This article examines the charity financial reporting regimes of three common law jurisdictions: Ireland, the UK and the US. It assesses whether these respective disclosure models improve either nonprofit behaviour or enforcement odds. Three core aspects of the regimes are reviewed: the reliability of the disclosed information, the consistency of such information and its ability to facilitate comparison between charities, and the level of enforcement arising from disclosure. Particular attention is paid to oversight mechanisms, including audits, and their rates of effectiveness in the regulation of charities. The article examines ongoing efforts to reform broader international accounting standards and considers the impact such moves are likely to have at both regional and national level for charity accountability. It concludes that given the markedly different spheres in which for-profits and nonprofits operate, care should be taken in modelling charity disclosure regimes on those developed for for-profit entities.

The nature of charity reporting and transparency is changing significantly; while the longstanding focus on financial reporting remains, there is much greater emphasis on illuminating governance systems and impacts. Regulatory regimes are becoming more polycentric with the expansion of third party watchdogs and emergence of new self-regulatory bodies. With more open access to data, transparency has become an independent force in these regimes. The article outlines a conceptual model of charity regulatory regimes and applies this to analyze recent developments of regulation-by-transparency in Canada. Although the intent of encouraging greater transparency is seldom questioned, this Canadian case study demonstrates how transparency can become politicized, damaging the relationship between the regulator and the charitable sector. In addition, the open data movement means that charities now operate in a world in which neither they nor state regulators control access and use of information.