellenistic figure)
• Kabbalah (mystical tradition within Judaism)
• Alchemy (an ancient practice blending proto-chemistry, philosophy, and mysticism)
• Astrology (interpretation of celestial phenomena and zodiacal symbolism)
• Rosicrucianism (a mystical, esoteric spiritual movement blending Christian mysticism, Hermeticism, alchemy, and Kabbalah)
• Theosophy; (from Greek for “divine wisdom,”)
• New Age movements (a loose, decentralised collection of 20th century Western spiritual and therapeutic practices)

All of which typically operate outside of mainstream religious or scientific paradigms.

The appellants argued they were seeking to advance esoteric studies from an educational standpoint, with both having extensive backgrounds in academia, conceptual history and esoteric studies prior to establishing RENSEP.

Why the Charity Commission refused this charity registration application

On 9 April 2025, the Charity Commission’s decision was upheld after review and rested on the following key principles:

1. RENSEP was not established exclusively for charitable purposes
2. The organisation failed to demonstrate sufficient public benefit
3. The Appellants failed to demonstrate how the proposed activities of the organisation would avoid conferring private benefits, thereby displaying inconsistency with charity law.

To be “established for exclusively charitable purposes” means there cannot be dual purposes and inadvertent benefits received by the organisation when operating. The expectation is the organisation is established completely for the benefit to the public and no ulterior benefit.

For RENSEP, their objects which were framed broadly to encompass esoteric traditions (Hermeticism, alchemy, astrology, Theosophy, etc.) were deemed to be unclear. The tribunal also found they did not clearly link activities to outcomes recognisable as charitable; and that the objects created too much interpretation beyond “advancement of education” as claimed by the appellants.

The tribunal concluded that the purposes of the proposed CIO did not fall clearly within the charitable head of “advancement of education”.

Further, in order to be registered as a charity, an organisation must be able to demonstrate a benefit either to the public in general, or to a “sufficient section of the public” (the “public benefit test”). Given the esoteric nature of the organisation, it was considered that an insufficient section of the public would receive a benefit, failing the “public benefit test”.

It was also possible that the beneficiaries of the organisation would be the same pool of academics from which the trustees originated, and therefore there was the possibility of private benefit.

It is notable that the tribunal did not dismiss esotericism as an unworthy academic field; rather, it required the appellants to demonstrate exclusively charitable purposes for the public benefit.

Key lessons for charity trustees preparing a charity registration application

Charitable objects are the foundation of any charitable structure. Therefore, it is important to ensure they are drafted in a manner which represents the organisation accurately.

Creating objects that are too specific could limit the organisation and hinder progress; equally, having objects which are too broad may create uncertainty for the Charity Commission and inadvertently catch interpretation which falls outside the scope of permissible charitable status.

Further, trustees should ensure that the charity will provide a benefit (i.e. will improve people’s lives), and that this benefit is available to either the general public or to a sufficiently large section of it. This is not just an esoteric academic exercise; it requires real evidence and justification.

The Centore & Anor case is therefore a reminder that charity law is purpose-driven, evidence-based and centred around public benefit above all. It illustrates the scrutiny applied by the Charity Commission and the tribunal – particularly when dealing with intellectual, metaphysical or spiritually adjacent fields such as esotericism.

What trustees should do before applying for charity registration

• Review charitable objects with clarity in mind.
• Prepare evidence of public benefit.
• Check whether activities overlap with personal or academic interests.
• Consider early advice for specialist fields.

If you have any queries or are interested in applying to register your organisation with the Charity Commission, our charity team can support you through the process.